`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`Janne Peisa, et al.
`In re Patent of:
`10,484,915 Attorney Docket No.: 50095-0070IP1
`U.S. Patent No.:
`November 19, 2019
`
`Issue Date:
`Appl. Serial No.: 16/211,399
`
`Filing Date:
`December 6, 2018
`
`Title:
`Identifying a beam for accessing a target cell of a wireless handover
`
`
`
`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. 10,484,915 PURSUANT TO 35 U.S.C. §§ 311–319, 37 C.F.R. § 42
`
`
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`TABLE OF CONTENTS
`
`I. 
`
`II. 
`
`REQUIREMENTS FOR IPR UNDER 37 C.F.R. § 42.104 ............................ 1 
`A.  Grounds for Standing Under 37 C.F.R. § 42.104(a)................................. 1 
`B.  Challenge Under 37 C.F.R. § 42.104(b) and Relief Requested ............... 1 
`C.  Claim Construction under 37 C.F.R. §§ 42.104(b)(3) .............................. 2 
`SUMMARY OF THE ‘915 PATENT ............................................................. 2 
`A.  Brief Description ....................................................................................... 2 
`B.  Summary of the Prosecution History of the ’915 Patent .......................... 3 
`III.  THE CHALLENGED CLAIMS ARE UNPATENTABLE ............................ 4 
`A.  GROUNDS 1-2 – Agiwal in view of TS36.331 (Ground 1) and Agiwal
`in view of TS36.331 and Murray (Ground 2) renders obvious claims 1-
`3, 6, 8-10, and 13-15 ................................................................................. 4 
`1.  Overview of Agiwal (EX-1005) ...................................................... 4 
`2.  Overview of TS36.331 (EX-1008) .................................................. 9 
`3. 
`Combination of Agiwal with TS36.331 ........................................ 11 
`4.  Overview of Murray (EX-1009) ................................................... 12 
`5. 
`Combination of Agiwal with Murray ............................................ 15 
`6.  Agiwal in view of TS36.331 (Ground 1) and Agiwal in view of
`TS36.331 and Murray (Ground 2) renders obvious Claims 1-3, 6,
`8-10, 13-15 .................................................................................... 17 
`B.  GROUND 3 – Abedini renders obvious claims 1-5, 7-12, 14 and 15 .... 48 
`1.  Overview of Abedini (EX-1010) ................................................... 48 
`2.  Abedini renders obvious Claims 1-5, 7-12, 14 and 15 .................. 53 
`IV.  PAYMENT OF FEES – 37 C.F.R. § 42.103 ................................................. 84 
`V. 
`CONCLUSION .............................................................................................. 84 
`VI.  MANDATORY NOTICES UNDER 37 C.F.R § 42.8(a)(1) ......................... 84 
`A.  Real Party-In-Interest Under 37 C.F.R. § 42.8(b)(1) .............................. 84 
`B.  Related Matters Under 37 C.F.R. § 42.8(b)(2) ....................................... 84 
`C.  Lead And Back-Up Counsel Under 37 C.F.R. § 42.8(b)(3) ................... 85 
`D.  Service Information ................................................................................ 85 
`
`
`
`i
`
`

`

`
`
`EX-1001
`
`EX-1002
`
`EX-1003
`
`EX-1004
`
`EX-1005
`
`EX-1006
`
`EX-1007
`
`EX-1008
`
`EX-1009
`
`EX-1010
`
`EX-1011
`
`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`
`EXHIBITS
`
`U.S. Patent No. 10,484,915 to Janne Peisa, et al. (“’915 patent”)
`
`Excerpts from the Prosecution History of the ’915 Patent
`(“Prosecution History”)
`
`Declaration of Dr. Zhi Ding
`
`Curriculum Vitae of Dr. Zhi Ding
`
`U.S. Patent Application Publication No. 2017/0251460 to
`Agiwal et al. (“Agiwal”)
`
`U.S. Provisional Patent Application No. 62/300,333 of Agiwal
`(“Agiwal-Prov1”)
`
`RESERVED
`
`3GPP TS 36.331 V12.10.0 (2016-06), 3rd Generation
`Partnership Project; Technical Specification Group Radio
`Access Network; Evolved Universal Terrestrial Radio Access
`(E-UTRA); Radio Resource Control (RRC); Protocol
`specification (Release 12) (“TS36.331”)
`
`International Application Publication No. WO 2014/078676 to
`Murray et al. (“Murray”)
`
`U.S. Patent Application Publication No. 2018/0115990 to
`Abedini et al. (“Abedini”)
`
`U.S. Provisional Patent Application No. 62/411,400 of Abedini
`(“Abedini-Prov1”)
`
`EX-1012
`
`RESERVED
`
`ii
`
`

`

`EX-1013
`
`EX-1014
`
`EX-1015
`
`EX-1016
`
`EX-1017
`
`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`Declaration of Friedhelm Rodermund
`
`RESERVED
`
`Qiu, L., Huang, Y. and Zhu, J., “Fast acquisition scheme and
`implementation of PRACH in WCDMA system,” IEEE 54th
`Vehicular Technology Conference. VTC Fall 2001.
