IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`David Hammarwall, et al.
`In re Patent of:
`9,300,432 Attorney Docket No.: 39843-0097IP1
`U.S. Patent No.:
`March 29, 2016
`
`Issue Date:
`Appl. Serial No.: 13/660,158
`
`Filing Date:
`October 25, 2012
`
`Title:
`LINK QUALITY ESTIMATION AND APPARATUS IN A TELE-
`COMMUNICATION SYSTEM
`
`
`
`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. 9,300,432 PURSUANT TO 35 U.S.C. §§ 311–319, 37 C.F.R. § 42
`
`
`
`

`

`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
`
`TABLE OF CONTENTS
`
`I.
`II.
`
`PETITIONER HAS STANDING .................................................................... 1
`SUMMARY OF THE ’432 PATENT ............................................................. 1
`A. Brief Description ....................................................................................... 1
`B. Summary of the Prosecution History of the ’432 Patent .......................... 4
`C. Level of Ordinary Skill ............................................................................. 4
`III. CLAIM CONSTRUCTION ............................................................................ 5
`IV. APPLICATION OF PRIOR ART TO THE CHALLENGED CLAIMS ........ 5
`A. TS-25.331 in view of TS-25.214 (Ground 1A – claims 1-2, 4-7, 9-12,
`14-16, 18) .................................................................................................. 7
`1. Overview of TS-25.331 (SAMSUNG-1004) .................................. 7
`2. Overview of TS-25.214 (SAMSUNG-1005) .................................. 8
`3.
`Combination of TS-25.331 and TS-25.214 ..................................... 9
`4. Analysis ......................................................................................... 10
`B. TS-25.331 in view of TS-25.214 and further in view of R1-074426 and
`Sampath (Ground 1B – claims 3, 5-10, 13, 15-18) ................................. 31
`1. Overview of R1-074426 (SAMSUNG-1006) ............................... 31
`2. Overview of Sampath (SAMSUNG-1007) ................................... 32
`3.
`Combination of TS-25.331, TS-25.214, R1-074426, and Sampath
` ....................................................................................................... 32
`4. Analysis ......................................................................................... 37
`C. Wintzell in view of Catreux-Erceg (Ground 2A – claims 1, 2, 4-7, 9-12,
`14-16, 18) ................................................................................................ 55
`1. Overview of Wintzell (SAMSUNG-1008) ................................... 55
`2. Overview of Catreux-Erceg (SAMSUNG-1009) .......................... 56
`3.
`Combination of Wintzell and Catreux-Erceg ................................ 57
`4. Analysis ......................................................................................... 60
`D. Wintzell in view of Catreux-Erceg and Sampath (Ground 2B – claims 3,
`5-10, 13, 15-18)....................................................................................... 83
`1.
`Combination of Wintzell, Catreux-Erceg, and Sampath ............... 83
`2. Analysis ......................................................................................... 86
`PTAB DISCRETION SHOULD NOT PRECLUDE INSTITUTION .......... 99
`V.
`VI. FEES .............................................................................................................. 99
`VII. CONCLUSION .............................................................................................. 99
`VIII. MANDATORY NOTICES UNDER 37 C.F.R § 42.8(a)(1) .......................100
`
`i
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`

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`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
`Real Party-In-Interest Under 37 C.F.R. § 42.8(b)(1) ..................................100
`Related Matters Under 37 C.F.R. § 42.8(b)(2) ............................................100
`Lead And Back-Up Counsel Under 37 C.F.R. § 42.8(b)(3) ........................100
`Service Information .....................................................................................100
`
`
`
`ii
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`

