IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Oumer Teyeb et al.
`In re Patent of:
`U.S. Patent No.: 10,517,133
`Issue Date:
`Dec. 24, 2019
`Appl. Serial No.: 16/380,844
`Filing Date:
`Apr. 10, 2019
`Title:
`METHODS AND UE FOR RESUMING A CONNECTION
`WITH FULL CONFIGURATION
`
`Attorney Docket No.: 39843-0093IP1
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`PETITION FOR INTER PARTES REVIEW OF UNITED STATES PATENT
`NO. 10,517,133 PURSUANT TO 35 U.S.C. §§ 311–319, 37 C.F.R. § 42
`
`
`
`

`

`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`TABLE OF CONTENTS
`
`I. 
`
`B. 
`
`C. 
`
`II. 
`
`REQUIREMENTS FOR IPR ........................................................................ 1 
`A.  Grounds for Standing .......................................................................... 1 
`B. 
`Challenge and Relief Requested ......................................................... 1 
`THE ’133 PATENT ....................................................................................... 3 
`A. 
`Brief Description ................................................................................. 3 
`B. 
`Summary of the Prosecution History .................................................. 3 
`C. 
`Level of Ordinary Skill in the Art ....................................................... 4 
`D. 
`Claim Construction ............................................................................. 4 
`III.  THE CHALLENGED CLAIMS ARE UNPATENTABLE .......................... 5 
`A. 
`[GROUND 1] – Claims 1-20 are obvious over Schliwa-
`Bertling and 3GPP ’279 ...................................................................... 5 
`1. 
`Overview of Schliwa-Bertling .................................................. 5 
`2. 
`Overview of 3GPP ’279 ............................................................ 6 
`3. 
`The combination of Schliwa-Bertling and 3GPP
`’279 ........................................................................................... 6 
`Reasons to combine Schliwa-Bertling and 3GPP
`’279 ........................................................................................... 7 
`Analysis ..................................................................................... 9 
`5. 
`[GROUND 2A] – 3GPP ’208 anticipated and rendered
`obvious Claims 1-5 ............................................................................ 28 
`1. 
`Overview of 3GPP ’208 .......................................................... 28 
`2. 
`3GPP ’208 is prior art to the ’133 Patent ................................ 29 
`3. 
`Analysis ................................................................................... 33 
`[GROUND 2B] – Claims 6-20 are obvious over 3GPP ’208
`and Van Lieshout ............................................................................... 44 
`1. 
`Overview of Van Lieshout ...................................................... 44 
`2. 
`The combination of 3GPP ’208 and Van
`Lieshout ................................................................................... 45 
`Reasons to combine 3GPP ’208 and Van
`Lieshout ................................................................................... 45 
`Analysis ................................................................................... 47 
`4. 
`IV.  Discretion ..................................................................................................... 57 
`V. 
`PAYMENT OF FEES ................................................................................. 58 
`VI.  CONCLUSION ............................................................................................ 58 
`
`4. 
`
`3. 
`
`i
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`VII.  MANDATORY NOTICES UNDER 37 C.F.R § 42.8(a)(1) ....................... 58 
`A. 
`Real Party-In-Interest Under 37 C.F.R. § 42.8(b)(1) ........................ 58 
`B. 
`Related Matters Under 37 C.F.R. § 42.8(b)(2) ................................. 58 
`C. 
`Lead And Back-Up Counsel Under 37 C.F.R. § 42.8(b)(3) ............. 58 
`D. 
`Service Information ........................................................................... 59 
`
`
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`EXHIBITS
`
`U.S. Patent No. 10,517,133 to Teyeb et al. (“the ’133
`Patent”)
`Excerpts from the Prosecution History of the ’133 Patent
`(“the Prosecution History”)
`Declaration of Dr. Robert Akl
`
`OFFLINE#22 LTE re-establishment and resume while
`using NR PDCP, Doc. No. R2-1714208, 3GPP TSG-
`RAN WG2 Meeting #100, Nov. 27 – Dec. 1, 2017
`(“3GPP ’208”)
`U.S. Pub. No. 2012/0202478 to Van Lieshout et al. (“Van
`Lieshout”)
`U.S. Pub. No. 2016/0278160 to Schliwa-Bertling et al.