`Proceedings (Cat. No. 01CH37211) (Vol. 3, pp. 1701-1705).
`IEEE.
`
`K. Dimou et al., “Handover within 3GPP LTE: Design
`Principles and Performance,” 2009 IEEE 70th Vehicular
`Technology Conference Fall, Anchorage, AK, USA, 2009, pp.
`1-5, doi: 10.1109/VETECF.2009.5378909
`
`A. Ghosh et al., “Random Access Design for UMTS
`Air-Interface Evolution,” 2007 IEEE 65th Vehicular
`Technology Conference - VTC2007-Spring, 2007, pp.
`1041-1045, doi: 10.1109/VETECS.2007.222
`
`
`
`
`
`iii
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`Apple Inc. (“Petitioner” or “Apple”) petitions for Inter Partes Review
`
`(“IPR”) of claims 1-15 (“Challenged Claims”) of U.S. Patent No. 10,484,915
`
`(“’915 patent”).
`
`I.
`
`REQUIREMENTS FOR IPR UNDER 37 C.F.R. § 42.104
`A. Grounds for Standing Under 37 C.F.R. § 42.104(a)
`Apple certifies that the ’915 Patent is available for IPR. Apple is not barred
`
`or estopped from requesting this review.
`
`B. Challenge Under 37 C.F.R. § 42.104(b) and Relief
`Requested
`Apple requests an IPR of the Challenged Claims on the 35 U.S.C. § 103
`
`grounds below. Additional explanation and support for each ground of rejection is
`
`provided in the Declaration of Dr. Zhi Ding (see EX-1003, ¶¶20-258), referenced
`
`throughout this Petition.
`
`’915 Patent Claims
`Ground
`Ground 1 1-3, 6
`
`103 Basis
`Agiwal in view of TS36.331
`
`Ground 2 8-10, 13-15
`
`Agiwal in view of TS36.331 and Murray
`
`Ground 3 1-5, 7-12, 14-15
`
`Abedini
`
`As shown below, each reference pre-dates November 4, 2016 (“Critical
`
`Date”), which is the earliest date to which the ’915 patent claims priority.1
`
`
`
` 1
`
` Petitioner does not concede that the ’915 Patent is entitled to the claimed priority.
`
`1
`
`

`

`Agiwal
`
`Reference
`US Pub. No.
`2017/0251460
`
`TS36.331 TS 36.331 V12.10.0
`(2016-08)
`
`International
`Application
`Publication No.
`WO2014/078676
`
`US Pub. No.
`2018/0115990
`
`Murray
`
`Abedini
`
`
`
`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`Date
`Section
`102(a)(2)
`February 26, 2016
`(Filing date of US provisional
`application 62/300,333
`(“Agiwal-Prov1”))
`
`July 1, 2016
`
`102(a)(1)
`
`May 22, 2014
`
`
`102(a)(1)
`
`102(a)(2)
`
`October 21, 2016
`(Filing date of US provisional
`application 62/411,400
`(“Abedini-Prov1”))
`
`C. Claim Construction under 37 C.F.R. §§ 42.104(b)(3)
`A claim subject to IPR is given its “ordinary and customary meaning” “as
`
`understood by one of ordinary skill in the art and the prosecution history pertaining
`
`to the patent.” 37 C.F.R. § 42.100(b). For purposes of this proceeding only, Apple
`
`submits that all terms should be given their plain meaning. See EX-1003, ¶¶56-57.
`
`II.
