`
`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`––––––––––
`
`SAMSUNG ELECTRONICS AMERICA, INC.,
`
`SAMSUNG ELECTRONICS CO., LTD.,
`
`Petitioners,
`
`
`v.
`
`COBBLESTONE WIRELESS, LLC,
`
`Patent Owner.
`
`––––––––––
`Case No. IPR2024-00318
`
`U.S. Patent No. 8,554,196
`
`––––––––––
`
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 8,554,196
`
`
`
`02198-00092/14565213.3
`
`Cobblestone Wireless, LLC
`Ex. 2026, IPR2024-00315
`Page 1 of 88
`
`

`

`
`
`
`
`
`I.
`
`TABLE OF CONTENTS
`
`Introduction ...................................................................................................... 1
`
`II.
`
`Standing ........................................................................................................... 3
`
`III.
`
`Identification of Challenge And Relief Requested .......................................... 3
`
`IV. Level Of Ordinary Skill In The Art ................................................................. 3
`
`V.
`
`The ’196 patent ................................................................................................ 4
`
`A. Overview ............................................................................................... 4
`
`B.
`
`Prosecution History of the ’196 patent .................................................. 5
`
`VI. Overview Of The Prior Art .............................................................................. 5
`
`A.
`
`Chitrapu (Ex. 1005) ............................................................................... 5
`
`B. Wong (Ex. 1006) ................................................................................... 7
`
`C.
`
`Dinan (Ex. 1007) ................................................................................... 9
`
`VII. Claim Construction ........................................................................................ 10
`
`VIII. Detailed Explanation of Invalidity Grounds .................................................. 10
`
`A. Ground 1: Claims 1-5, 7, 10, 12, 14, 17, 18, 20, and 21 are
`Rendered Obvious in View of Chitrapu .............................................. 10
`
`1.
`
`2.
`
`3.
`
`Claim 1 ...................................................................................... 10
`
`Claim 2: “The method of claim 1, wherein the providing
`the second coverage configuration comprises determining
`a direction of transmission for the second beam based at
`least in part on a location of the at least one continuous
`use device.” ............................................................................... 20
`
`Claim 3: “The method of claim 1, wherein the second
`beam of the first network is further configured to provide
`coverage to a second continuous use device of the group
`of devices.” ................................................................................ 21
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`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
`
`Claim 4: “The method of claim 1, wherein a subsequent
`iteration of providing the second coverage configuration
`includes transmitting the second beam of the first
`network configured to provide coverage to a second
`continuous use device, and wherein the at least one
`continuous use device has transitioned to being an
`interval use device.” .................................................................. 21
`
`Claim 5: “The method of claim 1, wherein the first
`network and the second network are different network
`types.”........................................................................................ 23
`
`Claim 7: “The method of claim 1, wherein the first
`network and the second network are the same network
`types, and wherein the at least one continuous use device
`is allowed access to the second beam based on an
`admission control parameter.” .................................................. 23
`
`Claim 10: “The method of claim 1, wherein the at least
`one continuous use device is engaged in at least one of a
`voice call, a download, or a content streaming.” ...................... 25
`
`Claim 12: “The method of claim 1, wherein the second
`beam is narrower than the first beam in at least one of a
`horizontal plane or a vertical plane.” ........................................ 25
`
`9.
`
`Claim 14 .................................................................................... 27
`
`10. Claims 17, 18, 20, 21 ................................................................ 34
`
`B.
`
`Ground 2: Claims 1-5, 7, 8, 12, 14, 17, 18, 20, and 21 Are
`Rendered Obvious by Chitrapu in View of Wong .............................. 35
`
`1.
`
`2.
`
`3.
`
`4.