`(“Schliwa-Bertling”)
`
`RRC connection re-establishment and resume procedures
`in NR, Doc. No. R2-1710279, 3GPP TSG-RAN WG2
`#99bis, Oct. 9-13, 2017 (“3GPP ’279”)
`U.S. Pub. No. 2016/0192403 to Gupta et al. (“Gupta”)
`U.S. Pub. No. 2012/0020318 to Naoe et al. (“Naoe”)
`Declaration of Friedhelm Rodermund
`House Report No. 112-98(I), Judiciary Committee
`Summary of the America Invents Act, submitted June 1,
`2011
`
`
`SAMSUNG-1001
`
`SAMSUNG-1002
`
`SAMSUNG-1003
`SAMSUNG-1004
`
`SAMSUNG-1005
`
`SAMSUNG-1006
`
`SAMSUNG-1007
`
`SAMSUNG-1008
`SAMSUNG-1009
`SAMSUNG-1010
`SAMSUNG-1011
`
`
`
`iii
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`

`

`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`
`
`Samsung petitions for Inter Partes Review (“IPR”) of claims 1-20 (“the
`
`Challenged Claims”) of U.S. Patent No. 10,517,133 (“the ’133 Patent”). As
`
`explained in this petition, there exists a reasonable likelihood that Samsung will
`
`prevail on the Challenged Claims.
`
`I.
`
`REQUIREMENTS FOR IPR
`A. Grounds for Standing
`Samsung certifies that the ’133 Patent is available for IPR. Samsung is not
`
`barred or estopped from requesting this review of the Challenged Claims.
`
`B. Challenge and Relief Requested
`Petitioner requests IPR of the Challenged Claims on the following grounds:
`
`Ground
`1
`2A
`2B
`
`
`
`Claims
`1-20
`1-5
`6-20
`
`Basis
`Schliwa-Bertling in view of 3GPP ’279
`3GPP ’208
`3GPP ’208 in view of Van Lieshout
`
`The following table summarizes the prior art basis for each reference relied
`
`on by the present Petition with respect to the earliest effective filing date (February
`
`15, 2018, hereinafter the “Critical Date”):
`
`Reference
`3GPP ’208
`(SAMSUNG-1004)
`
`Dates
`12/01/2017 (published)
`
`1
`
`

`

`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`Dates
`08/09/2012 (published)
`
`09/22/2016 (published)
`11/17/2015 (filed)
`10/13/2017 (published)
`
`Reference
`Van Lieshout
`(SAMSUNG-1005)
`Schliwa-Bertling
`(SAMSUNG-1006)
`3GPP ’279
`(SAMSUNG-1007)
`
`
`
`None of these references were cited or relied on by the examiner during
`
`prosecution of the ’592 patent. The 3GPP ’208 reference appears on the face of
`
`the ’133 Patent, but the Examiner did not rely on or cite to it during prosecution.
`
`See generally SAMSUNG-1002; see SAMSUNG-1001, Face.
`
`The 3GPP ’208 reference is a 3GPP offline discussion document from a
`
`meeting of the TSG-RAN Working Group (#2) held between November 27 and
`
`December 1, 2017. See SAMSUNG-1004, 1. As explained in the declaration of
`
`Friedhelm Rodermund, this document was publicly available and accessible via the
`
`3GPP website by December 2, 2017—nearly a full three months prior to the
`
`Critical Date of the ’133 Patent. SAMSUNG-1010, [45]-[50]. 3GPP ’208 thus
`
`qualifies as prior art at least under 35 U.S.C. § 102. In addition, as discussed in
`
`greater detail in Section III.B.2, infra, 3GPP ’208 is eligible prior art because it
`
`was not made by Oumer Teyeb and Gunnar Mildh—the inventive entity reflected
`
`by the ’133 patent. In fact, 3GPP ’208 expressly acknowledges that it represents
`
`disclosure made by Intel and other non-Ericsson companies (of the point of novelty
`
`2
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`advanced by Ericsson in prosecution, no less).
