Samsung Electronics Co., Ltd. et al.

Prosecution History analysis

Examiner Search analysis

Invalidity Framework analysis

Petition

Petition Analysis

## 1. Case Identification
- Case #: [PGR2025-00068](https://ai-lab.exparte.com/case/ptab/PGR2025-00068)
- Patent #: [12,169,756](https://ai-lab.exparte.com/patent/12169756)
- 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: Wireless Networking Device with Virtualized Resource Allocation
- Brief Description: [The ’756 patent](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1001) describes a wireless networking device that evaluates application bandwidth requirements and allocates available bandwidth from multiple transceivers. The system purports to use a processing layer, including virtual MAC and PHY interfaces, positioned between an application layer and the actual hardware MAC and PHY layers to manage resource allocation.

## 3. Grounds for Unpatentability

#### Ground 1: Claims 1-30 are obvious over Chincholi in view of Clegg under §103.
- **Prior Art Relied Upon:** [Chincholi](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1005) (WO 2013/126859) and [Clegg](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1009) (Patent 9,055,592).
- **Core Argument for this Ground:**
  - **Prior Art Mapping:** Petitioner argued that [Chincholi](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1005) teaches the core architecture of [the ’756 patent](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1001). This includes a multi-transceiver wireless device with actual MAC and PHY interfaces and a software-based "Opportunistic Multiple-Medium Access Control (MAC) Aggregation (OMMA) layer" positioned above them. Petitioner asserted this OMMA layer performs the functions of the claimed "virtual MAC interface" and "resource monitoring interface" by aggregating bandwidth and using feedback from the underlying radio access technologies (RATs) to make allocation decisions for application data streams.
  - **Motivation to Combine:** A person of ordinary skill in the art (POSITA) would combine [Clegg](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1009)'s teachings to improve [Chincholi](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1005)'s system. While [Chincholi](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1005) teaches dynamic allocation of channels, [Clegg](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1009) discloses specific techniques for mitigating carrier-specific interference *within* those channels, even across disjointed bands (e.g., 2.4 GHz and 5 GHz). Petitioner argued that adding [Clegg](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1009)’s teachings would allow [Chincholi](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1005)'s system to more flexibly and efficiently utilize available spectrum in a real-world environment with interference.
  - **Expectation of Success:** Petitioner asserted the combination would have been straightforward with a reasonable expectation of success. Both references address the common goal of increasing bandwidth efficiency in 802.11 networks, and [Clegg](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1009)'s interference mitigation techniques were described as complementary to [Chincholi](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1005)'s resource allocation framework.

#### Ground 2: Claims 1-30 are directed to patent-ineligible subject matter under §101.
- **Prior Art Relied Upon:** Not applicable.
- **Core Argument for this Ground:**
  - **Abstract Idea:** Petitioner asserted the claims are directed to the abstract idea of "using feedback information to select available communication resources." This was characterized as a fundamental concept that can be performed mentally or with pen and paper, and which has been repeatedly found to be abstract.
  - **No Inventive Concept:** The claims were argued to lack an inventive concept sufficient to transform the abstract idea into a patent-eligible application. Petitioner contended the claims merely recite the abstract idea and apply it using generic, conventional components (processors, transceivers, MAC/PHY interfaces) and vague, result-oriented functional language (e.g., "create an association," "use information to make allocation decisions," "in a manner transparent to any layer"). It was argued that the claims do not describe a specific technological improvement but rather preempt the abstract concept itself. The dependent claims were alleged to add only routine and well-known techniques, such as using IEEE 802.11 bands or conventional functional blocks.

#### Ground 3: Claims 1-30 are invalid for lack of adequate written description under §112.
- **Prior Art Relied Upon:** Not applicable.
- **Core Argument for this Ground:**
  - **Possession of the Invention:** Petitioner argued that the specification, which claims priority to 2013 provisional applications, fails to demonstrate that the inventor possessed the full scope of the challenged claims, which were drafted years later.
  - **Unsupported Limitations:** Several key claim limitations were alleged to be entirely absent from the specification. These include the device operating "in a manner transparent to any layer," the "evaluation of data transfer characteristics," the specific "resource monitoring interface," and the use of transceivers operating in "different bands of frequencies." Petitioner contended these concepts were added to the claims years after the priority date to cover features of modern standards like Wi-Fi 7, which were not contemplated in the original disclosure.

#### Ground 4: Claims 1, 18, 25, and 27 are invalid for indefiniteness under §112.
- **Prior Art Relied Upon:** Not applicable.
- **Core Argument for this Ground:**
  - **Terms of Degree:** Key claim terms of degree were argued to be indefinite because the specification provides no objective boundaries to inform a POSITA of their scope with reasonable certainty.
  - **Indefinite Terms:** The terms "partially simultaneously" (Claim 27) and "partially satisfy" (Claims 1, 18, 25) were identified as fatally indefinite. Petitioner argued that it is unclear from the intrinsic record what degree of temporal overlap qualifies as "partially simultaneous" or what minimal level of fulfillment constitutes "partially satisfying" an application's bandwidth requirement. This ambiguity allegedly makes it impossible for a POSITA to determine the scope of the claims.

## 4. Key Technical Contentions (Beyond Claim Construction)
- Petitioner’s central technical contention, which underpins the written description ground, is that the challenged claims were strategically drafted more than a decade after the priority date to read on features of the recently adopted Wi-Fi 7 (802.11be) specification. Specifically, concepts like Multi-Link Operation (MLO) across different frequency bands—which Patent Owner touts as a key feature in co-pending litigation—were argued to be entirely absent from the 2013 specification. This alleged disconnect between the original disclosure and the final claims was presented as evidence that the claims cover an invention different from the one the inventor actually possessed at the time of filing.

## 5. Relief Requested
- Petitioner requested institution of Post-Grant Review for claims 1-30 of [the ’756 patent](https://ai-lab.exparte.com/case/ptab/PGR2025-00068/doc/1001) and cancellation of all challenged claims as unpatentable under 35 U.S.C. §§101, 103, and 112.

Samsung challenges a wireless networking patent on multiple grounds (§101, §103, §112), arguing 30 claims were broadened to cover modern Wi-Fi 7 tech.