`
`SUMMARY OF THE ‘915 PATENT
`A. Brief Description
`The ’915 patent proclaims disclosure of a method for device handover in
`
`2
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`beam-based wireless communications systems. See EX-1001, 1:15-65. In
`
`particular, the ’915 patent describes a method in which a wireless device, which
`
`can be a user equipment (UE) (e.g., a mobile phone), receives a handover message
`
`from a serving base station, for connecting to a target base station. See, e.g., id.,
`
`1:30-2:30, 5:25-49, 12:55-14:40, 15:34-17:67, FIGS. 2-4 and 6-7. Disclosed
`
`examples of base stations are evolved NodeBs (eNBs) and next-generation NodeBs
`
`(gNBs). See id. The handover message includes a target base station identity and
`
`random access channel parameters for beams of the target base station. See id.
`
`The wireless device selects a beam associated with the target base station identified
`
`from the handover message, and connects, using the random access parameters, to
`
`the target base station on the selected beam. See id. See also EX-1003, ¶¶42-50.
`
`B.
`Summary of the Prosecution History of the ’915 Patent
`In its only response during original prosecution of the ’915 patent, Applicant
`
`amended the independent claims to clarify that the received message is an “RRC
`
`connection reconfiguration message” comprising both common and dedicated
`
`random access configuration information. EX-1002, 27-32. In accompanying
`
`remarks, Applicant argued that “common and dedicated random access
`
`configuration information . . . is not equivalent to access information for
`
`omnidirectional or directional signals.” EX-1002, 33-36. Allowing the ’915
`
`patent in response, the Examiner held that the prior art did not teach an RRC
`
`3
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`connection reconfiguration message with both common and dedicated random
`
`access configuration. EX-1002, 12. See also EX-1003, ¶¶51-55.
`
`And yet, unlike the then-applied art, references advanced in Grounds 1-3 of
`
`this petition demonstrate the obviousness of RRC connection reconfiguration
`
`messages with both common and dedicated random access configuration. See id.
`
`III. THE CHALLENGED CLAIMS ARE UNPATENTABLE
`A. GROUNDS 1-2 – Agiwal in view of TS36.331 (Ground 1)
`and Agiwal in view of TS36.331 and Murray (Ground 2)
`renders obvious claims 1-3, 6, 8-10, and 13-15
`1. Overview of Agiwal (EX-1005)
`Agiwal discloses methods leveraging random access techniques to connect a
`
`wireless device to a base station in a wireless communication system. See
`
`EX-1005, Title, Abstract, ¶¶[0009-19] and ¶¶[0066-92]. Agiwal’s FIG. 1 (below)
`
`illustrates a next-generation wireless communications system in which the
`
`disclosed methods can be realized. Id., ¶¶[0009-10]. This system includes “low
`
`frequency (LF) macro” and “high frequency (HF) small cells,” respectively served
`
`by a LF base station (LF-BS) and HF base stations (e.g., HF-BS1 and HF-BS2 in
`
`FIG. 1). Id.
`
`4
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`
`EX-1005, FIG. 1 (annotated)
`
`
`
`Referring to a wireless device as a “[m]obile station (MS)” or “user
`
`equipment (UE),” Agiwal notes that the disclosed random access methods are
`
`applicable to handover, in which “the MS first connects with the HF-BS and then it
`
`is handed over to another HF-BS ([also] referred to as target eNB). In this case the
`
`MeNB in the description is a source eNB and the SeNB []is a target eNB.” EX-
`
`1005, ¶[0070].
`
`Agiwal’s FIG. 5 illustrates one such handover method for “a beamformed
`
`random access procedure,” in which a source eNB, MeNB 502, enables UE 501 to
`
`connect to a target eNB, SeNB 503. Id., ¶¶[0087-92] and FIG. 5 (below). At
`
`5
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`operation 513, MeNB 502 sends, to UE 501, a “RRC connection reconfiguration”
`
`message, which includes common and dedicated random access channel
`
`configurations (HF RACH Config) for SeNB 503. Id. At operation 514, UE 501
`
`identifies the best downlink (DL) transmit (TX) and corresponding receive (RX)
`
`beams, and at operations 517a/517, accesses SeNB 503 using the TX beam. Id.
`
`See also EX-1003, ¶¶58-61.