`
`II. THE ’133 PATENT
`A. Brief Description
`The ’133 patent, entitled “Methods and UE for Resuming a Connection with Full
`
`Configuration,” was filed on April 10, 2019, and claims an earliest priority date of
`
`February 15, 2018. The patent describes a “wireless device for resuming a
`
`connection in a communication network.” SAMSUNG-1001, Abstract. The
`
`wireless device is configured to “send to a network node a request to resume a
`
`connection in a communication network,” and “receive a resume response message
`
`from the network node” including “an indication to perform a full configuration.”
`
`Id. In response, the wireless device “appl[ies] the full configuration.” Id. The
`
`’133 Patent describes that the resume response message (i.e., an
`
`“RRCConnectionResume message”) “can contain the SRB2/DRB configuration”
`
`(the bearer configuration), “and thus RRCConnectionReconfiguration” (i.e., a
`
`“reconfiguration message”) “is not needed after resume.” Id., 4:58-62.
`
`B.
`Summary of the Prosecution History
`During prosecution, Ericsson, in attempting to distinguish then-pending
`
`prior art grounds, focused on the claim 1/6/11 requirement for indicating a full
`
`configuration based on receipt of a resume message, without receiving a separate
`
`reconfiguration message; this argument relied upon by the Examiner. . See
`
`SAMSUNG-1002, 100-102 (Ericsson arguments), 12 (“The following is an
`
`3
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`examiner's statement of reasons for allowance: the prior art does not teach or
`
`adequately suggest a full configuration being indicated by a network node and
`
`applied by wireless without receiving a reconfiguration message.”).
`
`C. Level of Ordinary Skill in the Art
`As Dr. Akl notes:
`
`[A] POSITA relating to the technology of the ’133 Patent would
`have had a Bachelor’s degree in electrical engineering, computer
`engineering, computer science, or a related field, and 2-3 years of
`experience in the design or development of wireless communication
`systems, or the equivalent. Additional graduate education could
`substitute for professional experience, or significant experience in the
`field could substitute for formal education.
`
`SAMSUNG-1003, [18]-[20].
`
`D. Claim Construction
`Unless otherwise noted, terms should be given their plain meaning, but
`
`Petitioner reserves the right to respond to any constructions offered by Patent
`
`Owner or the Board. Samsung is not waiving any arguments concerning
`
`indefiniteness or claim scope.
`
`
`
`4
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`III. THE CHALLENGED CLAIMS ARE UNPATENTABLE
`A.
`[GROUND 1] – Claims 1-20 are obvious over Schliwa-Bertling
`and 3GPP ’279
`1. Overview of Schliwa-Bertling
`Schliwa-Bertling, titled “Network Nodes, a User Equipment and Methods
`
`Therein for Establishing a Connection Between the User Equipment and a Wireless
`
`Communications Network,” describes a “method performed by a wireless device
`
`for handling suspension of a connection between the wireless device and a wireless
`
`communications network.” SAMSUNG-1006, Abstract. Schliwa-Bertling
`
`describes that a network node can instruct a wireless device “to transition into a
`
`suspended state,” in which the wireless device “behave[s] as in idle mode, but
`
`caches a context related to the last connection, for example data related to security,
`
`such as keys, sequence number etc., and data related to bearers, such as signaling
`
`and data bearers.” Id., [0121], [0125]. After transitioning into the suspended state,
`
`if “the wireless device 240 wants to resume its connection 251 for some reason,
`
`e.g. due to paging of the wireless device 240, wanting to send data, etc., it [makes]
`
`contact with the network, i.e. with the first network node 211.” Id., [0126]. The
`
`wireless device “initiates the resumption by transmitting…[an] RRC Connection
`
`Resume Request” (sending a request to resume a connection) to a network node.
