Samsung Electronics America Inc v. Massively Broadband LLC

1. Case Identification

• Case #: IPR2025-01564
• Patent #: 11,063,625
• Filed: September 26, 2025
• Petitioner(s): Samsung Electronics America, Inc.; Samsung Electronics Co., Ltd.
• Patent Owner(s): Massively Broadband LLC
• Challenged Claims: 1-33

2. Patent Overview

• Title: Steerable Antenna Technology for Avoiding Radiation
• Brief Description: The ’625 patent discloses methods and systems for wireless devices to improve safety by avoiding radiation toward a user or structure. The technology uses sensors (e.g., cameras, gyroscopes) to detect the device's orientation relative to a user, determines zones of avoidance, and adjusts the radiation pattern of a steerable antenna to direct energy away from those zones.

3. Grounds for Unpatentability

Ground 1: Claims 1-2, 5, 9-14, 17, 21-26, 29, and 33 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 limitations of the challenged claims. Schlub taught a handheld electronic device that adjusts its wireless communications based on proximity to external objects, such as a user's body. It disclosed using a wide array of sensors—including cameras, motion sensors, and capacitive sensors—to detect the device's orientation relative to the user in three-dimensional space. Based on this sensor data, processing circuitry determines the user's location and adjusts a steerable "phased antenna array" using beam steering techniques to direct radio-frequency emissions away from the user, thereby creating nulls in the user's direction. Schlub also disclosed operating on multiple bands and at frequencies within the claimed 10 GHz to 500 GHz range (specifically at 60 GHz). Dependent claims reciting specific sensor types, beamforming techniques, and repeated operation were also argued to be expressly taught by Schlub.

Ground 2: Claims 3-4, 6-8, 15-16, 18-20, 27-28, and 30-32 are obvious over Schlub in view of Seol.

• Prior Art Relied Upon: Schlub (Application # 2011/0250928) and Seol (Patent 9,362,994).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Schlub provided the foundational system of a wireless device with a sensor-guided steerable antenna. The claims challenged under this ground add limitations requiring different directional patterns for transmitting and receiving signals, and the use of Time Division Duplexing (TDD). Petitioner argued Seol explicitly taught these features, disclosing a millimeter-wave communication system that employs distinct beamforming patterns for uplink (transmission) and downlink (reception) to optimize performance. Seol also expressly taught using TDD to synchronize communication between a mobile station and a base station.
  • Motivation to Combine: A POSITA would combine Seol’s teachings with Schlub’s device to improve performance and mitigate propagation loss, a known problem in the millimeter-wave frequencies disclosed by Schlub. Seol provided an express motivation by teaching that using distinct uplink and downlink beams maximizes efficiency and diversity. Applying Seol’s TDD method was presented as a known, predictable solution for enabling the bidirectional communication necessary for Schlub’s device to operate effectively.
  • Expectation of Success: A POSITA would have had a high expectation of success, as combining these known antenna steering and communication techniques to solve a known problem in analogous art would have required only routine engineering.

Ground 3: Claims 1-33 are obvious over Prasad in view of Seol and further in view of 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 a comprehensive challenge to all claims. Prasad, the primary reference, disclosed a "smart directional radiation protection system" for mobile devices. It used sensors like gyroscopes and cameras to detect device orientation relative to a user and employed a tunable, steerable antenna to redirect radiation away from the user-facing direction. Seol was added to teach operation in the claimed 10-500 GHz frequency range and the use of TDD, as argued in Ground 2. Yin was introduced to supplement Prasad’s disclosure of determining "zones or spans of directions," as Yin explicitly taught using a camera to identify "regions" containing a person and directing radiation away from those determined zones.
  • Motivation to Combine: A POSITA would combine Prasad’s safety-focused system with Seol’s high-frequency, high-performance mmWave technology for the same reasons articulated in Ground 2. Further, a POSITA would be motivated to incorporate Yin’s method for defining discrete zones because it would simplify and improve the control logic for Prasad's steerable antenna, making it more efficient to steer radiation based on well-defined regions rather than complex object contours.
  • Expectation of Success: Petitioner argued success would be predictable. The references are all analogous art directed at steering beams in wireless systems. Combining Prasad’s safety system with Seol’s mmWave capabilities and Yin’s zone-based control logic represented the application of known techniques to improve a known device type.

4. Key Technical Contentions (Beyond Claim Construction)

• Priority Date Challenge: Petitioner contended that the challenged claims of the ’625 patent were not entitled to the priority dates of any parent applications (dating back to 2008). The petition argued that key limitations required by all claims—specifically the use of a "steerable antenna" whose beam pattern is adjusted based on sensor data detecting a user's orientation—were new matter added for the first time in the 2013 application that led to the ’625 patent. Therefore, Petitioner asserted the critical date for prior art purposes is the application’s filing date of August 14, 2013, which rendered all cited references valid prior art.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-33 of the ’625 patent as unpatentable.