PTAB

IPR2026-00033

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 ’337 patent relates to an ultrawideband (UWB) radio transceiver or repeater system designed to merge wired and wireless network devices. The technology aims to provide enhanced repeater capabilities, traffic monitoring, and network security for high-bandwidth communications.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ganz, Larrick, and Roese - Claims 1-16, 20, and 24-28 are obvious over Ganz and Larrick in further view of Roese.

  • Prior Art Relied Upon: Ganz (Patent 6,584,080), Larrick (Patent 7,209,523), and Roese (Patent 7,295,556).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ganz taught a "wireless burstable communications repeater" system with the core components of the challenged claims, including transceivers and a controller for managing network traffic and connecting to a network backbone. However, Ganz did not explicitly disclose the high bandwidth and data rates recited in the claims (e.g., 100 MHz bandwidth or 100 Mbps). Petitioner asserted that Larrick remedied this deficiency by teaching a UWB transmitter and receiver system capable of operating with bandwidths of 400 MHz and data rates in the "hundreds of megabits per second." Petitioner further contended that for limitations related to "position location capabilities," Roese taught a method for a network device like a router or repeater to determine its physical location and the location of user devices connected to it.
    • Motivation to Combine: A POSITA would combine Ganz with Larrick to improve the performance of Ganz's repeater system, specifically to increase its data throughput and operate over wider bandwidths. This combination was driven by a clear industry trend toward higher data rates, and Larrick provided a known UWB solution to achieve this. A POSITA would further incorporate Roese's location-discovery methods to enhance the combined system with valuable location-based services, such as for improving network security, optimizing handovers, or enabling emergency services, which were known benefits of location awareness in wireless networks.
    • Expectation of Success: Petitioner argued that a POSITA would have a reasonable expectation of success because combining these references involved implementing known technologies for their intended purposes. Larrick provided detailed technical descriptions for its UWB components, and Roese used conventional network techniques, making their integration into Ganz’s foundational repeater architecture a straightforward engineering task.

Ground 2: Obviousness over Ganz/Larrick/Roese in view of Perlman - Claims 18-19 and 21-22 are obvious over Ganz, Larrick, and Roese in further view of Perlman.

  • Prior Art Relied Upon: Ganz (Patent 6,584,080), Larrick (Patent 7,209,523), Roese (Patent 7,295,556), and Perlman (Application # 2004/0160928).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the base combination of Ganz, Larrick, and Roese and added Perlman to teach the limitations in claims 18-19 and 21-22. Petitioner asserted that Perlman taught a "self-configuring feature" where a network processor determines an optimal set of frequency channels, thus rendering the controller self-configurable as required by claim 18. Perlman also explicitly described its system's ability to provide connectivity for mobile users with portable computers and to extend network coverage to indoor, outdoor, and moving platform environments, thereby teaching the limitations of claims 19, 21, and 22.
    • Motivation to Combine: A POSITA would be motivated to add Perlman's teachings to the base combination to improve the system's usability and operational flexibility. Self-configuration was a known and desirable feature that reduced the need for manual setup. Extending network coverage to various environments (indoor, outdoor, mobile) was a well-understood goal to make a wireless network more versatile and valuable to end-users.

Ground 3: Obviousness over Ganz/Larrick/Roese in view of Engels - Claims 17, 23, 29-40, 43, and 46-51 are obvious over Ganz, Larrick, and Roese in further view of Engels.

  • Prior Art Relied Upon: Ganz (Patent 6,584,080), Larrick (Patent 7,209,523), Roese (Patent 7,295,556), and Engels (WO 03/058850).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Engels to the base combination to teach advanced antenna technologies and network compatibilities. Petitioner argued that Engels explicitly taught the use of "multiple input multiple output (MIMO) systems" and adaptive antenna techniques like beamforming, directly mapping to the limitations of claims 17 and 29. Furthermore, Engels taught applying repeater technology to various networks, including "cellular wireless systems," thus disclosing operation in a cellular network as required by claim 23.
    • Motivation to Combine: A POSITA would incorporate Engels' teachings of MIMO and adaptive antennas to improve the robustness and efficiency of the wireless link, which were well-known benefits of such technologies (e.g., minimizing errors, optimizing data speed, and increasing capacity). Applying the repeater technology to cellular networks was a natural and obvious extension of its function, as Engels itself referenced methods for using repeaters to extend such networks.
  • Additional Grounds: Petitioner asserted a fourth ground of obviousness (Ground 4) for claims 41-42, 44-45, and 52-63 based on the combination of all five prior art references (Ganz, Larrick, Roese, Perlman, and Engels), arguing that the collective teachings rendered the remaining functional and result-oriented claims obvious.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-63 of the ’337 patent as unpatentable.