`
`Id., [0127]. The network node responds by sending an “RRC Connection Resume
`
`Complete” message to the UE. Id., [0129].
`
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`2. Overview of 3GPP ’279
`3GPP ’279 describes a nearly-identical suspend / resume procedure to that
`
`described in Schliwa-Bertling, shown in the following annotated FIG. 3:
`
`
`
`SAMSUNG-1007, FIG. 3 (annotated)
`
`In addition, 3GPP ’279 describes that the “RRC Connection
`
`Resume…message can optionally include [a] dedicated radio resource
`
`configuration,” thereby allowing the network to reconfigure UE’s resuming from a
`
`suspended state without sending an extra “reconfiguration” message. SAMSUNG-
`
`1007, 3; SAMSUNG-1003, [46].
`
`3.
`The combination of Schliwa-Bertling and 3GPP ’279
`In the combination, the suspend / resume procedure of Schliwa-Bertling is
`
`modified based on the techniques described in 3GPP ’279 such that the message
`
`6
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`sent by the network node to the wireless device indicating a connection has been
`
`successfully resumed can also include the “dedicated radio resource configuration”
`
`described in 3GPP ’279. SAMSUNG-1006, [0121]-[0129], FIG. 4a; SAMSUNG-
`
`1007, 3, FIG. 3; SAMSUNG-1003, [47].
`
`4.
`Reasons to combine Schliwa-Bertling and 3GPP ’279
`A POSITA would have been motivated and found it obvious to modify the
`
`suspend / resume procedure of Schliwa-Bertling based on the techniques described
`
`in 3GPP ’279. 3GPP ’279 describes including a “dedicated radio resource
`
`configuration” in the RRCConnectionResume message sent by the network node to
`
`the wireless device, rather than requiring the network node to send a separate
`
`RRCConnectionReconfiguration message to update the wireless device’s
`
`configuration. SAMSUNG-1007, 3, FIG. 3; SAMSUNG-1006, [0149];
`
`SAMSUNG-1003, [48]. Incorporating this technique into Schliwa-Bertling would
`
`greatly improve network efficiency, as it would not only eliminate the need for the
`
`network node to send the RRCConnectionReconfiguration message, but would also
`
`eliminate the need for the wireless device to send an
`
`RRCConnectionReconfigurationRequest to start the reconfiguration process.
`
`SAMSUNG-1007, 3, FIG. 3; SAMSUNG-1006, [0149]; SAMSUNG-1003, [48].
`
`This would lead to decreased network load, and ultimately to greater performance
`
`for not only the network as a whole, but possibly for individual users whose
`
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`suspended connections will resume more quickly due to the reduced back-and-
`
`forth between their wireless device and the network. Id.
`
`Further, a POSITA would have found it obvious to modify Schliwa-Bertling
`
`based on 3GPP ’279’s teachings because doing so entails the use of known
`
`solutions to improve similar systems and methods in the same way. SAMSUNG-
`
`1003, [49]. Here, “when a patent ‘simply arranges old elements with each
`
`performing the same function it had been known to perform’ and yields no more
`
`than one would expect from such an arrangement, the combination is obvious.”
`
`KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 417 (2007). A POSITA would have
`
`recognized that applying 3GPP ’279’s teachings to the wireless system of Schliwa-
`
`Bertling would have led to predictable results without significantly altering or
`
`hindering the functions performed by the system. SAMSUNG-1003, [49].
`
`In fact, a POSITA would have been motivated to incorporate the well-
`
`known wireless communication techniques of 3GPP ’279 into the Schliwa-Bertling
`
`system to achieve the predictable benefits described in 3GPP ’279. SAMSUNG-
`
`1003, [50]; see, e.g., SAMSUNG-1007, 2-5. Indeed, a POSITA would have had a
`
`reasonable expectation of success in making this modification, and would have
`
`reasonably expected to reap the benefits of the techniques described in 3GPP ’279.