`

`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
`
`EXHIBITS
`
`SAMSUNG-1001 U.S. Patent No. 9,300,432
`
`SAMSUNG-1002 File History for U.S. Patent No. 9,300,432
`
`SAMSUNG-1003 Expert Declaration of Dr. Robert Akl
`
`SAMSUNG-1004 3rd Generation Partnership Project; Universal Mobile
`Telecommunications System (UMTS); Radio Resource Control
`(RRC); Protocol specification; 3GPP TS 25.331 version 7.4.0
`Release 7 (March 2007) (“TS-25.331”)
`
`SAMSUNG-1005 3rd Generation Partnership Project; Universal Mobile
`Telecommunications System (UMTS); Physical layer
`procedures (FDD); 3GPP TS 25.214 version 7.4.0 Release 7
`(March 2007) (“TS-25.214”)
`
`SAMSUNG-1006 “Rank feedback in downlink MIMO,” 3GPP TSG RAN WG1
`Meeting #50bis, R1-074426, October 8-12, 2007 (“R1-
`074426”)
`
`SAMSUNG-1007 U.S. Patent No. 8,971,461 (“Sampath”)
`
`SAMSUNG-1008 U.S. Patent Publication No. 2005/0003782 (“Wintzell”)
`
`SAMSUNG-1009 U.S. Patent No. 7,876,808 (“Catreux-Erceg”)
`
`SAMSUNG-1010 3rd Generation Partnership Project; Technical Specification
`Group Services and System Aspects; Vocabulary for 3GPP
`Specifications (Release 7) (June 2007) (“TR-21.905”)
`
`SAMSUNG-1011 U.S. Patent No. 8,699,587 (“Blanz”)
`
`SAMSUNG-1012 U.S. Patent No. 8,483,141 (“Malkamaki”)
`
`SAMSUNG-1013 3rd Generation Partnership Project; Technical Specification
`Group Radio Access Network; Physical channels and mapping
`
`iii
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`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
`
`of transport channels onto physical channels (FDD) (Release 7)
`(November 2007); (“TS-25.211”)
`
`SAMSUNG-1014 3rd Generation Partnership Project; Technical Specification
`Group Radio Access Network; Services provided by the
`physical layer (Release 7) (June 2007); (“TS-25.302”)
`
`SAMSUNG-1015 Declaration of Friedhelm Rodermund
`
`SAMSUNG-1016 U.S. Patent No. 8,171,381 (“Vayanos”)
`
`
`
`
`
`iv
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`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
`
`LISTING OF CLAIMS
`
`Claim 1
`[1pre] A method, in a user equipment, of enabling link quality estimation of a
`radio channel used for transmitting signals from a sending node to the
`user equipment, the method comprising:
`
`[1a]
`
`[1b]
`
`[1c]
`
`[1d]
`
`Claim 2
`[2]
`
`Claim 3
`[3]
`
`Claim 4
`[4]
`
`receiving, from the sending node and by dedicated higher layer signal-
`ing, a user equipment specific measurement adjusting parameter for ad-
`justing signal power measurements;
`
`measuring properties based on reference symbols of the radio channel
`transmitted by the sending node;
`
`adjusting the measured properties of the radio channel based on the re-
`ceived measurement adjusting parameter; and
`
`sending, to the sending node, a channel state information report based
`on the adjusted measured properties.
`
`The method of claim 1, further comprising: deriving a channel quality
`indicator based on the adjusted measured channel properties; wherein
`the channel state information report includes the derived channel qual-
`ity indicator.
`
`The method of claim 1, further comprising: deriving a rank indicator
`based on the adjusted measured channel properties; wherein the chan-
`nel state information report includes the rank indicator.
`
`The method of claim 1, wherein the dedicated higher layer signaling is
`radio resource control (RRC) signaling.
`
`
`
`
`
`
`v
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`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
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`
`The method of claim 1, further comprising: receiving payload data and
`reference symbols from the sending node; and
`
`configuring the channel state information report based on signal meas-
`urements on the reference symbols;
`
`wherein the measurement adjusting parameter compensates for a differ-
`ence in received power of measured signals and data signals.
`
`Claim 5
`[5a]
`
`[5b]
`
`[5c]
`
`Claim 6
`[6pre] A user equipment, comprising:
`
`[6a]
`
`[6c]
`
`[6d]
`
`[6e]
`
`Claim 7
`[7]
`
`a signal receiving circuit adapted to receive, from a sending node and
`by dedicated higher layer signaling, a user equipment specific measure-
`ment adjusting parameter for adjusting signal power measurements;
`
`a signal measuring circuit configured to measure properties based on
`reference symbols of the radio channel transmitted by the sending
`node;
`
`a quality estimating circuit configured to adjust the measured properties
`of the radio channel based on the received measurement adjusting pa-
`rameter; and
`
`a reporting circuit configured to send, to the sending node, a channel
`state in-formation report based on the adjusted measured properties.
`
`The user equipment of claim 6: wherein the quality estimating circuit is
`configured to derive a channel quality indicator based on the adjusted
`measured channel properties; wherein the channel state information re-
`port includes the derived channel quality indicator.
`
`
`
`
`
`
`vi
`
`