`
`EX-1005, FIG. 5 (annotated)
`
`
`
`(a) Dynamic Drinkware analysis
`Agiwal-Prov1 is incorporated in its entirety in Agiwal. See EX-1005,
`
`¶[0001]. Thus, the disclosure of Agiwal-Prov1 is part of Agiwal and any citation
`
`6
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`to disclosure of Agiwal-Prov1 represents citation to disclosure in Agiwal itself.
`
`Agiwal-Prov1 supports at least Agiwal’s claim 1, as shown below. See EX-1003,
`
`¶62. Accordingly, Agiwal is entitled to Agiwal-Prov1’s February 26, 2016, filing
`
`date. See Dynamic Drinkware, LLC v. Nat’l Graphics, Inc., 800 F.3d 1375, 1382
`
`(Fed. Cir. 2015) (holding that “[a] reference patent is only entitled to claim the
`
`benefit of the filing date of its provisional application if the disclosure of the
`
`provisional application provides support for the claims in the reference patent”).
`
`
`
`A method of performing a random access by an
`apparatus in a wireless communication system, the
`method comprising:
`Agiwal-Prov1 discloses “method[s] of performing random access in [a]
`
`beam-formed system.” EX-1006, Title, 21 (emphasis added). Agiwal-Prov1’s
`
`FIG. 1 illustrates one such “wireless communication system,” in which a “UE
`
`communicates with both master BS/eNB and Secondary BS/eNB.” Id., 22-24 and
`
`FIG. 1. With respect to FIGS. 16A-19C, Agiwal-Prov1 discloses methods
`
`performed by a UE for “random access in beamformed system.” Id., 49-59 and
`
`FIGS. 16A-19C. See also EX-1003, ¶¶63-64.
`
`
`
`identifying a first downlink (DL) reception (RX) beam
`based on a measurement on a beam measurement
`signal;
`For the random access method of FIGS. 16A-16B, Agiwal-Prov1 discloses
`
`that, in one embodiment, the “UE measures the beamformed beam
`
`7
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`measurement signal transmitted by BS and determines the best DL RX beam.”
`
`EX-1006, 50-51 (emphasis added) and FIGS. 16A-16B. See also EX-1003, ¶¶65-
`
`66.
`
`
`
`identifying a first uplink (UL) transmission (TX) beam
`corresponding to the identified first DL RX beam; and
`Agiwal-Prov1 discloses that, following determining the “best DL RX beam,”
`
`the “UE uses [determines] the UL TX beam reciprocal (same or same
`
`direction) to DL RX beam.” EX-1006, 50 (emphasis added) and FIG. 16B
`
`(below). See also EX-1003, ¶¶67-68.
`
`
`
`EX-1006, FIG. 16B (annotated)
`
`8
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`transmitting at least one random access preamble for
`an RX sweeping at a base station, using the identified
`first UL TX beam based on a first power.
`Agiwal-Prov1 discloses that, upon identifying the UL TX beam reciprocal to
`
`
`
`the best DL RX beam, the UE “transmits PRACH [preamble] using UL TX
`
`beam one or more times using the power ‘P’ wherein UE may transmit multiple
`
`times for RX beam sweeping at BS.” EX-1006, 50 (emphasis added) and FIG.
`
`16B (below). See also EX-1003, ¶¶69-70.
`
`
`
`EX-1006, FIG. 16B (annotated)
`
`2. Overview of TS36.331 (EX-1008)
`
`9
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`TS36.331 is a Technical Specification (TS) from the 3rd Generation
`
`Partnership Project (3GPP), specifying “the Radio Resource Control (RRC)
`
`protocol for the radio interface between UE and the [Evolved Universal Terrestrial
`
`Radio Access Network (E-UTRAN)],” i.e., LTE, a wireless network technology
`
`applicable to the’915 patent. See EX-1008, Title and §§1-4; EX-1001, 4:30-5:36;
`
`EX-1003, ¶71. TS36.331 was publicly available no later than July 1, 2016,
`
`qualifying as prior art for the ’915 patent under 35 USC §102(a)(1). See EX-1013,
`
`¶20. As demonstrated, TS36.331 was uploaded to the public 3GPP ftp server no
`
`later than July 1, 2016; an interested skilled person would have been made aware
`
`of the public availability of TS36.331 in a public email distribution list, or would
`
`have been able to access the server location using online search engines. Id.,
`
`¶¶21-52; see also id., ¶¶1-19. During prosecution of the ’915 patent, a later
`
`version—14.0.0—of TS36.331 was disclosed by the Applicant, but was never
`
`relied upon by the examiner as part of a rejection. See EX-1002, pp 48-65. See
`
`also EX-1003, ¶¶71-72.