`
`Id. Schliwa-Bertling and 3GPP ’279 describe similar types of wireless systems,
`
`and, in the combination, 3GPP ’279’s features are implemented in combination
`
`8
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`

`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`with the Schliwa-Bertling system just as they are in 3GPP ’279. Id.
`
`Accordingly, for at least these reasons, incorporating 3GPP ’279’s
`
`techniques into the Schliwa-Bertling system would have been routine and
`
`straightforward to a POSITA, and it would have been clear that such a combination
`
`would predictably work and provide the expected functionality. Id.; SAMSUNG-
`
`1003, [51].
`
`5.
`
`Analysis
`a.
`Claim 1
`[1.0] A method in a wireless device, the method comprising:
`To the extent the preamble is limiting, the combination of Schliwa-Bertling
`
`and 3GPP ’279 renders it obvious.
`
`In the combination, Schliwa-Bertling describes a “method performed by a
`
`wireless device for handling suspension of a connection between the wireless
`
`device and a wireless communications network.” SAMSUNG-1006, Abstract.
`
`[1.1] sending to a network node a request to resume a connection in a
`communication network;
`In the combination, Schliwa-Bertling describes that a network node can
`
`instruct a wireless device “to transition into a suspended state,” in which the
`
`wireless device “behave[s] as in idle mode, but caches a context related to the last
`
`connection, for example data related to security, such as keys, sequence number
`
`etc., and data related to bearers, such as signaling and data bearers.” SAMSUNG-
`
`9
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`

`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`1006, [0121], [0125].
`
`After transitioning into the suspended state, if “the wireless device 240
`
`wants to resume its connection 251 for some reason, e.g. due to paging of the
`
`wireless device 240, wanting to send data, etc., it [makes] contact with the
`
`network, i.e. with the first network node 211.” Id., [0126]. The wireless device
`
`“initiates the resumption by transmitting…[an] RRC Connection Resume
`
`Request” (sending a request to resume a connection) to a network node. Id.,
`
`[0127]; SAMSUNG-1003, [55]. The following annotated FIG. 4a from Schliwa-
`
`Bertling shows this process:
`
`SAMSUNG-1006, Detail of FIG. 4a (annotated)
`
`Also in the combination, 3GPP ’279 describes a nearly identical process to
`
`
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`

`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`the one described in Schliwa-Bertling, where a UE (a wireless device) sends an
`
`“RRCConnectionResumeRequest” (a request to resume a connection) to a
`
`network node, as shown in the following annotated figure. SAMSUNG-1007, 2;
`
`SAMSUNG-1003, [56]:
`
`SAMSUNG-1007, FIG. 3 (annotated)
`
`
`
`[1.2] receiving a resume message from the network node
`In the combination, Schliwa-Bertling describes that after receiving the RRC
`
`Connection Resume Request (a request to resume a connection, see [1.1], supra)
`
`from the wireless device, the network node responds by sending an “RRC
`
`Connection Resume Complete” message to the UE, as shown in the following
`
`annotated FIG. 4a from Schliwa-Bertling. SAMSUNG-1006, [0129]; SAMSUNG-
`
`1003, [57]:
`
`11
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`
`
`SAMSUNG-1006, Detail of FIG. 4a (annotated)
`
`Also in the combination, 3GPP ’279 describes a nearly identical process to
`
`the one described in Schliwa-Bertling, where a UE (a wireless device) receives an
`
`“RRCConnectionResume” (a resume message) from the network node, as shown
`
`in the following annotated figure. SAMSUNG-1007, 2; SAMSUNG-1003, [58]:
`
`12
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`SAMSUNG-1007, FIG. 3 (annotated)
`
`
`
`[1.3] the message comprising an indication to perform a full configuration; and
`In the combination, 3GPP ’279 describes that the “RRC Connection
`
`Resume…message can optionally include the dedicated radio resource
`
`configuration.” SAMSUNG-1007, 3. Because the inclusion of dedicated radio
`
`resource configuration information in the RRC Connection Resume message is
`
`optional, the presence of this configuration information is an indication to the UE
`
`to perform a configuration. Id.; SAMSUNG-1003, [59]. Likewise, the absence of
`
`this configuration information is an indication to the UE not to perform a
`
`configuration. Id. In addition, the LTE “full configuration” procedure described in
`
`the ’133 patent “includes an initialization of the radio configuration” of the
`
`wireless device. SAMSUNG-1001, 7:46-47. It would have been obvious to a
`
`13
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`POSITA to reinitialize the radio configuration of the wireless device in response to
`
`receiving the “dedicated radio resource configuration” included in the RRC
`
`Connection Resume message in 3GPP ’279. SAMSUNG-1003, [59]; SAMSUNG-
`
`1007, 3.
