PTAB

PGR2025-00069

Samsung Electronics Co Ltd v. XiFi Networks R&D Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Networking Device and Method
  • Brief Description: The ’564 patent relates to a wireless networking device that uses a processing layer, including virtual MAC and PHY layers, to evaluate bandwidth requirements of applications and allocate resources from multiple wireless transceivers to satisfy those requirements.

3. Grounds for Unpatentability

Ground 1: Claims 1-29 are obvious over Chincholi in view of Choi and Clegg

  • Prior Art Relied Upon: Chincholi (WO 2013/126859), Choi (Patent 7,206,840), and Clegg (Patent 9,055,592).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Chincholi, Choi, and Clegg disclosed all limitations of the challenged claims. Chincholi taught the core architecture of the ’564 patent, including a wireless device with multiple transceivers, each with actual MAC and PHY interfaces, and an "Opportunistic Multiple-Medium Access Control (MAC) Aggregation (OMMA) layer" that acts as the claimed processing interface. This OMMA layer aggregates bandwidth from the different transceivers to meet application data stream requirements. Petitioner contended that Chincholi’s OMMA layer, which transparently distributes packets between an IP layer and multiple radio access technologies (RATs), is equivalent to the claimed "virtual MAC interface." Chincholi further taught monitoring available resources and feeding that information back to the OMMA layer, fulfilling the "resource monitoring interface" limitation.
    • Petitioner asserted that Choi supplemented Chincholi by teaching a detailed method for dynamically selecting communication channels in an 802.11 network. Choi disclosed evaluating data transfer characteristics, such as Received Signal Strength Indication (RSSI) and Clear Channel Assessment (CCA), to select a channel with minimal interference, mapping to the claim limitation of evaluating characteristics and selecting the "better" portion. Clegg was argued to add the teaching of mitigating carrier-specific interference by "notching out" specific subcarriers, allowing for the use of only the available subset of frequencies within a given channel, as claimed.
    • Motivation to Combine: A POSITA would combine these references to improve the bandwidth efficiency of the Chincholi system. Choi’s dynamic frequency selection techniques would allow the system to more flexibly utilize available channels by minimizing interference. Clegg’s teachings on mitigating carrier-specific interference would further enhance Chincholi’s system by enabling more efficient use of bandwidth within channels that experience such interference.
    • Expectation of Success: The teachings of all three references were complementary, arose in the same field of 802.11 wireless networks, and addressed the common problem of increasing bandwidth efficiency. A POSITA would have recognized that the techniques could be implemented into Chincholi’s architecture without technical challenges.

Ground 2: Claims 1-29 are patent-ineligible under 35 U.S.C. §101

  • Core Argument for this Ground: Petitioner argued that the claims were directed to the abstract idea of "evaluating and selecting available communication resources." The claims boil down to a simple, result-oriented process: (1) feeding bandwidth availability information to an interface, (2) identifying portions of bandwidth, (3) evaluating their data transfer characteristics, and (4) determining which is "better" to use for transmission. Petitioner contended this process is a fundamental economic or mental process that can be performed by a human.
  • Petitioner further argued that the claims lacked an inventive concept sufficient to transform the abstract idea into a patent-eligible application. The claims merely recited conventional networking components (e.g., processors, MAC/PHY interfaces, transceivers) performing their generic functions in a well-known environment. The results-oriented language, such as operating in a "transparent manner" or selecting a "better" channel, did not provide any specific technical solution or improvement to computer functionality but merely stated a desired outcome.

Ground 3: Claims 1-29 are invalid for lack of written description under 35 U.S.C. §112

  • Core Argument for this Ground: Petitioner asserted that the specification failed to demonstrate that the inventor possessed the full scope of the claimed invention as of the priority date. Several key limitations, including operating in a "transparent manner," the comparative evaluation of "data transfer characteristics," the presence of a generic "resource monitoring interface," and using transceivers in "different bands of frequencies," were allegedly added to the patent family years after the original provisional applications were filed.

  • The petition argued that the specification provided no disclosure for these concepts. For instance, the word "transparent" does not appear, and there is no description of evaluating data transfer characteristics to determine which is "better." Similarly, while the patent mentions an RF block, it does not describe the broader, claimed "resource monitoring interface." Petitioner argued that these claim limitations correspond to features of modern Wi-Fi standards (e.g., Wi-Fi 7) and go far beyond the scope of the invention disclosed in the 2013 provisional applications.

  • Additional Grounds: Petitioner asserted an additional ground that claims 1, 15-16, and 18-29 are invalid for indefiniteness under §112, arguing that terms of degree like "partially/substantially simultaneously" and the subjective term "better than" lack objective boundaries in the specification, and that claim 27 is internally inconsistent.

4. Relief Requested

  • Petitioner requests institution of Post Grant Review and cancellation of claims 1-29 of the ’564 patent as unpatentable under 35 U.S.C. §§101, 103, and/or 112.