`
`As a technical standard, TS36.331 provides a detailed technical description
`
`of the RRC network protocol implemented by E-UTRAN network devices, e.g., by
`
`UEs and eNBs. Id., ¶73. The document notes that, in some cases, the network,
`
`e.g., eNB, provides system information parameters to the UE “within an
`
`RRCConnectionReconfiguration message,” which is used to “modify an RRC
`
`10
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`connection, e.g. … to perform handover.” EX-1008, §5.2.1.1 and §5.3.5.1
`
`(emphasis added). Handover of the UE from a source eNB to a target eNB due to
`
`mobility is controlled, in part, using “mobilityControlInfo” information element
`
`(IE) in the RRCConnectionReconfiguration message. Id., §5.3.1.3 and §6.2.2,
`
`182-185. TS36.331 discloses that the mobilityControlInfo IE includes parameters
`
`for the target eNB, such as “a physical cell identity indicated by targetPhysCellId,”
`
`and access information, such as common and dedicated random access parameters
`
`provided respectively by “radioResourceConfigCommon” and
`
`“rach-ConfigDedicated.” Id., §5.3.5.4, §6.3.2, pp. 274-277, and §6.3.4, 302-304.
`
`See also EX-1003, ¶73.
`
`3.
`Combination of Agiwal with TS36.331
`Agiwal notes that the wireless communication system in which its disclosed
`
`methods are applicable includes a “4th-generation (4G)+5G system.” EX-1005,
`
`¶[0068]; see also supra §III(A)(1). A person of ordinary skill in the art (POSITA)2
`
`would have known that 4G refers to E-UTRAN (LTE) communication systems,
`
`which is the communication technology to which TS36.331 is directed. See EX-
`
`1003, ¶74. Indeed, Agiwal discloses that, for the random access methods, “MeNB
`
`502 transmits the RRC Connection Reconfiguration including the received HF
`
`
`
` 2
`
` See EX-1003, ¶¶20-22.
`
`11
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`RACH Config to a UE 501,” which sends a “‘RRC Connection Reconfiguration
`
`Complete’ message” in response. EX-1005, ¶¶[0088-90] (emphasis added); EX-
`
`1003, ¶74.
`
`Agiwal, however, does not describe in detail the RRC Connection
`
`Reconfiguration message or other protocol messages used in its methods. A
`
`POSITA looking to implement Agiwal’s random access procedure would have
`
`sought to understand the structure of the RRC Connection Reconfiguration
`
`message and other related messages discussed in Agiwal, and motivated to look at
`
`various standards documents related to Agiwal’s technologies, such as various
`
`3GPP specifications for E-UTRAN. See EX-1003, ¶75. A POSITA would
`
`specifically have looked at TS36.331, the technical standard that specifies the RRC
`
`protocol, including detailing various message structures, such as
`
`RRCConnectionReconfiguration and RRCConnectionReconfigurationComplete.
`
`Id.; see also EX-1008, §6.2.2, 182-186. Accordingly, to fully understand the RRC
`
`protocol used in Agiwal’s random access procedure, a POSITA would have been
`
`motivated to look at Agiwal and TS36.331 together, combining their teachings.
`
`See EX-1003, ¶¶75-76.
`
`4. Overview of Murray (EX-1009)
`Murray discloses techniques “for channel evacuation of a shared spectrum
`
`channel” for a “wireless transmit receive unit (WTRU)” in a wireless network. See
`
`12
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`EX-1009, Title and Abstract. With respect to FIG. 1A (below), Murray provides
`
`an example multiple access communications system that includes “[WTRUs] 102a,
`
`102b, 102c, and/or 102d ([collectively referred] to as WTRU 102)” and “base
`
`stations 114a, 114b [that are] configured to wirelessly interface with at least one of
`
`the WTRUs 102a, 102b, 102c, 102d to facilitate access to one or more
`
`communication networks.” Id., ¶¶[0045-48], FIG. 1A. A WTRU can be a UE or a
`
`mobile station, while a base station can be “a Node-B, an eNode B,” among others.