`
`Rationale to Combine Chitrapu with Wong ............................. 36
`
`Limitations 1[a], 14[a], 17[a], and 20[a]: “cycling over
`time through a coverage sequence” .......................................... 40
`
`Claim 5 ...................................................................................... 40
`
`Claim 8: “The method of claim 1, wherein the first
`coverage configuration is provided for a first time
`duration and the second coverage configuration is
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`Page 3 of 88
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`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
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`provided for a second time duration that is longer than
`the first time duration.” ............................................................. 41
`
`C.
`
`Ground 3: Claims 1-5, 8, 10, 12, 14, 17, and 20 Are Rendered
`Obvious by Dinan in View of Wong ................................................... 42
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`Rationale to Combine Dinan with Wong .................................. 42
`
`Claim 1 ...................................................................................... 45
`
`Claim 2: “The method of claim 1, wherein the providing
`the second coverage configuration comprises determining
`a direction of transmission for the second beam based at
`least in part on a location of the at least one continuous
`use device.” ............................................................................... 55
`
`Claim 3: “The method of claim 1, wherein the second
`beam of the first network is further configured to provide
`coverage to a second continuous use device of the group
`of devices.” ................................................................................ 56
`
`Claim 4: “The method of claim 1, wherein a subsequent
`iteration of providing the second coverage configuration
`includes transmitting the second beam of the first
`network configured to provide coverage to a second
`continuous use device, and wherein the at least one
`continuous use device has transitioned to being an
`interval use device.” .................................................................. 56
`
`Claim 5: “The method of claim 1, wherein the first
`network and the second network are different network
`types.”........................................................................................ 57
`
`Claim 8: “The method of claim 1, wherein the first
`coverage configuration is provided for a first time
`duration and the second coverage configuration is
`provided for a second time duration that is longer than
`the first time duration.” ............................................................. 57
`
`Claims 10: “The method of claim 1, wherein the at least
`one continuous use device is engaged in at least one of a
`voice call, a download, or a content streaming.” ...................... 57
`
`02198-00092/14565213.3
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`Page 4 of 88
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`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
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`9.
`
`Claims 12: “The method of claim 1, wherein the second
`beam is narrower than the first beam in at least one of a
`horizontal plane or a vertical plane.” ........................................ 58
`
`10. Claim 14 .................................................................................... 58
`
`11. Claims 17 and 20....................................................................... 64
`
`IX. Discretionary Denial ...................................................................................... 66
`
`A.
`
`Fintiv.................................................................................................... 66
`
`B.
`
`C.
`
`General Plastic .................................................................................... 67
`
`35 U.S.C. §325(d)................................................................................ 68
`
`X.
`
`Ranking of Parallel Petitions ......................................................................... 69
`
`XI. Mandatory Notices And Fees ........................................................................ 71
`
`A.
`
`Real Party-In-Interest .......................................................................... 71
`
`B.
`
`C.
`
`Related Matters .................................................................................... 71
`
`Counsel and Service Information ........................................................ 72
`
`D.
`
`Payment of Fees .................................................................................. 73
`
`XII. Conclusion ..................................................................................................... 73
`
`
`
`
`
`
`
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`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
`
`EXHIBIT LIST
`
`Ex.
`
`Description
`
`1001
`
`U.S. Patent No. 8,554,196 (“’196 patent”)
`
`1002
`
`File History for U.S. Patent No. 8,554,196
`
`1003
`
`Declaration of Dr. Kevin Almeroth
`
`1004
`
`Curriculum Vitae of Dr. Kevin Almeroth
`
`1005
`
`U.S. Patent Pub. No. 2005/0261028 (“Chitrapu”)
`
`1006
`
`U.S. Patent No. 8,548,525 (“Wong”)
`
`1007
`
`U.S. Patent No. 8,285,291 (“Dinan”)
`
`1008
`
`Patent Owner’s Infringement Contentions in Cobblestone Wireless,
`LLC v. Samsung Electronics America, Inc., et al., No. 2:23-cv-
`00285 (E.D. Tex.) filed June 16, 2023
`
`1009
`
`Cobblestone Wireless, LLC v. Samsung Electronics Co., Ltd., No.