`

`Claim 8
`[8]
`
`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
`
`The user equipment of claim 6: wherein the quality estimating circuit is
`configured to derive a rank indicator based on the adjusted measured
`channel properties; wherein the channel state information report in-
`cludes the rank indicator.
`
`Claim 9
`[9]
`
`The user equipment of claim 6, wherein the dedicated higher layer sig-
`naling is radio resource control (RRC) signaling.
`Claim 10
`[10a]
`The user equipment of claim 6: wherein the signal receiving circuit is
`configured to receive payload data and reference symbols from the
`sending node;
`
`[10b] wherein the signal receiving circuit is configured to configure the chan-
`nel state information report based on signal measurements on the refer-
`ence symbols;
`
`[10c]
`
`wherein the measurement adjusting parameter compensates for a differ-
`ence in received power of measured signals and data signals.
`Claim 11
`[11pre] A method, in a sending node, for enabling link quality estimation of a
`radio channel used for transmitting signals from the sending node to a
`user equipment, the method comprising:
`
`[11a]
`
`[11b]
`
`sending, by dedicated higher layer signaling, a user equipment specific
`measurement adjusting parameter to the user equipment for adjusting
`signal power measurements; and
`
`receiving a channel state information report from the user equipment,
`the channel state information report including measured properties de-
`fined by reference symbols of the radio channel transmitted by the
`sending node adjusted in accordance with the sent measurement adjust-
`ing parameter.
`
`vii
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`

`

`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
`
`Claim 12
`[12]
`The method of claim 11, wherein the received channel state infor-
`mation report includes a channel quality indicator determined based on
`the adjusted measured channel property.
`Claim 13
`[13]
`The method of claim 11, wherein the received channel state infor-
`mation report includes a rank indicator determined based on the ad-
`justed measured channel properties.
`Claim 14
`[14a]
`The method of claim 11, further comprising: sending payload data and
`reference symbols to the user equipment, which configures the channel
`state information report based on signal measurements on the reference
`symbols;
`
`[14b] wherein the measurement adjusting parameter compensates for a differ-
`ence in received power of measured signals and data signals.
`Claim 15
`[15pre] A sending node for enabling link quality estimation of a radio channel
`used for transmitting signals from the sending node to a user equip-
`ment, comprising:
`
`[15a]
`
`[15b]
`
`a sending circuit configured to send, by dedicated higher layer signal-
`ing, a user equipment specific measurement adjusting parameter to the
`user equipment for adjusting signal power measurements; and
`
`a report receiver configured to receive a channel state information re-
`port from the user equipment, the channel state information report in-
`cluding measured properties defined by reference symbols of the radio
`channel transmitted by the sending node adjusted in accordance with
`the sent measurement adjusting parameter.
`
`
`
`
`
`
`viii
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`

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`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
`
`Claim 16
`[16]
`The sending node of claim 15, wherein the report receiver is configured
`to receive a channel state information report including a channel quality
`indicator determined based on the adjusted measured channel proper-
`ties.
`Claim 17
`[17]
`The sending node of claim 15, wherein the report receiver is configured
`to receive a channel state information report including a rank indicator
`determined based on the adjusted measured channel properties.
`Claim 18
`[18a]
`The sending node of claim 15: wherein the sending circuit is config-
`ured to send payload data and reference symbols to the user equipment,
`which configures the channel state information report based on signal
`measurements on the reference symbols; and
`
`[18b] wherein the measurement adjusting parameter compensates for a differ-
`ence in received power of measured signals and data signals.
`
`
`
`ix
`
`