`
`Accordingly, the combination of Schliwa-Bertling and 3GPP ’279 renders
`
`this limitation obvious.
`
`[1.4] applying the full configuration, without receiving a reconfiguration
`message.
`In the context of this claim and element [1.4],1 a “reconfiguration message”
`
`is a message that is separate from the “resume message” and includes
`
`configuration information, such as an RRCConnectionReconfiguration message.
`
`SAMSUNG-1001, claim 1, 4:58-62; SAMSUNG-1003, [61]. Specifically, in the
`
`claim, the “resume message” is “receiv[ed]” and, by contrast, the “reconfiguration
`
`message” is not; they cannot be the same message. See SAMSUNG-1001, claim 1,
`
`limitation [1a] (“receiving a resume message from the network node”), limitation
`
`[1b] (“applying the full configuration, without receiving a reconfiguration
`
`message.”); SAMSUNG-1003, [61]. The ’133 specification reinforces this point
`
`
`1 This interpretation is also applicable to the recitations of “a reconfiguration
`
`message” in independent claims 6 and 11.
`
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`

`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`by pointing out that a “RRCConnectionResume message [i.e., a resume message]
`
`can contain SRB2/DRB configuration, and thus RRCConnectionReconfiguration
`
`[i.e., a reconfiguration message] is not needed after resume.” SAMSUNG-1001,
`
`4:58-62; SAMSUNG-1003, [61].
`
`As described above (see [1.3], supra), it would have been obvious to a
`
`POSITA for the optional “dedicated radio resource configuration” included in the
`
`RRC Connection Resume message described in 3GPP ’279 to indicate that a full
`
`configuration should be performed. In addition, it would have been obvious to
`
`POSITA for the wireless device to apply the configuration received in the
`
`RRCConnectionResume message, because otherwise the eNB sending the
`
`configuration information to the UE would be pointless. SAMSUNG-1003, [62];
`
`see, e.g., SAMSUNG-1007, 3.
`
`Further, in light of the dedicated radio resource configuration included in the
`
`resume response taught by 3GPP ’279, it would have obvious to a POSITA that
`
`sending a reconfiguration message after the RRCConnectionResume message
`
`would be both inefficient (due to an extra message being sent on the network), and
`
`pointless (due to the RRCConnectionResume message including the same
`
`configuration parameters). SAMSUNG-1003, [63]; see, e.g., SAMSUNG-1007, 3.
`
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`b.
`Claim 2
`[2.0] The method of claim 1, further comprising discarding an old bearer
`configuration and old radio parameters.
`As previously discussed (see [1.3]-[1.4], supra), the combination of
`
`Schliwa-Bertling and 3GPP ’279 renders obvious applying a full configuration to
`
`the wireless device, including the “dedicated radio resource configuration”
`
`described in 3GPP ’279. In the combination, 3GPP ’279 describes that the
`
`“dedicated radio resource configuration” applies to “all SRBs” (Signaling Radio
`
`Bearers) and to all “DRBs” (Dedicated Radio Bearers). SAMSUNG-1007, 5;
`
`SAMSUNG-1003, [64]. Because it applies to SRBs and DRBs, which are both
`
`bearers, the “dedicated radio resource configuration” is a bearer configuration. Id.