`2:22-cv-00285-JRG-RSP, Dkt. 29-1, Docket Control Order
`
`
`
`
`
`
`
`02198-00092/14565213.3
`
`
`v
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`Ex. 2026, IPR2024-00315
`Page 6 of 88
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`

`
`
`Claim
`
`1[pre]
`
`1[a]
`
`1[b]
`
`1[c]
`
`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
`
`LIST OF CHALLENGED CLAIMS
`
`Limitation
`
`A method for providing network coverage for a group of devices
`in an area comprising:
`
`cycling over time through a coverage sequence that includes
`providing a first coverage configuration and providing a second
`coverage configuration, wherein:
`
`providing the first coverage configuration includes transmitting a
`first beam of a first network that is configured to provide
`coverage for the group of devices; and
`
`providing the second coverage configuration includes
`transmitting a second beam of the first network that is narrower
`than the first beam and configured to provide coverage to at least
`one continuous use device of the group of devices, the at least
`one continuous use device being actively involved in a
`substantially continuous service with the network,
`
`1[d]
`
`and providing coverage by a second network to a plurality of
`interval use devices of the group of devices.
`
`
`
`
`
`
`
`2
`
`3
`
`4
`
`The method of claim 1, wherein the providing the second
`coverage configuration comprises determining a direction of
`transmission for the second beam based at least in part on a
`location of the at least one continuous use device.
`
`The method of claim 1, wherein the second beam of the first
`network is further configured to provide coverage to a second
`continuous use device of the group of devices.
`
`The method of claim 1, wherein a subsequent iteration of
`providing the second coverage configuration includes
`
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`
`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
`
`Claim
`
`Limitation
`
`transmitting the second beam of the first network configured to
`provide coverage to a second continuous use device, and wherein
`the at least one continuous use device has transitioned to being
`an interval use device.
`
`5
`
`7
`
`8
`
`10
`
`12
`
`
`
`
`
`
`
`
`
`
`
`
`
`The method of claim 1, wherein the first network and the second
`network are different network types.
`
`The method of claim 1, wherein the first network and the second
`network are the same network types, and wherein the at least one
`continuous use device is allowed access to the second beam
`based on an admission control parameter.
`
`The method of claim 1, wherein the first coverage configuration
`is provided for a first time duration and the second coverage
`configuration is provided for a second time duration that is
`longer than the first time duration.
`
`The method of claim 1, wherein the at least one continuous use
`device is engaged in at least one of a voice call, a download, or a
`content streaming.
`
`The method of claim 1, wherein the second beam is narrower
`than the first beam in at least one of a horizontal plane or a
`vertical plane.
`
`14[pre]
`
`A method for providing network coverage for a group of devices
`in an area comprising:
`
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`Claim
`
`14[a]
`
`14[b]
`
`14[c]
`
`14[d]
`
`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
`
`Limitation
`
`cycling over time through a coverage sequence that includes
`providing a first coverage configuration, providing a second
`coverage configuration, and providing a third coverage
`configuration, wherein:
`
`providing the first coverage configuration includes transmitting a
`first beam of a first network that is configured to provide
`coverage for a first set of the group of devices, and providing
`coverage by a second network to at least a second set of the
`group of devices;
`
`providing the second coverage configuration includes
`transmitting a second beam of the first network that is configured
`to provide coverage for the second set of the group of devices,
`and providing coverage by the second network to at least the first
`set of the group of devices; and
`
`providing the third coverage configuration includes transmitting
`a third beam of the first network that is narrower than the first
`beam and is configured to provide coverage to at least one
`continuous use device of the group of devices, the at least one
`continuous use device being actively involved in a substantially
`continuous service with the network,
`
`14[e]
`
`and providing coverage by the second network to at least a
`plurality of interval use devices of the group.
