Samsung Electronics America Inc v. Massively Broadband LLC

1. Case Identification

• Case #: IPR2025-01587
• Patent #: 8,593,358
• Filed: October 21, 2025
• Petitioner(s): Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
• Patent Owner(s): Massively Broadband LLC
• Challenged Claims: 1-31

2. Patent Overview

• Title: Tunable Multiband Antenna Array for Wireless Devices
• Brief Description: The ’358 patent describes a wireless device featuring an antenna array that is actively or passively tuned to operate across multiple frequency bands. The system is designed for use with multiple transceivers and can be implemented in technologies such as multiple-input multiple-output (MIMO) systems or beam-switchable arrays.

3. Grounds for Unpatentability

Ground I: Obviousness over Wen and Poilasne - Claims 1-7, 25-31 are obvious over Wen alone or in view of Poilasne.

• Prior Art Relied Upon: Wen (European Pat. No. 1,914,835) and Poilasne (Application # 2004/0095280).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Wen disclosed a mobile wireless device with a common, multiband antenna coupled to a plurality of transceivers, where the antenna is tuned using passive elements ("leg portions") selected via electronic control. Poilasne was argued to supply the teaching of a multi-element antenna array (e.g., two or more dipole antennas) configured for advanced functionalities like MIMO operation or beam switching, which Wen’s single antenna did not explicitly form. The combination of Wen's multiband transceiver system with Poilasne's antenna array structure allegedly rendered the claims obvious.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Wen and Poilasne to improve the performance and reduce the size of wireless devices. Poilasne expressly taught that "new generations" of smaller, multi-band devices would require new antenna designs, such as arrays, to implement performance-enhancing techniques like beam switching and achieve better transmission quality.
  • Expectation of Success: A POSITA would have reasonably expected success in applying Poilasne's well-described antenna array concepts to Wen's system, as both references are directed to multiband antenna systems for mobile devices and their combination would involve routine engineering.

Ground II: Obviousness over Wen, Poilasne, and Govind - Claims 8-21, 23-24 are obvious over Wen in view of Poilasne and Govind.

• Prior Art Relied Upon: Wen, Poilasne, and Govind (Patent 7,489,914).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination of Wen and Poilasne. Petitioner asserted that while Wen taught a plurality of single-band transceivers, Govind taught the use of a single multiband transceiver capable of operating at multiple frequencies simultaneously. The argument was that it would have been obvious to substitute Wen's multiple transceivers with the more integrated multiband transceiver taught by Govind. This combination, along with the antenna array from Poilasne, allegedly met the limitations of claims reciting a single multiband transceiver.
  • Motivation to Combine: A POSITA would be motivated to incorporate Govind to reduce the number of components, device size, and cost. Wen expressly identified the challenge of limited space in multi-frequency devices, and Govind directly addressed this by teaching multiband transceivers that "can be reused at different frequency ranges, thereby reducing the number of components required."
  • Expectation of Success: The substitution of multiple single-band transceivers with a known, commercially available multiband transceiver was argued to be a simple substitution of known elements to achieve a predictable result.

Ground IV: Obviousness over Rubinshteyn, Wen, and Poilasne - Claims 1-7, 25-31 are obvious over Rubinshteyn in view of Wen and Poilasne.

• Prior Art Relied Upon: Rubinshteyn (Application # 2004/0125027), Wen, and Poilasne.
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner presented Rubinshteyn as an alternative primary reference that disclosed a wireless device with a tunable, planar antenna capable of simultaneous operation at two different frequencies. Rubinshteyn's antenna was tuned using passive elements (capacitors) selected by electronic control. Poilasne was added to provide the teaching of configuring antennas into an array for MIMO or beam switching. Wen was cited primarily to teach a plurality of transceivers, as an obvious alternative to Rubinshteyn’s single multiband transmitter/receiver configuration.
  • Motivation to Combine: A POSITA would be motivated to combine these references to create a more robust and feature-rich device. Poilasne provided the motivation to improve Rubinshteyn's antenna performance by using an array structure. A designer would also recognize that using a plurality of transceivers (from Wen) versus a single multiband transceiver (from Rubinshteyn) represented a choice between two known, predictable design alternatives depending on system constraints.
  • Expectation of Success: A POSITA would have been capable of implementing these combinations using routine engineering, as all references concern the same field of technology. Adding a plurality of transceivers to Rubinshteyn's device or modifying its antenna into an array based on Poilasne's teachings were argued to be predictable modifications.
• Additional Grounds: Petitioner asserted additional obviousness challenges, including grounds adding Vlahos (Patent 5,926,751) to the above combinations to teach RF isolation means for claim 22, and grounds based on Rubinshteyn and Poilasne without Wen for claims not requiring a plurality of transceivers.

4. Key Claim Construction Positions

• Petitioner argued that the term “isolation means for isolating said one or more components from more than one particular frequency band of said plurality of frequency bands” in claim 22 is a means-plus-function limitation under pre-AIA 35 U.S.C. §112, Paragraph 6.
• Function: "isolating said one or more components from more than one particular frequency band of said plurality of frequency bands."
• Structure: Petitioner identified the corresponding structure disclosed in the ’358 patent’s specification as "element(s) that provides overload protection, shielding, and/or filters out unwanted bands."

5. Relief Requested

• Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-31 of Patent 8,593,358 as unpatentable.