`
`It would have been obvious to a POSITA that, when the new “dedicated radio
`
`resource configuration” was applied to all SRBs and DRBs, the old bearer
`
`configuration would be discarded. Id.
`
`Also in the combination, 3GPP ’279 describes that the
`
`RRCConnectionResume message includes an “antenna info” parameter, which is a
`
`radio parameter because the antenna is an integral part of the radio subsystem of
`
`the wireless device. SAMSUNG-1007, 4; SAMSUNG-1003, [65].
`
`c.
`Claim 3
`[3.0] The method of claim 1, further comprising keeping security keys.
`As previously discussed (see [1.1]-[1.2], supra), in the combination,
`
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`Schliwa-Bertling describes a process by which a previously suspended UE
`
`connection can be resumed. Schliwa-Bertling further describes that after a resume
`
`“it is possible to continue with” (keep) “the same connection data, e.g. security
`
`context, keys, bearer setup etc.” SAMSUNG-1006, [0171]; SAMSUNG-1003,
`
`[66].
`
`d.
`Claim 4
`[4.0] The method of claim 1, further comprising receiving a configuration.
`As previously discussed, 3GPP ’279 describes that the “RRC Connection
`
`Resume” message received by the UE from the eNB “include[s] the dedicated
`
`radio resource configuration” (a configuration). SAMSUNG-1007, 3;
`
`SAMSUNG-1003, [67].
`
`e.
`Claim 5
`[5.0] The method of claim 4, further comprising applying the received
`configuration.
`As previously discussed (see [1.4], supra), it would have been obvious to a
`
`POSITA for the wireless device to apply the configuration received in the
`
`RRCConnectionResume message, because otherwise the eNB sending the
`
`configuration information to the UE would be pointless. SAMSUNG-1003, [68];
`
`see, e.g., SAMSUNG-1007, 3.
`
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`a.
`Claim 6
`[6.0] A wireless device, comprising a communication interface; and one or more
`processing circuits communicatively connected to the communication interface,
`the one or more processing circuits comprising at least one processor and
`memory, the memory containing instructions that, when executed, cause the at
`least one processor to:
`To the extent the preamble is limiting, the combination of Schliwa-Bertling
`
`and 3GPP ’279 renders it obvious. In the combination, Schliwa-Bertling describes
`
`that its system can be “be implemented through one or more processors,” such as
`
`the “processor 1280, 2280 in the wireless device 240 depicted in FIGS. 12 and 22.”
`
`SAMSUNG-1006, [0434]. Schliwa-Bertling further describes that the wireless
`
`device “may be implemented by means of a computer program product,
`
`comprising instructions, i.e., software code portions, which, when executed on at
`
`least one processor, cause the at least one processor to carry out the actions
`
`described herein.” Id., [0435]; SAMSUNG-1003, [69].
`
`[6.1] send to a network node a request to resume a connection in a
`communication network;
`See [1.1]
`
`[6.2] receive a resume response message from the network node, the message
`comprising an indication to perform a full configuration; and
`See [1.2]
`
`[6.3] apply the full configuration, without receiving a reconfiguration message.
`See [1.3]
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`b.
`Claim 7
`[7.0] The wireless device of claim 6, wherein the at least one processor is
`configured to discard an old bearer configuration and old radio parameters.
`See [2.0]
`
`c.
`Claim 8
`[8.0] The wireless device of claim 6, wherein the at least one processor is
`configured to keep security keys.
`See [3.0]
`
`d.
`Claim 9
`[9.0] The wireless device of claim 6, wherein the at least one processor is
`configured to receive a configuration.
`See [4.0]
`
`e.
`Claim 10
`[10.0] The wireless device of claim 9, wherein the at least one processor is
`configured to apply the received configuration.
`See [5.0]
`
`f.