`

`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
`Samsung Electronics Co., Ltd. (“Petitioner” or “Samsung”) petitions for Inter
`
`Partes Review (“IPR”) of claims 1-18 (“the Challenged Claims”) of U.S. Patent
`
`9,300,432 (“’432 Patent”). As explained in this Petition, there exists a reasonable
`
`likelihood that Petitioner will prevail.
`
`I.
`
`PETITIONER HAS STANDING
`Samsung certifies that the ’432 Patent is available for IPR. Samsung has not
`
`been served with a complaint for infringement of the ’432 patent. Samsung is not
`
`barred or estopped from requesting this review based on the grounds identified in
`
`Section IV.
`
`II.
`
`SUMMARY OF THE ’432 PATENT
`A. Brief Description
`The ’432 Patent describes a method for “enabling link quality estimation”
`
`(SAMSUNG-1001, Abstract) to support “dynamic link adaptation” (id., 4:29-35) of
`
`a wireless link, or channel, between a sending node, such as a wireless network base
`
`station, and a receiving node, such as a mobile phone. Link adaptation optimizes
`
`channel parameters for transmitting payload data to a receiving node and enables the
`
`sending node to send data at the highest rate that still allows the UE to reliably de-
`
`code it. SAMSUNG-1001, 3:59-4:7. By adjusting channel parameters to accurately
`
`reflect channel quality, the sending node can utilize parameters recommended by the
`
`receiving node instead of needing to “override” them (id., 6:29-33), which can result
`
`1
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`

`

`in inefficiencies such as “reduced throughput” and increased error rates. Id., 3:59-
`
`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
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`4:7.
`
`The ’432 Patent describes a process in which a receiving node generates chan-
`
`nel state information (CSI) and transmits the same to a sending node. Id., 9:24-29.
`
`If the sending node determines that the CSI is inaccurate, it generates a “measure-
`
`ment adjusting parameter” and transmits the parameter to the receiving node. Id.,
`
`7:65-8:13. The receiving node then uses the parameter to adjust “the signal power”
`
`or “other signal measurements” upon which the CSI is based. Id., 6:9-12, 8:14-19,
`
`9:47-54. The parameter “compensates for a difference in received power or SINR
`
`between measured signals and data signals” (id., 5:9-16) and can be used to “adjust
`
`an assumed…offset” to provide a “more realistic power value considering the actual
`
`link state,” (id., 10:28-41) representing a “mapping” from the measured control
`
`channel to the data channel. Id., 10:1-20.
`
`The ’432 Patent proclaims that this process of using an “adjusting parameter”
`
`to adjust measured channel properties is a new technique for improving link quality
`
`estimation. Id., 6:37-41. However, as demonstrated below with reference to the
`
`applied prior art and Dr. Akl’s testimony, the ’432 Patent’s technique for adjusting
`
`CSI using feedback to continually refine an estimate was well-known prior to the
`
`’432 Patent’s earliest possible priority date. SAMSUNG-1003, [42].
`
`2
`
`

`

`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
`Additionally, the claims of the ’432 Patent require only that the receiving node
`
`receives, from a sending node, an adjusting parameter; generates CSI configured
`
`based on the received parameter; and transmits the CSI to the sending node so that
`
`the sending node can process information according to the CSI for subsequent trans-
`
`mission to the receiving node. SAMSUNG-1001, 11:55-12:2 (claim 1); FIGS. 1 and
`
`2, with claimed subject matter shown in red.
`
`
`
`SAMSUNG-1001, FIG. 1 (left, annotated), FIG. 2 (right, annotated)
`
`For example, during prosecution and in response to a 112(b) rejection, Erics-
`
`son stated that the “[d]etermination of the adjusting parameter is not described in
`
`any of the claims,” and that the value of the adjustment parameter and the way in
`
`which it is determined has not been described by Ericsson as being “necessary” to
`
`practice of the claims. SAMSUNG-1002, 532-533, 577-578. However, prior art
`
`3
`
`