`
`Id. The base stations and WTRUs use cellular technologies such as “Long Term
`
`Evolution (LTE) and/or LTE-Advanced (LTE-A).” Id., ¶[0051]; see also id.,
`
`¶¶[0105-109] and EX-1003, ¶77.
`
`EX-1009, FIG. 1A (annotated)
`
`
`
`13
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`Murray explains that a WTRU includes a power source, a processor and
`
`input/output components by disclosing that “WTRU 102 may include a processor
`
`118, a transceiver 120, a transmit/receive element 122, a speaker/microphone 124,
`
`a keypad 126, a display/touchpad 128, [and] a power source 134,” among others.
`
`EX-1009, ¶¶[0057-65] and FIG. 1B (below).
`
`EX-1009, FIG. 1B (annotated)
`
`
`
`Murray describes that channel evacuation can be performed using “a
`
`handover (HO) method,” in which “[o]ne or more WTRUs may be evacuated from
`
`14
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`a channel by performing a HO to a target cell providing coverage in the same area
`
`as the source cell.” EX-1009, ¶¶[0153-156] and FIG. 12 (below); see also id.,
`
`¶¶[0089-93], and EX-1003, ¶¶78-79.
`
`EX-1009, FIG. 12 (annotated)
`
`
`
`5.
`Combination of Agiwal with Murray
`Agiwal and Murray are in similar technical fields, with both describing
`
`random access procedures for moving a wireless device connection (Agiwal’s
`
`mobile station or UE, and Murray’s WTRU, which can be a UE) from a source
`
`base station (Agiwal’s MeNB or Murray’s source base station) to a target base
`
`station (Agiwal’s SeNB or Murray’s target base station). EX-1003, ¶80; see also
`
`15
`
`

`

`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`supra §§III(A)(1), III(A)(4). Both references describe methods that involve RRC
`
`connection reconfiguration for UE handover. See, e.g., EX-1005, ¶¶[0086-92] and
`
`FIG. 5; EX-1009, ¶¶[0153-156] and FIG. 12; EX-1003, ¶80. Agiwal discloses that
`
`its apparatus (MS/UE) includes a transceiver to transmit and receive signals, and a
`
`processor to identify DL RX and corresponding UL TX beams, and transmit a
`
`random access preamble. See, e.g., EX-1005, ¶[0019], ¶¶[0347-48] and FIG. 36.
`
`Agiwal, however, does not explicitly describe additional functionalities of the
`
`processor. Murray, on the other hand, describes that its WTRU includes a
`
`processor that can be a “general purpose processor” and “perform signal coding,
`
`data processing, power control, input/output processing, and/or any other
`
`functionality that enables the WTRU 102 to operate in a wireless environment.”
`
`EX-1009, ¶[0058]. The processor can perform additional functionalities, such as
`
`power distribution, by receiving “power from the power source 134, and
`
`[distributing] and/or [controlling] the power to the other components in the WTRU
`
`102.” Id., ¶¶[0062-65]. Murray further discloses that “the processor[] and the
`
`transceiver[] may be integrated together in an electronic package or chip.” Id.,
`
`[0058]. See also EX-1003, ¶81.
`
`A POSITA designing a wireless device that implements Agiwal’s random
`
`access procedures in beamformed systems would have benefited from the
`
`knowledge provided by Murray’s disclosure of deploying a general purpose
`
`16
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`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`processor in the wireless device to perform the disclosed procedures, and
`
`integrating the processor with the transceiver. Id., ¶82. This would reduce the
`
`number of hardware components in Agiwal’s wireless device, thereby lowering the
`
`hardware cost by electronic package integration. Id. Enabling additional processor
`
`functionalities using a general purpose processor, without installing additional
`
`dedicated hardware, would also lead to efficiencies in device operation, for
`
`example, improved storage usage, improved power distribution, or removal of
`
`redundant interfaces. Id. See also id., ¶¶83-84.
`
`6.