`Claim 11
`[11.0] A network node comprising: a communication interface; and one or more
`processing circuits communicatively connected to the communication interface,
`the one or more processing circuits comprising at least one processors and
`memory, the memory containing instructions that, when executed, cause the at
`least one processor to
`In the combination, Schliwa-Bertling describes that its system can be
`
`“implemented through one or more processors, such as the processor 1180, 2380
`
`in the first network node 211 depicted in FIGS. 11 and 23.” SAMSUNG-1006,
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`[0434]. Schliwa-Bertling further teaches that network node 211 can be
`
`“implemented by means of a computer program product, comprising instructions,
`
`i.e., software code portions, which, when executed on at least one processor,
`
`cause the at least one processor to carry out the actions described herein.” Id.,
`
`[0435]. The network node 211 further includes a transmitting module “configured
`
`to transmit” information to other devices on the network, and a receiving module
`
`“configured to receive” information from other devices on the network. Id.,
`
`[0422], [0430]; SAMSUNG-1003, [77].
`
`
`[11.1] receive, from a wireless device, a request to resume a connection in a
`communication network;
`In the combination, Schliwa-Bertling describes that, after transitioning into
`
`the suspended state, if “the wireless device 240 wants to resume its connection 251
`
`for some reason, e.g. due to paging of the wireless device 240, wanting to send
`
`data, etc., it [makes] contact with the network, i.e. with the first network node
`
`211.” Id., [0126]. The wireless device “initiates the resumption by
`
`transmitting…[an] RRC Connection Resume Request” (sending a request to
`
`resume a connection) to a network node, which receives the request. Id., [0127].
`
`The following annotated FIG. 4a from Schliwa-Bertling shows this process.
`
`SAMSUNG-1003, [78]:
`
`20
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`
`
`SAMSUNG-1006, Detail of FIG. 4a (annotated)
`
`Also in the combination, 3GPP ’279 describes a nearly identical process to
`
`the one described in Schliwa-Bertling, where a UE (a wireless device) sends an
`
`“RRCConnectionResumeRequest” (a request to resume a connection) to a
`
`network node, as shown in the following annotated figure. SAMSUNG-1007, 2;
`
`SAMSUNG-1003, [79]:
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`SAMSUNG-1007, FIG. 3 (annotated)
`
`
`
`[11.2] send a resume response message to the wireless device,
`In the combination, Schliwa-Bertling describes that after receiving the RRC
`
`Connection Resume Request (a request to resume a connection, see [1.1], supra)
`
`from the wireless device, the network node responds by sending an “RRC
`
`Connection Resume Complete” message to the UE, as shown in the following
`
`annotated FIG. 4a from Schliwa-Bertling. SAMSUNG-1006, [0129]; SAMSUNG-
`
`1003, [80]:
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`22
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`
`
`SAMSUNG-1006, Detail of FIG. 4a (annotated)
`
`Also in the combination, 3GPP ’279 describes a nearly identical process to
`
`the one described in Schliwa-Bertling, where a UE (a wireless device) receives an
`
`“RRCConnectionResumeComplete” (a request to resume a connection) from the
`
`network node, as shown in the following annotated figure. SAMSUNG-1007, 2;
`
`SAMSUNG-1003, [81]:
`
`23
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No. 10,517,133
`
`SAMSUNG-1007, FIG. 3 (annotated)
`
`
`
`[11.3] the message comprising an indication to perform a full configuration,
`without sending a reconfiguration message.
`As previously discussed (see [1.3], supra), the combination of Schliwa-
`
`Bertling and 3GPP ’279 renders obvious that the resume response message
`
`comprises an indication to perform a full configuration. As also previously
`
`discussed (see [1.4], supra), the combination of Schliwa-Bertling and 3GPP ’279
`
`renders obvious performing the suspend/resume process without sending a
`
`reconfiguration message. SAMSUNG-1003, [82].
`
`g.
`Claim 12
`[12.0] The network node of claim 11, wherein the indication comprises a flag.
`The combination of Schliwa-Bertling and 3GPP ’279 renders this limitation
`
`obvious. It would have been obvious to a POSITA to use a flag to indicate
`
`24
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`Attorney Docket No. 39843-0093IP1
`IPR of U.S. Patent No