`

`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
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`methods for optimizing communications link parameters often included adjusting
`
`the parameters based on information from the sending node. SAMSUNG-1003,
`
`[44].
`
`B.
`Summary of the Prosecution History of the ’432 Patent
`During prosecution leading to issuance of the ’432 Patent, a single Office Ac-
`
`tion rejected the then-pending claims under 35 U.S.C. § 112(b) “as being incomplete
`
`for omitting essential steps.” SAMSUNG-1002, 531-533. Responsively, addressing
`
`the claims that were ultimately granted, Ericsson stated without equivocation that
`
`“none of the rejected claims are concerned with how the adjusting parameter is de-
`
`termined” and that the “determination of the adjusting parameter is not described in
`
`any of the claims.” Id., 577-578. Ericsson further stated that they had not “described
`
`the alleged omitted steps as being ‘necessary to practice the invention’” and thus the
`
`112 rejection could not be sustained. Id. The Examiner then issued a notice of
`
`allowance. Id., 603-610.
`
`C. Level of Ordinary Skill
`For purposes of this IPR, Petitioner submits that a person of ordinary skill in
`
`the art at the time of the alleged invention (a “POSITA”) would have had a Bache-
`
`lor’s degree in electrical engineering, computer engineering, computer science, or a
`
`related field, and 3-5 years of experience related to the design or development of
`
`wireless communication systems, or the equivalent. SAMSUNG-1003, [1]-[22].
`
`4
`
`

`

`Additional graduate education could substitute for professional experience, or sig-
`
`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
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`nificant experience in the field could substitute for formal education. Id.
`
`III. CLAIM CONSTRUCTION
`Petitioner submits that all claim terms should be construed according to the
`
`Phillips standard. Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005); 37 C.F.R.
`
`§ 42.100. Because the evidence below and the prior art’s description of the claimed
`
`elements are similar to that of the ’432 Patent specification, no formal claim
`
`constructions are necessary in this proceeding.1 Wellman, Inc. v. Eastman Chem.
`
`Co., 642 F.3d 1355, 1361 (Fed. Cir. 2011) (“claim terms need only be construed to
`
`the extent necessary to resolve the controversy”). SAMSUNG-1003, [48]-[50].
`
`IV. APPLICATION OF PRIOR ART TO THE CHALLENGED CLAIMS
`Petitioner requests IPR and cancellation of the Challenged Claims on the
`
`grounds listed below, and testimony offered by Dr. Robert Akl (SAMSUNG-1003).
`
`Ground
`1A
`1B
`
`Obviousness Grounds of Rejection
`Claim(s)
`1-2, 4-7, 9-12, 14-16, 18 TS-25.214 and TS-25.331
`3, 5-10, 13, 15-18
`TS-25.214, TS-25.331, R1-074426, and
`Sampath
`
`
`1 Petitioner is not conceding that each challenged claim satisfies all statutory re-
`
`quirements, such as 35 U.S.C. § 112, nor is Petitioner waiving any arguments con-
`
`cerning other grounds that can only be raised in district court.
`
`5
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`

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`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
`
`Ground
`2A
`2B
`
`Obviousness Grounds of Rejection
`Claim(s)
`1-2, 4-7, 9-12, 14-16, 18 Wintzell and Catreux-Erceg
`3, 5-10, 13, 15-18
`Wintzell, Catreux-Erceg, and Sampath
`
`As shown below, each reference pre-dates February 11, 2008 (“Critical
`
`Date”), which is the earliest possible date to which the ’432 Patent claims priority.2
`
`Reference
`
`TS-25.331
`
`TS-25.214
`
`R1-074426
`
`Sampath
`
`Wintzell
`
`Date
`
`April 6, 2007 (published)3
`
`March 22, 2007 (published)
`
`October 2, 2007 (published)
`
`January 11, 2007 (published)
`
`January 6, 2005 (published)
`
`Catreux-Erceg
`
`November 30, 2006 (priority)
`
`Section
`
`102(a)
`
`102(a)
`
`102(a)
`
`102(b)
`
`102(b)
`
`102(e)
`
`
`
`
`
`
`
`
`2 Petitioner does not concede that the ’432 Patent is entitled to the claimed priority.
`
`3 Each of the 3GPP technical documents listed in this table was publicly available
`
`as of the Critical Date as evidenced by historic 3GPP ftp server information, and
`
`therefore qualifies as prior art. SAMSUNG-1015.
`
`6
`
`

