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 – 00069
- Patent #: [12,250,564](https://ai-lab.exparte.com/patent/12250564)
- 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: 1-29

## 2. Patent Overview
- Title: Wireless Networking Device with Dynamic Resource Allocation
- Brief Description: [The ’564 patent](https://ai-lab.exparte.com/case/ptab/PGR2025-00069/doc/1001) describes a wireless networking device that evaluates application bandwidth requirements and wireless transceiver bandwidth availabilities to allocate resources. The system purports to use a "processing layer" with "virtual MAC" and "virtual PHY" layers positioned between the application and the actual hardware layers to manage this resource allocation.

## 3. Grounds for Unpatentability

#### Ground 1: Claims 1-29 are obvious over Chincholi, Choi, and Clegg
- **Prior Art Relied Upon:** [Chincholi](https://ai-lab.exparte.com/case/ptab/PGR2025-00069/doc/1005) (WO 2013/126859), [Choi](https://ai-lab.exparte.com/case/ptab/PGR2025-00069/doc/1016) (Patent 7,206,840), and [Clegg](https://ai-lab.exparte.com/case/ptab/PGR2025-00069/doc/1009) (Patent 9,055,592).
- **Core Argument for this Ground:**
  - **Prior Art Mapping:** Petitioner argued that the combination of these references taught all limitations of the challenged claims. Chincholi was asserted to disclose the fundamental architecture: a multi-transceiver wireless device (e.g., an access point) with a processing interface—its "Opportunistic Multiple-Medium Access Control (MAC) Aggregation (OMMA) layer"—that sits above the actual MAC/PHY layers. This OMMA layer functions as the claimed "virtual MAC interface" by aggregating bandwidth from multiple transceivers to serve application data streams. Choi was argued to teach the claimed evaluation of channel quality, disclosing a dynamic frequency selection scheme for 802.11 networks that measures "data transfer characteristics" like Received Signal Strength Indication (RSSI) and Clear Channel Assessment (CCA) to select the channel with minimum interference. Finally, Clegg was argued to teach the use of specific resource subsets by disclosing methods to mitigate carrier-specific interference, such as "notching out" problematic subcarriers to utilize the remaining available spectrum within a channel, even across disjointed bands.
  - **Motivation to Combine:** A person of ordinary skill in the art (POSITA) would have been motivated to combine these references to improve the performance of Chincholi’s system. A POSITA would integrate Choi's detailed channel measurement and selection techniques to make Chincholi's bandwidth management more robust and interference-aware. Further, a POSITA would incorporate Clegg's interference mitigation techniques to allow Chincholi's system to more flexibly and efficiently utilize bandwidth on channels experiencing known types of interference.
  - **Expectation of Success:** Petitioner asserted a high expectation of success, as all three references operate in the same field of 802.11 wireless networking, address common and well-understood challenges of bandwidth efficiency and interference, and provide complementary solutions that could be implemented together without undue experimentation.

#### Ground 2: Claims 1-29 are patent-ineligible under §101
- **Prior Art Relied Upon:** Not applicable.
- **Core Argument for this Ground:**
  - **Abstract Idea:** Petitioner argued that all challenged claims are directed to the patent-ineligible abstract idea of "evaluating and selecting available communication resources." Petitioner contended this is a fundamental economic practice or a method of organizing human activity that can be performed mentally or with pen and paper.
  - **No Inventive Concept:** Applying the second step of the *Alice* framework, Petitioner asserted the claims lack an inventive concept sufficient to transform the abstract idea into a patent-eligible application. The claims merely recite the abstract idea being performed by generic, conventional computer components (e.g., a "processing interface," "wireless transceivers," "MAC and PHY interfaces") without any improvement to the functioning of the components themselves. The claim language was characterized as purely functional and results-oriented (e.g., "evaluate the data transfer characteristics," determine which is "better," "satisfy" a requirement), failing to specify *how* these results are achieved in a technologically innovative way. Petitioner further argued that the dependent claims add only other routine and conventional networking techniques, such as using an access point or aggregating bandwidth, which do not supply an inventive concept.

#### Ground 3: Claims 1-29 are invalid for Lack of Written Description under §112
- **Prior Art Relied Upon:** Not applicable.
- **Core Argument for this Ground:**
  - **Possession of the Invention:** Petitioner argued that the ’564 patent’s specification, which relies on a 2013 priority date, fails to demonstrate that the inventor possessed the full scope of the claimed invention at the time of filing. The petition asserted that many key claim limitations were added in related applications years later, allegedly to cover features of modern standards like Wi-Fi 7 (802.11be), and find no support in the original disclosure.
  - **Unsupported Limitations:** Petitioner identified several claim limitations as lacking adequate written description support. These include: operating "in a manner transparent to any layer" above the processing interface; evaluating "data transfer characteristics" and determining if one is "better" than another; a "resource monitoring interface" as claimed; transmitting "without requiring disassociation" of the recipient; and using transceivers adapted to emit waves in "first and second different bands of frequencies." For each, Petitioner argued the specification is silent on these concepts, providing no details that would have informed a POSITA that the inventor had invented these specific features as of 2013.

- **Additional Grounds:** Petitioner also challenged claims 1-29 as indefinite under §112. The challenge asserted that terms of degree such as "better than," "partially simultaneously," and "substantially simultaneously" are subjective and fail to inform a POSITA of the claim scope with reasonable certainty, as the specification provides no objective boundaries or metrics for these terms.

## 4. Relief Requested
- Petitioner requested institution of Post Grant Review and cancellation of claims 1-29 of Patent 12,250,564 as unpatentable under 35 U.S.C. §§ 101, 103, and 112.

Samsung challenges wireless networking patent on 3 grounds, citing obviousness, §101 ineligibility, and lack of written description for all 29 claims.