`
`Agiwal in view of TS36.331 (Ground 1) and Agiwal in
`view of TS36.331 and Murray (Ground 2) renders ob-
`vious Claims 1-3, 6, 8-10, 13-15
`[1Pre] A method performed by a wireless device for handover, the method
`comprising:
`
`[8 Pre] A wireless device for handover comprising:
`To the extent the preamble is limiting, Agiwal teaches a method for
`
`handover performed by a wireless device. For example, disclosing a wireless
`
`communication system with a “low frequency (LF) macro cell” and a plurality of
`
`“high frequency (HF) small cells,” which are respectively served by LF base
`
`station (LF-BS) and HF base stations (HF-BS), Agiwal describes methods in which
`
`a “[m]obile station (MS)” or “user equipment (UE),” “first connects with [a] HF-
`
`BS and then it is handed over to another HF-BS ([]target eNB). In this case the
`
`MeNB … is a source eNB and the SeNB … is a target eNB.” EX-1005,
`
`17
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`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`¶¶[0069-70] (emphasis added) and FIG. 1 (below); see also id., ¶¶[0009-10],
`
`¶¶[0066-68] and ¶[0018], and supra §III(A)(1).
`
`EX-1005, FIG. 1 (annotated)
`
`
`
`A POSITA would have understood that Agiwal’s MS/UE, which
`
`communicates with a first HF-BS (e.g., HF-BS1) and is then handed over to a
`
`second HF-BS (e.g., HF-BS2), corresponds to a wireless device for handover in the
`
`wireless communication system. A POSITA would have also understood that: (a)
`
`Agiwal’s MeNB or source eNB (e.g., HF-BS1) corresponds to the source network
`
`node associated with a source cell (e.g., Agiwal’s HF small cell of HF-BS1) recited
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`18
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`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`in the claims of the ’915 patent, and (b) Agiwal’s SeNB or target eNB (e.g., HF-
`
`BS2) corresponds to the second network node that is associated with a target cell
`
`(e.g., Agiwal’s HF small cell of HF-BS2) recited in the claims of the ’915 patent.
`
`As described in greater detail below, Agiwal discloses multiple methods or
`
`procedures for beamformed random access, describing handover from the source
`
`eNB in the source cell to the target eNB in the target cell. See, e.g., id., ¶¶[0071-
`
`92] and FIGS. 3-5. See also EX-1003, ¶98-107.
`
`[1a] receiving an RRC connection reconfiguration message from a source
`network node associated with a source cell,
`Agiwal teaches this limitation by describing a method for beamformed
`
`random access procedure in FIG. 5, disclosing that the UE receives an RRC
`
`connection reconfiguration message from the MeNB: “At operation 513, the
`
`MeNB 502 transmits the RRC Connection Reconfiguration … to a UE 501.”
`
`EX-1005, ¶[0088] and FIG. 5 (below).
`
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`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`
`EX-1005, FIG. 5 (annotated)
`
`
`
`As explained above, a POSITA would have understood that Agiwal’s
`
`MeNB corresponds to a source network node and the cell served by the MeNB
`
`corresponds to a source cell. See §III(A)(6)[1pre]; see also EX-1003, ¶¶108-109.
`
`[8a] a wireless interface configured to receive an RRC connection
`reconfiguration message from a source network node associated with a source
`cell,
`
`Agiwal teaches that the wireless device receives an RRC connection
`
`reconfiguration message from a source network node associated with a source cell.
`
`See §III(A)(6)[1a].
`
`Agiwal further discloses that the wireless device includes a transceiver
`
`configured to transmit and receive signals: “an apparatus in wireless
`
`communication system is provided. The apparatus includes a transceiver
`
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`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`configured to transmit and receive signals.” EX-1005, ¶[0019] (emphasis
`
`added).
`
`A POSITA would have understood that Agiwal’s UE is an example of the
`
`apparatus, and the transceiver corresponds to a wireless interface that is configured
`
`to receive signals, such as the RRC connection reconfiguration message. See
`
`EX-1003, ¶¶110-112.
`
`[1b/8b] the RRC connection reconfiguration message comprising an
`identification of a target cell and access information associated with the target
`cell,
`
`Agiwal in view of TS 36.331 renders this limitation obvious. For example,
`
`Agiwal discloses that the RRC connection reconfiguration message includes “HF
`
`RACH Config” information, including a preamble for the random access channel
`
`used to perform random access procedures: “SeNB 503 transmits the SeNB
`
`Addition Request ACK including the HF RACH Config. At operation 513, the
`
`MeNB 502 transmits the RRC Connection Reconfiguration including the
`
`received HF RACH Config.” EX-1005, ¶[0088] (emphasis added) and FIG. 5
`
`(below). “The MeNB sends the RRCConnectionReconfiguration message to the
`
`UE[]. The UE performs Uplink synchronisation towards the SeNB using the
`
`random access procedure. … In such a system, sending of the random access
`
`preamble (RACH) [is] performed in a beam formed manner.” Id., ¶¶[0013-14]
`
`(emphasis added).