`

`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
`A. TS-25.331 in view of TS-25.214 (Ground 1A – claims 1-2, 4-7, 9-
`12, 14-16, 18)
`1. Overview of TS-25.331 (SAMSUNG-1004)4
`TS-25.331 is a 25 series technical specification (TS) from the 3rd Generation
`
`Partnership Project (3GPP) relating to Universal Mobile Telecommunications Sys-
`
`tem (UMTS) technology. SAMSUNG-1004, Title. It specifies the “Radio Resource
`
`Control” (RRC) “protocol for the UE-UTRAN” (user equipment-universal terres-
`
`trial radio access network) link within the UMTS. Id., 31; SAMSUNG-1010, 29,
`
`51. The RRC is a sublayer of the radio interface “responsible for controlling the
`
`configuration” of lower levels of the interface between UE and a wireless network.
`
`SAMSUNG-1010, 22. TS-25.331 describes various RRC messages, including a
`
`message for “physical channel reconfiguration,” (SAMSUNG-1004, 443-445) spec-
`
`ifying downlink channel parameters, such as “Measurement Feedback” information
`
`(id., 618) for a high speed downlink shared channel (HS-DSCH) over which data is
`
`transmitted from the network to the UE. Id., 35. The “Measurement Feedback”
`
`information includes a “Measurement Power Offset” (MPO) for adjusting a meas-
`
`ured channel parameter, such as a channel power. Id., 637.
`
`
`4 General descriptions provided for the following references and combinations
`
`thereof are incorporated into each mapping that includes citations to these refer-
`
`ences. All emphasis is added unless otherwise indicated.
`
`7
`
`

