PTAB

PGR2025-00056

Geotab Inc v. Fractus SA

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Antennas in Wireless Devices
  • Brief Description: The ’149 patent relates to antennas for wireless devices, such as mobile phones. The technology purports to optimize antenna efficiency by defining antenna shapes using specific mathematical "complexity factors" (F21 and F32) that are calculated based on the antenna's three-dimensional contour.

3. Grounds for Unpatentability

Ground 1: Claims 7-9, 11-14, 16-17, and 19-20 are obvious over Dou in view of Ciais-Multiband.

  • Prior Art Relied Upon: Dou (Application # 2007/0200773) and Ciais-Multiband (a 2004 journal article).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Dou taught a wireless device with multiple internal antennas and explicitly left the choice of a "suitable internal antenna" to a person of ordinary skill in the art (POSITA). Ciais-Multiband allegedly disclosed a compact, non-planar multiband antenna designed for mobile phones. Petitioner asserted that when the ’149 patent's own methodology is used to calculate the "complexity factors" of the Ciais-Multiband antenna, the resulting values (F21 = 1.41, F32 = 1.52) fall squarely within the ranges required by the challenged claims (F21 ≥ 1.20, F32 ≥ 1.35). The combination allegedly supplied the claimed wireless device with a ground plane and first and second non-planar antennas meeting the required complexity and frequency coverage limitations.
    • Motivation to Combine: A POSITA would combine Ciais-Multiband's antenna with Dou's device because Dou’s system required a "suitable" antenna, and Ciais-Multiband disclosed an antenna designed for the exact same purpose and environment (mobile handsets). The combination represented a straightforward implementation of known components for their intended functions.
    • Expectation of Success: Success was predictable because integrating a known antenna type (like the PIFA antenna in Ciais-Multiband) into a mobile device (as in Dou) to achieve desired frequency coverage was a conventional and well-understood practice.

Ground 2: Claims 1-20 are obvious over Dou in view of Ciais-Quadband and Nakano.

  • Prior Art Relied Upon: Dou (Application # 2007/0200773), Ciais-Quadband (a 2004 journal article), and Nakano (a 2005 journal article).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground contended that a POSITA would implement Dou’s versatile wireless device using different antennas to cover distinct frequency ranges, a common design approach. Petitioner argued Nakano disclosed a planar inverted-FL antenna for WLAN frequencies (2.4/5 GHz) whose calculated complexity factors (F21 = 1.43, F32 = 1.43) met the limitations of claims requiring a planar antenna (e.g., claim 1). Simultaneously, Ciais-Quadband disclosed a non-planar antenna for cellular frequencies whose calculated complexity factors (F21 = 1.31, F32 = 1.57) met the limitations of claims requiring a non-planar antenna (e.g., claim 7). By implementing Dou's device with a combination of these antennas, Petitioner argued that all claims 1-20 were rendered obvious.
    • Motivation to Combine: A POSITA would combine antennas from Nakano (for WLAN) and Ciais-Quadband (for cellular) into Dou's device to provide the comprehensive, multi-system wireless functionality that Dou expressly contemplated and that the market demanded.
    • Expectation of Success: There was a high expectation of success because combining multiple antennas for different communication standards into a single mobile device was a conventional and well-established design practice with predictable outcomes.

Ground 3: Claims 1, 3-5, 13, 15, 17, and 19-20 are obvious over Dou in view of Jing.

  • Prior Art Relied Upon: Dou (Application # 2007/0200773) and Jing (a 2005 conference proceeding).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner presented Jing as another example of a "suitable" planar antenna for mobile devices, covering a broad range of cellular and WLAN services. Petitioner asserted that after calculating the complexity factors for Jing's disclosed antenna shape according to the patent’s instructions, the values met the claimed thresholds (F21 = 1.43, F32 = 1.70). The combination of Dou's wireless device with Jing's planar antenna allegedly rendered claim 1 and its associated dependent claims obvious.
    • Motivation to Combine: A POSITA would have been motivated to select Jing's antenna for use in Dou's device because it was explicitly designed for mobile handsets and provided the wide, multi-band coverage that Dou's system was intended to support.
    • Expectation of Success: The combination was merely a predictable implementation of known technologies, as Jing's antenna was designed for the precise application context described in Dou.

  • Additional Grounds: Petitioner asserted further obviousness challenges by adding Hilgers (Application # 2003/0025635) to the Dou/Ciais-Multiband combination to provide GPS/Bluetooth functionality (claims 10 and 18), and by adding Ying (Patent 6,166,694) to the Dou/Jing combination to provide similar GPS/GSM functionality (claims 6 and 18).

4. Key Claim Construction Positions

  • "perimeter": Petitioner argued that the Patent Owner is collaterally estopped from arguing a construction of "perimeter" different from that adopted in a related district court case involving parent patents. The proposed construction is "boundary of an object," which critically excludes any implicit step of extending the shape of a radiating element to form a complete boundary.
  • "complexity factors F21 and F32": Petitioner contended that, unlike in related patents, the ’149 patent claims themselves explicitly define the mathematical formulas and the methodology for calculating these factors (e.g., grid creation, cell counting). Therefore, the claim language itself is definitional and governs their interpretation, limiting reliance on extrinsic evidence or the prosecution histories of other patents.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial is unwarranted, citing the USPTO Director's March 26, 2025 Memorandum on "Interim Processes for PTAB Workload Management." To address potential concerns related to co-pending litigation, Petitioner stipulated under the precedent of Sotera Wireless, Inc. v. Masimo Corp. that it will not pursue any ground raised or that reasonably could have been raised in this Post-Grant Review (PGR) in the co-pending district court litigation if the PGR is instituted.

6. Relief Requested

  • Petitioner requests institution of post-grant review and cancellation of claims 1-20 of Patent 12,095,149 as unpatentable.