`
`
`
`17[pre]
`
`A machine readable non-transitory medium having stored therein
`instructions that, when executed, cause a device to provide a
`network coverage by:
`
`17[a]
`
`cycling over time through a coverage sequence that includes
`providing a first coverage configuration and providing a second
`coverage configuration, wherein:
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`Claim
`
`17[b]
`
`17[c]
`
`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
`
`Limitation
`
`providing the first coverage configuration includes transmitting a
`first beam of a first network that is configured to provide
`coverage for the group of devices; and
`
`providing the second coverage configuration includes
`transmitting a second beam of the first network that is narrower
`than the first beam and configured to provide coverage to at least
`one continuous use device of the group of devices, the at least
`one continuous use device being actively involved in a
`substantially continuous service with the network,
`
`17[d]
`
`and providing coverage by a second network to a plurality of
`interval use devices of the group of devices.
`
`
`
`
`
`18
`
`The machine readable non-transitory medium of claim 17,
`wherein the first network and the second network are the same
`network types, and wherein the at least one active device is
`allowed access to the second beam based on an admission
`control parameter.
`
`20[pre]
`
`A device comprising: a machine readable medium having stored
`therein instructions that, when executed, cause the device to
`provide network coverage by:
`
`20[a]
`
`20[b]
`
`20[c]
`
`cycling over time through a coverage sequence that includes
`providing a first coverage configuration and providing a second
`coverage configuration, wherein:
`
`providing the first coverage configuration includes transmitting a
`first beam of a first network that is configured to provide
`coverage for the group of devices; and
`
`providing the second coverage configuration includes
`transmitting a second beam of the first network that is narrower
`than the first beam and configured to provide coverage to at least
`
`02198-00092/14565213.3
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`ix
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`Claim
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`Limitation
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`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
`
`20[d]
`
`20[e]
`
`20[f]
`
`
`
`21
`
`one continuous use device of the group of devices, the at least
`one continuous use device being actively involved in a
`substantially continuous service with the network,
`
`and providing coverage by a second network to a plurality of
`interval use devices of the group of devices;
`
`a processor coupled to the machine readable medium to execute
`the instructions; and
`
`an adaptive antenna configured to transmit the first beam and the
`second beam.
`
`The device of claim 20, wherein the first network and the second
`network are the same network types, the at least one active
`device is allowed access to the second beam based on an
`admission control parameter, and the adaptive antenna is further
`configured to transmit a third beam of the second network.
`
`
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`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
`
`I.
`
`INTRODUCTION
`
`Samsung Electronics America, Inc. and Samsung Electronics Co., Ltd.
`
`(“Petitioners”) respectfully requests inter partes review of claims 1-5, 7, 8, 10, 12,
`
`14, 17, 18, 20, and 21 (the “Challenged Claims”) of U.S. Patent No. 8,554,196 (the
`
`“’196 patent”) pursuant to 35 U.S.C. §311 and 37 C.F.R. §42.100.
`
`The ’196 patent is directed to conventional beamforming techniques in a
`
`wireless system that were well-known by the patent’s earliest priority date, August
`
`2011. The claims of the ’196 patent describe providing coverage to mobile devices
`
`using a wide beam for intermittent data usage and a narrow beam better suited for
`
`continuous use (such as streaming or downloading). Such techniques had long
`
`been used in wireless systems.
`
`For example, Chitrapu discloses a wireless system that uses three beams: (1)
`
`an omni-directional beam for initial handshaking, (2) a narrow cover beam for
`
`broadcasting or paging messages, and (3) a very narrow center beam for providing
`
`high throughput transmission of data. Chitrapu discloses cycling through these
`
`different beams to provide the level of service needed by the mobile device.
`
`Chitrapu also discloses that the omni-directional beam or cover beam can locate
`
`the device so that the center beam can be directed toward the device.