`

`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
`
`TS-25.331’s disclosure further includes specific references to other 3GPP
`
`documents, including TS-25.214 (SAMSUNG-1005) and TR-21.905 (SAMSUNG-
`
`1010). SAMSUNG-1004, 31-32. For example, regarding the MPO, TS-25.331 re-
`
`fers the reader to the other chapter of TS 25; namely, TS-25.214. Id. As discussed
`
`below, TS-25.214 provides details of the MPO referred to in TS-25.331. SAM-
`
`SUNG-1003, [53]-[54].
`
`2. Overview of TS-25.214 (SAMSUNG-1005)
`TS-25.214 is a TS specifying the “Physical layer procedures” for a UMTS
`
`network. SAMSUNG-1005, Title. TS-25.214 describes “characteristics of the
`
`physical[] layer procedures” of the UTRA (universal terrestrial radio access), and
`
`is generally considered together with TS-25.331. Id., 7; SAMSUNG-1010, 51;
`
`SAMSUNG-1003, [55].
`
`TS-25.214 discloses a HS-DSCH procedure that includes “signal[ing,] to the
`
`UE,” parameters from “higher layers,” including “[m]easurement power offset Γ.”
`
`SAMSUNG-1005, 34-35. These parameters are used to estimate a channel quality
`
`by selecting a channel quality indication (CQI) value. Id., 39. For example, when
`
`the UE is configured in a multiple-input-multiple-output (MIMO) mode, the UE
`
`reports a CQI value selected based on an assumed “total received HS-PDSCH
`
`power” determined based on Γ. Id., 39-40; SAMSUNG-1003, [56].
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`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
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`3. Combination of TS-25.331 and TS-25.214
`TS-25.331 and TS-25.214 are related UMTS TSs from the same group
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`(3GPP), in the same version and release (version 7.4.0, Release 7). SAMSUNG-
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`1004, Title; SAMSUNG-1005, Title. Each of the TSs explicitly references the
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`other. SAMSUNG-1004, 637 (referencing “measurement power offset, Γ, in dB,
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`as described in” TS-25.214), 32; SAMSUNG-1005, 7. In fact, TS-25.331 lists TS-
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`25.214 as a document containing “provisions which, through reference in this text,
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`constitute provisions of the present document,” essentially incorporating TS-
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`25.214 by reference, and vice versa. SAMSUNG-1004, 32; SAMSUNG-1005, 7.
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`A POSITA would have been motivated to consider TS-25.331 and TS-25.214 to-
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`gether and to combine their teachings, which would have involved combining prior
`
`art elements using known methods to yield predictable results because, for exam-
`
`ple, TS-25.214 provides specific details of parameters described by TS-25.331, in-
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`cluding the “Measurement Power Offset” parameter. SAMSUNG-1004, 637;
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`SAMSUNG-1003, [63].
`
`A POSITA would have understood that TS-25.331 and TS-25.214 are part of
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`a collection of documents, each considered as portions of a larger document and
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`collectively considered as a set of teachings related to UMTS implementation.
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`SAMSUNG-1003, [63]-[64]. Where TS-25.331 does not provide details of partic-
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`ular parameters and procedures, a POSITA would have had reason to turn to TS-
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`25.214. SAMSUNG-1005, 34-35, 39-40; SAMSUNG-1003, [64]. For example, a
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`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
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`POSITA would have been motivated to look to TS-25.214 for implementation de-
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`tails regarding the MPO because TS-25.331 explicitly identifies TS-25.214 as hav-
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`ing additional details. SAMSUNG-1004, 32, 637; SAMSUNG-1003, [64].
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`4. Analysis
`[1pre] A method, in a user equipment, of enabling link quality estimation of a
`radio channel used for transmitting signals from a sending node to the user equip-
`ment, the method comprising:
`To the extent the preamble is limiting, the combination of TS-25.331 and TS-
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`25.214 (“TS-25.331-TS-25.214”) renders obvious a method, in UE, of enabling
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`channel quality estimation of a radio channel used for transmitting signals from a
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`sending node to the user equipment. SAMSUNG-1004, 45, 402-403, 443, 618, 637;
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`SAMSUNG-1005, 34-40; SAMSUNG-1003, [67]. TS-25.331 discusses a method
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`for determining a channel quality indicator (CQI). SAMSUNG-1004, 45, 402-403,
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`443, 618, 637; SAMSUNG-1005, 39-40. A UMTS UE transmits a CSI report con-
`
`taining the CQI to the wireless network to enable the network to schedule and format
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`data transmissions to the UE. SAMSUNG-1003, [67] citing SAMSUNG-1009, 2:1-
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`22, 5:21-25.
`
`First, TS-25.331 discloses that the UTRAN transmits a “PHYSICAL CHAN-
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`NEL RECONFIGURATION” RRC message to the UE over the dedicated control
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`channel (DCCH). SAMSUNG-1004, 443. This message is “used by UTRAN to
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`Attorney Docket No 39843-0097IP1
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`assign, replace or release a set of physical channels used by a UE.” Id. The UTRAN
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`uses logical nodes (NodeBs, or base stations) “for radio transmission/reception in
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`one or more cells to/from the U[E].” SAMSUNG-1010, 7, 18; SAMSUNG-1001,
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`7:21-25 (a sending node can be a “base station” of a wireless network). TS-25.331’s
