Samsung Electronics America Inc v. Massively Broadband LLC

1. Case Identification

• Case #: IPR2025-01563
• Patent #: 11,876,548
• Filed: October 9, 2025
• Petitioner(s): Samsung Electronics America, Inc., Samsung Electronics Co., Ltd.
• Patent Owner(s): Massively Broadband LLC
• Challenged Claims: 1-16

2. Patent Overview

• Title: Steerable Antenna Technologies for Wireless Devices
• Brief Description: The ’548 patent relates to a system for wireless devices that uses various sensors, such as cameras and gyroscopes, to determine a device’s orientation relative to a user or structure. This information is then used to steer an antenna's radiation pattern away from the user, purportedly improving safety and performance.

3. Grounds for Unpatentability

Ground 1: Anticipation/Obviousness over Schlub - Claims 1-3, 6-9, and 12-14 are anticipated by or obvious over Schlub.

• Prior Art Relied Upon: Schlub (Application # 2011/0250928).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Schlub disclosed all elements of the independent claims. Schlub taught a handheld electronic device that uses a wide range of sensors (including motion sensors, capacitance sensors, and cameras) to determine its orientation and proximity to external objects, such as a user's body. Based on this sensor data, processing circuitry determines an appropriate action, which includes adjusting a "phased antenna array" to modify "the direction in which the antenna array is operating" to avoid the user. Petitioner asserted that Schlub's disclosure of a phased antenna array operating "at 60 GHz" explicitly met the claimed frequency range of 10 GHz to 500 GHz.
  • Key Aspects: This ground asserted that Schlub's comprehensive disclosure of sensor-based beam steering for user avoidance directly mapped to the core invention of the ’548 patent.

Ground 2: Obviousness over Schlub and Oshiyama - Claims 4-5, 10-11, and 15-16 are obvious over Schlub in view of Oshiyama.

• Prior Art Relied Upon: Schlub (Application # 2011/0250928) and Oshiyama (Application # 2006/0097918).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Schlub provided the base system of a sensor-guided steerable antenna, as detailed in Ground 1. The challenged dependent claims primarily add the limitation of the antenna being configured for transmitting and receiving simultaneously in a plurality of different bands. Petitioner asserted that Oshiyama supplied this missing element, as it disclosed a single-element, multiband antenna for mobile devices explicitly designed for "simultaneous antenna operation in multiple frequency bands," citing concurrent GPS and cellular use as an example.
  • Motivation to Combine: A POSITA would combine Oshiyama’s teachings with Schlub's system to achieve the well-known and desirable benefit of supporting simultaneous communications in a mobile device. This combination would also advance the established industry goal of reducing overall antenna size and weight compared to using multiple separate antennas.
  • Expectation of Success: Petitioner contended that the combination would have been straightforward and predictable. Since antennas with simultaneous multi-band operation were well-known, incorporating this functionality into Schlub's steerable antenna system would have required only routine engineering.

Ground 3: Obviousness over Prasad, Seol, and Yin - Claims 1-3, 6-9, and 12-14 are obvious over Prasad in view of Seol and Yin.

• Prior Art Relied Upon: Prasad (Application # 2013/0237272), Seol (Patent 9,362,994), and Yin (WO 2014/194455).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground presented an alternative invalidity theory for the independent claims. Petitioner argued that Prasad disclosed a "smart directional radiation protection system" using sensors like gyroscopes and cameras to detect a device's orientation and then employing beamforming to redirect radiation away from a "user-facing direction." Seol was cited to teach operating such a system in the claimed high-frequency range, as it described beamforming in the millimeter-wave (mmWave) band (30-300 GHz). To the extent Prasad's disclosure of determining avoidance areas was considered insufficient, Yin was introduced to teach explicitly determining "zones or spans of directions" by using a camera to identify people in a 3D space and define "regions" to avoid with radiation.
  • Motivation to Combine: A POSITA would combine Prasad's radiation-avoidance system with Seol's mmWave technology to gain access to the higher data rates available in that spectrum, a key driver of wireless innovation. Seol provided a strong motivation by teaching that beamforming is crucial for mitigating the increased path loss inherent to mmWave frequencies. Adding Yin's method for defining zones was argued to be a logical and well-understood implementation for improving the system's control.
  • Expectation of Success: Petitioner asserted that the combination was predictable, as both antenna steering and mmWave communications were well-established fields. A POSITA would have been capable of configuring Prasad's system to operate at mmWave frequencies with a high expectation of success.

• Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) against claims 4-5, 10-11, and 15-16 based on the combination of Prasad, Seol, Yin, and Oshiyama, relying on Oshiyama to add simultaneous multi-band operation to the base combination of Ground 3.

4. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1-16 of Patent 11,876,548 as unpatentable.