`
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`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`
`EX-1005, FIG. 5 (annotated)
`
`
`
`A POSITA would have understood that Agiwal’s SeNB corresponds to a
`
`target network node and the cell served by the SeNB corresponds to a target cell.
`
`See §III(A)(6)[1pre][8pre]. Further, that “HF RACH Config” in the RRC
`
`connection reconfiguration message corresponds to the access information
`
`associated with the target cell. See EX-1003, ¶¶113-115.
`
`Agiwal teaches that the HF RACH Config includes information about the
`
`target cell, including the beamforming capabilities of the SeNB serving the target
`
`cell: “SeNB[] transmits the SeNB Addition Request ACK including its
`
`beamforming capability []in the HF random access preamble (RACH) Config
`
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`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`[wherein] said capability includes the Number of TX Beams (P) and the
`
`Number of RX Beams (M) supported by the SeNB.” EX-1005, ¶[0073]
`
`(emphasis added). As discussed below, the HF RACH Config includes
`
`information identifying the SeNB and associated access information (e.g.,
`
`information about TX and RX beams supported by the SeNB), and
`
`correspondingly the target cell served by the SeNB, to enable the UE to connect to
`
`the SeNB. See §III(A)(6)[1d/8d]. See EX-1003, ¶116.
`
`Moreover, a POSITA would have known or would have found it obvious,
`
`based on TS36.331 as noted below, that the RRC Connection Reconfiguration
`
`Message for handover includes the MobilityControlInfo information element (IE),
`
`which specifies (i) physical cell identifier for the target cell (“targetPhysCellId”)
`
`and (ii) access parameters for the target cell (e.g., “carrierFreq,”
`
`“carrierBandwidth,” “radioResourceConfigCommon” and “rach-
`
`ConfigDedicated,” among others). As discussed above, a POSITA would have
`
`been motivated to combine Agiwal and TS36.331. See supra §III(A)(3) and
`
`EX-1003, ¶¶117-118.
`
`For example, TS36.331 teaches that, in handover, the UE shall identify the
`
`target cell and determine associated access parameters (e.g., carrier frequency)
`
`using information in the mobilityControlInfo IE in the
`
`RRCConnectionReconfiguration message: when “the
`
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`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`RRCConnectionReconfiguration message includes the mobilityControlInfo,” the
`
`UE shall “consider the target PCell to be one on the frequency indicated by the
`
`carrierFreq with a physical cell identity indicated by the targetPhysCellId[.]”
`
`EX-1008, §5.3.5.4 (emphasis added); see also id., §6.3.4, 302-304
`
`(“MobilityControlInfo information element,” below), and §III(A)(6)[1d/8d]
`
`(describing the access information provided by “radioResourceConfigCommon”
`
`and “rach-ConfigDedicated” in mobilityControlInfo).
`
`EX-1008, §6.3.4, 302-304 (annotated)
`
`
`
`A POSITA accordingly would have found it obvious that Agiwal in view of
`
`TS36.331 teaches that the RRC connection reconfiguration message includes
`
`information identifying the target cell, and random access configuration
`
`information, such as information about the number of TX and RX beams, and
`
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`Attorney Docket No. 50095-0070IP1
`IPR of U.S. Patent No. 10,484,915
`associated carrier frequency and carrier bandwidth, for the target cell. See
`
`EX-1003, ¶117.
`
`[1c/8c] wherein the target cell is different than the source cell and comprises one
`or more beams to be transmitted by the target cell and
`Agiwal teaches this limitation. For example, Agiwal discloses its handover
`
`procedures involve handing over the wireless device from the MeNB (e.g., HF-
`
`BS1) in a first HF small cell to the SeNB (e.g., HF-BS2) in a second HF small cell.
`
`See III(A)(6)[1pre]; see also EX-1005, FIG. 1 (below). A P