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`physical channel reconfiguration RRC message includes a downlink radio resource
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`having “downlink HS-PDSCH information.” SAMSUNG-1004, 443-445. This
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`downlink HS-PDSCH information includes information elements referred to collec-
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`tively as “Measurement Feedback Info.” Id. One information element, the “Meas-
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`urement Power Offset,” is used when determining a CQI value. Id., 618. TS-25.331
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`describes the MPO as a “measurement power offset, Γ, in dB, as described in [TS-
`
`25.214].” Id., 637; SAMSUNG-1003, [68].
`
`Second, TS-25.214 discloses that “measurement power offset Γ” is a “physi-
`
`cal layer parameter” “signaled to the UE” from higher layers. SAMSUNG-1005,
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`39-40. When the UE is configured in a MIMO mode, it constructs CSI reports con-
`
`taining information, such as CQI values and precoding control indication (PCI) val-
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`ues, to be transmitted to the NodeB. Id., 37-40. The quality of the channel can be
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`measured, for example, based on the received power across various antenna and/or
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`channels. SAMSUNG-1003, [69] citing SAMSUNG-1008, [0017].
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`Third, TS-25.214 discloses that, “[f]or the purpose of CQI reporting, the UE
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`shall assume a total received HS-PDSCH power of PHSPDSCH = PCPICH + Γ in dB.”
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`Attorney Docket No 39843-0097IP1
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`SAMSUNG-1005, 40. This assumed total received power PHSPDSCH, calculated by
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`adjusting a common pilot channel (CPICH) power PCPICH by applying the MPO, is
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`used to determine a CQI value according to an equation that can be defined by sys-
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`tems adhering to the standard defined in TS 25. SAMSUNG-1003, [70]. As dis-
`
`cussed above with respect to Section IV.A.3, various formulas and values for spe-
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`cific parameters could be implemented, as long as the relationships explicitly defined
`
`within the 3GPP standard were met. Id.
`
`Thus, TS-25.331-TS-25.214’s combined disclosure of determining a CQI
`
`value (enabling link quality estimation) of the HS-DSCH channel (a radio channel)
`
`used for transmitting data signals from a NodeB (a network-side sending node) to
`
`the UE renders obvious, to a POSITA, a method performed by a UE that enables
`
`link quality estimation of a radio channel used for transmitting signals from a send-
`
`ing node to the UE. SAMSUNG-1003, [67]-[72].
`
`[1a] receiving, from the sending node and by dedicated higher layer signaling, a
`user equipment specific measurement adjusting parameter for adjusting signal
`power measurements;
`TS-25.331-TS-25.214 renders obvious [1a]. SAMSUNG-1004, 45, 637;
`
`SAMSUNG-1005, 39-40; SAMSUNG-1003, [73].
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`Attorney Docket No 39843-0097IP1
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`First, as described above with respect to [1pre],5 TS-25.214 discloses a UE
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`receiving the MPO Γ from a NodeB through dedicated “higher layer[]” signaling.
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`SAMSUNG-1005, 39-40. TS-25.331 discloses that this higher layer signaling is
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`performed by transmitting a physical channel reconfiguration RRC message over the
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`dedicated control channel DCCH. SAMSUNG-1004, 45, 443-445, 618, 637;
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`SAMSUNG-1003, [74].
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`Furthermore, because the DCCH is a dedicated channel which links a single
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`UE and the network, the MPO is UE-specific: The DCCH is used to carry dedicated
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`control information specifically for the single UE. SAMSUNG-1004, 443-445;
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`SAMSUNG-1003, [75] citing SAMSUNG-1013, 8; SAMSUNG-1014.
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`Finally, the parameter Γ is used to adjust signal power measurements—the
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`MPO Γ is applied to a CPICH power, PCPICH, to determine a “total received HS-
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`PDSCH power” PHSPDSCH according to the following equation: “PHSPDSCH = PCPICH +
`
`Γ in dB.” SAMSUNG-1005, 40. It was well-known to a POSITA as of the Critical
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`Date that PCPICH, the power of a CPICH, was commonly measured by the UE as an
`
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`5 Analysis of previously addressed claim elements and upon which a particular
`
`claim element depends is wholly incorporated in the particular claim element. For
`
`example, analysis for element [1pre] is incorporated into all following elements of
`
`claim 1.
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`Attorney Docket No 39843-0097IP1
`IPR of U.S. Patent No. 9,300,432
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`indicator of signal quality, as disclosed by TS-25.331. SAMSUNG-1003, [76] citing
`
`SAMSUNG-1008, [0031].
`
`The CPICH is a downlink channel having constant power and a known bit
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`sequence broadcast by a NodeB. SAMSUNG-1003, [78] citing SAMSUNG-1013,
`
`29-32. Pilot channels carry pilot symbols, or reference symbols, inserted at known
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`intervals and locations. Id. These symbols act as points of reference against which
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`other signals can be compared and with which signal quality can be measured. Id.
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`TS-25.214’s UE “uses the CPICH” to estimate