Samsung Electronics Co., Ltd. et al.

Prosecution History analysis

Examiner Search analysis

Invalidity Framework analysis

Petition

Petition Analysis

## 1. Case Identification
- Case #: Post Grant Review No. 2025 – 00067
- Patent #: U.S. Patent No. 12,190,198
- Filed: July 21, 2025
- Petitioner(s): [Samsung Electronics Co., Ltd.](https://ai-lab.exparte.com/party/samsung-electronics-america-inc), [Samsung Electronics America, Inc.](https://ai-lab.exparte.com/party/samsung-electronics-america-inc)
- Patent Owner(s): [XiFi Networks R&D, Inc.](https://ai-lab.exparte.com/party/xifi-networks-r-and-d-inc)
- Challenged Claims: 1-30

## 2. Patent Overview
- Title: Method for Improving Wireless Networking Operation
- Brief Description: The [’198 patent](https://ai-lab.exparte.com/case/ptab/PGR2025-00067/doc/1001) relates to a method for managing wireless network communications by using a "processing layer" containing virtual MAC and PHY interfaces. This layer is designed to evaluate the bandwidth requirements of applications and allocate available bandwidth from multiple wireless transceivers to satisfy those requirements.

## 3. Grounds for Unpatentability

#### Ground 1: Claims 1-30 are obvious over Chincholi in view of Clegg
- **Prior Art Relied Upon:** [Chincholi](https://ai-lab.exparte.com/case/ptab/PGR2025-00067/doc/1005) (WO 2013/126859) and [Clegg](https://ai-lab.exparte.com/case/ptab/PGR2025-00067/doc/1009) (Patent 9,055,592).
- **Core Argument:**
    - **Prior Art Mapping:** Petitioner argued that Chincholi taught the core architecture of the ’198 patent, including a multi-transceiver device with a central processing layer called the "Opportunistic Multiple-Medium Access Control (MAC) Aggregation (OMMA) layer." This OMMA layer allegedly functions as the claimed "processing interface" and "virtual MAC interface" by aggregating multiple actual MACs and transparently managing data streams ("IP flows") from applications. Petitioner contended Chincholi's system receives feedback on available resources (e.g., channel quality, bandwidth) from multiple Radio Access Technologies (RATs) via a "Feedback Device Classifier" module, which serves as the "resource monitoring interface," to make allocation decisions. Petitioner further argued that Clegg supplemented Chincholi by teaching specific techniques for mitigating carrier-specific interference to utilize non-contiguous portions of bandwidth, thereby disclosing the limitation of using resources that are "not unavailable."
    - **Motivation to Combine:** A person of ordinary skill in the art (POSITA) would combine Clegg’s interference mitigation techniques with Chincholi’s dynamic resource allocation system to enhance overall bandwidth efficiency. Petitioner asserted this combination was a predictable solution to the well-known goal of more flexibly and fully utilizing available spectrum in 802.11 wireless networks, the field in which both references operate.
    - **Expectation of Success:** Petitioner asserted that success would be expected because the teachings are complementary, address a common problem, and could be implemented into Chincholi’s system without significant technical challenge or modification.

#### Ground 2: Claims 1-30 are directed to patent-ineligible subject matter under 35 U.S.C. §101
- **Prior Art Relied Upon:** Not applicable.
- **Core Argument:**
    - **Abstract Idea (Alice Step 1):** Petitioner contended the claims were directed to the abstract idea of "evaluating and selecting available communication resources." The claims were characterized as result-oriented and functional, reciting the collection of information (bandwidth availability), analysis of that information, and making a selection, without providing a concrete technological improvement or specific implementation. Petitioner argued this is akin to a fundamental economic practice or mental process.
    - **No Inventive Concept (Alice Step 2):** Petitioner argued the claims lacked an inventive concept sufficient to transform the abstract idea into a patent-eligible application. The claims merely recited conventional components (transceivers, MAC/PHY interfaces) performing their well-known functions in a generic wireless networking environment. The dependent claims were dismissed as adding only routine and conventional techniques, such as specifying IEEE 802.11 frequency bands or using generic functional blocks, which do not provide "significantly more" than the abstract idea itself.

#### Ground 3: Claims 1-30 are invalid for lack of written description under 35 U.S.C. §112
- **Prior Art Relied Upon:** Not applicable.
- **Core Argument:** Petitioner argued that the specification, which claims priority to 2013 provisional applications, fails to provide adequate written description for several key claim limitations. These limitations—including operating "in a manner transparent to any layer," the "evaluation of...data transfer characteristic[s]," creating "associations," and using "different bands of frequencies"—were allegedly added in applications filed years after the priority date. Petitioner asserted these concepts are not described in the original disclosure and were added to cover features of modern standards like Wi-Fi 7 Multi-Link Operation (MLO). Therefore, Petitioner contended the inventor did not possess the full scope of the claimed invention at the time of filing, rendering the claims invalid for overreaching the inventor's contribution.

- **Additional Grounds:** Petitioner also challenged claims 1-30 for indefiniteness under §112, arguing that terms of degree such as “partially simultaneously” (claim 27) and “partially satisfy” (claims 1, 18, 25) lack objective boundaries in the specification, failing to inform a POSITA of the claim scope with reasonable certainty.

## 4. Relief Requested
- Petitioner requests institution of Post Grant Review and cancellation of claims 1-30 of the ’198 patent as unpatentable under 35 U.S.C. §§ 101, 103, and 112.

Samsung challenges a multi-link Wi-Fi patent on §101, §103 & §112 grounds, arguing all 30 claims are abstract, obvious, or lack written description.