PTAB

IPR2025-01605

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 ’783 patent discloses an ultrawideband (UWB) radio transceiver or repeater designed to merge wired and wireless network devices. The system aims to provide a low-cost infrastructure solution that extends network access and manages traffic flow for devices using wide frequency bandwidths.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ganz/Larrick/Soomro - Claims 1 and 13-15 are obvious over Ganz, in further view of Larrick and 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: Petitioner argued that Ganz taught a wireless burstable communications repeater system that processes and retransmits wireless data, forming the basis of the claimed wireless network device. However, Ganz did not expressly disclose the claimed bandwidth of 100-500 MHz. Larrick was asserted to remedy this deficiency by teaching a UWB transmitter and receiver capable of operating with a 400 MHz bandwidth and data rates in the hundreds of megabits per second. The combination of Ganz and Larrick allegedly disclosed all limitations of independent claims 1 and 13 except for transmitting beacon frames (claim 1) and using Orthogonal Frequency Division Multiplexing (OFDM) (claim 13). Soomro, which taught the use of beacon frames in IEEE 802.11 networks and the use of OFDM as a physical layer, was asserted to supply these final elements.
    • Motivation to Combine: A POSITA would combine Ganz and Larrick to improve the data throughput and bandwidth of Ganz’s repeater system, which was a known industry trend. Larrick’s UWB technology offered a direct and predictable way to achieve the higher data rates that the market demanded. A POSITA would have further incorporated Soomro’s teachings to implement the well-known and conventional functions of beacon frames for network discovery and synchronization, and OFDM for improved spectral efficiency, especially since Ganz incorporated the IEEE 802.11 standard by reference, which was amended to include OFDM.
    • Expectation of Success: Petitioner contended that combining these known wireless technologies would have been straightforward for a person of ordinary skill. Implementing UWB technology into a repeater and adding standard features like beacon frames and OFDM modulation were predictable design choices with a high expectation of success.

Ground 2: Obviousness over Ganz/Larrick/Soomro/Bareis - Claims 2-5 are obvious over the combination of Ganz, Larrick, and Soomro, in further view of Bareis.

  • Prior Art Relied Upon: Ganz (’080 patent), Larrick (’523 patent), Soomro (’456 application), and Bareis (Application # 2004/0136373).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the combination established in Ground 1. Petitioner argued that the additional limitations of dependent claims 2-5 were taught by Bareis. Specifically, Bareis disclosed wireless network devices capable of transmitting and receiving at multiple data rates (e.g., "at least 100 Mbps, and beyond to over 500 Mbps"), addressing claims 2 and 3. Bareis also expressly taught that its broadband network devices could be powered by either a DC or a low-frequency AC power source, directly mapping to the limitations of claims 4 and 5.
    • Motivation to Combine: A POSITA would combine Bareis with the primary combination to add advantageous and well-known features. Offering multiple, adaptive data rates was a common technique to improve connection reliability and range based on signal quality. Similarly, providing options for both AC and DC power was a conventional design choice to increase the device's versatility and usability in different environments (e.g., wall-powered vs. battery-powered).
    • Expectation of Success: Petitioner asserted a high expectation of success, as incorporating adaptive data rates and standard AC/DC power inputs were routine and conventional modifications for wireless networking hardware.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that: claim 6 (operating in a cellular network) is obvious over Ganz/Larrick in view of Engels; claims 7-10 and 16-17 are obvious over Ganz/Larrick; claims 11-12 (coaxial/optical connection) are obvious over Ganz/Larrick in view of Bareis; and claims 14-15 (100/160 MHz bandwidth) are obvious over Ganz/Larrick in view of Gardner. These grounds relied on similar combination rationales, adding single references to teach specific, well-known networking or hardware features.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-17 of Patent 10,797,783 as unpatentable.