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IPR2025-01594

Samsung Electronics America Inc v. Massively Broadband LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Ultrawideband Radio Transceiver/Repeater
  • Brief Description: The ’999 patent relates to an ultrawideband (UWB) radio transceiver/repeater system designed to merge wireless and wired network devices. The system functions as a repeater to extend the range of broadband network access for various devices.

3. Grounds for Unpatentability

Ground 1: Claims 1-11, 16-25, and 27-31 are obvious over Ganz in view of Larrick

  • Prior Art Relied Upon: Ganz (Patent 6,584,080) and Larrick (Patent 7,209,523).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ganz taught a wireless high-speed data communication system using repeaters that receive, process, and retransmit wireless data, effectively disclosing the core repeater functionality of independent claims 1, 31, and 32. However, Ganz did not expressly disclose the specific bandwidth (100-500 MHz) and data rate (100-480 Mbps) limitations. Larrick allegedly supplied these missing elements by teaching a UWB transmitter and receiver system operating with a bandwidth of 400-500 MHz and capable of data rates in the "hundreds of megabits per second."
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Larrick’s UWB technology with Ganz’s repeater system to improve performance. The industry trend at the time was toward higher data rates and wider bandwidths. A POSITA would have been motivated to incorporate Larrick’s high-speed UWB capabilities into Ganz’s established repeater architecture to increase throughput and overcome the data rate limitations inherent in the Ganz system.
    • Expectation of Success: Petitioner asserted a high expectation of success because Larrick provided detailed technical descriptions of its UWB transmitter and receiver. Implementing these known UWB principles into Ganz’s repeater framework would have been a straightforward integration for a POSITA.

Ground 2: Claims 12-15 and 26 are obvious over Ganz and Larrick in further view of Engels

  • Prior Art Relied Upon: Ganz (Patent 6,584,080), Larrick (Patent 7,209,523), and Engels (WO 03/058850).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Ganz/Larrick combination by adding Engels to teach advanced antenna and network functionalities. Petitioner argued that Engels disclosed multiple-input multiple-output (MIMO) systems (claim 12), beamforming techniques (claim 13), and the use of adaptable and steerable antennas (claims 14-15). Engels also taught communication systems for indoor-outdoor environments that utilize known cellular technologies, allegedly rendering obvious the limitation of operating in a cellular network (claim 26).
    • Motivation to Combine: A POSITA would combine Engels with the Ganz/Larrick system to incorporate well-known and beneficial antenna technologies. MIMO and beamforming were conventional methods for improving signal quality, data speed, and network capacity. Adding these features would have been a predictable way to enhance the performance and reliability of the base repeater system.
    • Expectation of Success: The technologies taught by Engels (MIMO, beamforming, cellular operation) were conventional and well-understood at the time of the invention. Their implementation into a wireless repeater system was well within the skill of an ordinary artisan.

Ground 3: Claims 32-36 and 39 are obvious over Ganz and Larrick in further view of Soomro

  • Prior Art Relied Upon: Ganz (Patent 6,584,080), Larrick (Patent 7,209,523), and Soomro (Application # 2003/0002456).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Soomro to the Ganz/Larrick combination to teach the use of beacon frames and Orthogonal Frequency Division Multiplexing (OFDM). Soomro taught the use of "beacon frames" for network synchronization based on the IEEE 802.11 standard, which allegedly rendered obvious the limitation of transmitting beacon frames (claim 32). Soomro also referenced the IEEE 802.11a standard, which specified the use of OFDM for the physical layer. This allegedly rendered obvious the claims requiring data transmission via OFDM signals (claims 33 and 39).
    • Motivation to Combine: A POSITA would have been motivated to incorporate the teachings of Soomro to add standard, essential features to the Ganz/Larrick wireless system. Beacon frames were a fundamental technology for announcing a network's presence and capabilities, and OFDM was a well-known modulation technique for improving data rates and spectral efficiency, particularly in 802.11 systems.
    • Expectation of Success: Because Ganz expressly incorporated the IEEE 802.11 specification by reference, and Soomro taught features from amendments to that same standard (like 802.11a), a POSITA would have readily understood how to integrate these conventional features and would have had a reasonable expectation of success.
  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Bareis (Application # 2004/0136373) for its teachings on mesh networks and AC/DC power, and Gardner (Application # 2005/0233709) for its teachings on aggregating multiple channels to achieve wider bandwidths.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-39 of Patent 10,224,999 as unpatentable.