`
`Another example is Dinan, which describes an algorithm for providing
`
`simultaneous 3G and 4G coverage, where a device is assigned 3G or 4G service
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`02198-00092/14565213.3
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`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
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`depending on its data and QoS needs. Dinan discloses that applications with high
`
`QoS needs, such as video streaming or VoIP, are given the highest priority to 4G
`
`service, whereas applications with intermittent data usage, such as Email, is given
`
`the lowest priority and often assigned 3G service. In an environment that allows
`
`for beamforming, a POSITA would have looked to a variety of references to
`
`describe how to specifically implement beamforming. One such example is Wong.
`
`It would have been obvious to combine it with Wong, which expressly discloses
`
`using antenna patterns in a WiMAX (a 4G service) system and a scheduler that
`
`cycles through these patterns. These antenna patterns use beams of various widths
`
`depending on the particular needs of the coverage area. For example, Wong
`
`discloses that the scheduler can initially use 90 degree beam patterns around a
`
`coverage area, and then schedule narrower antenna patterns if it detects high
`
`traffic, or wider antenna patterns if it detects low amounts of traffic.
`
`Along with this Petition, Petitioners have concurrently filed another Petition
`
`(IPR2024-00317) against different claims of the ’196 Patent using different prior
`
`art. That Petition is a copycat of the Petition filed in T-Mobile USA, Inc. et al. v.
`
`Cobblestone Wireless, LLC, IPR2024-00135. The claims, prior art, and arguments
`
`in the Copycat Petition are materially different from those in this Petition.
`
`02198-00092/14565213.3
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`2
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`II.
`
`STANDING
`
`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
`
`Petitioners certify that the ’196 patent is available for IPR and that Petitioners
`
`are not barred or estopped from presenting the grounds identified in this Petition.
`
`III.
`
`IDENTIFICATION OF CHALLENGE AND RELIEF REQUESTED
`
`Petitioners request cancellation of claims 1-5, 7, 8, 10, 12, 14, 17, 18, 20, 21
`
`(“Challenged Claims”) on the following grounds:
`
`Ground
`
`Reference(s)
`
`Chitrapu
`
`Chitrapu, Wong
`
`1
`
`2
`
`3
`
`Basis
`
`§103
`
`§103
`
`Claims
`
`1-5, 7, 10, 12, 14, 17, 18,
`20, 21
`
`1-5, 7, 8, 10, 12, 14, 17, 18,
`20, 21
`
`Dinan, Wong
`
`§103
`
`1-5, 8, 10, 12, 14, 17, 20
`
`
`
`IV. LEVEL OF ORDINARY SKILL IN THE ART
`
`A person of ordinary skill in the art (“POSITA”) as of August 24, 2011 would
`
`have had at least a bachelor’s degree in electrical engineering, computer engineering,
`
`computer science, physics, or the equivalent, and at least two years of experience
`
`working in the field. Ex. 1003, ¶¶50-51. Less work experience may be compensated
`
`by a higher level of education or vice versa. Id. Relevant working experience would
`
`include experience with cellular telecommunications and networking, radio-access
`
`networking architectures, protocols and signal propagation in wireless networks. Id.
`
`Petitioners’ expert, Dr. Kevin Almeroth, exceeds this definition. Id., ¶51.
`
`02198-00092/14565213.3
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`3
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`V. THE ’196 PATENT
`
`A. Overview
`
`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
`
`U.S. Pat. No. 8,554,196 (the “’196 patent”) is directed to “Technologies and
`
`implementations for providing network coverage by cycling through beam shape
`
`coverage configurations.” Ex. 1001, Abstract; Ex. 1003, ¶¶52-53. The claims are
`
`directed to cycling through two or more coverage configurations. For example, “a
`
`first coverage configuration may include a beam that may be relatively wide such
`
`that it may provide coverage for all the devices in an area or sector.” Ex. 1001, 3:38-
`
`41. And a “second coverage configuration may include a beam that may be
`
`relatively narrow such that it may provide coverage by the first network type for one
`
`or more continuous use devices in the area.” Id., 3:42-45.
`
`The ’196 patent describes “continuous use devices” as “a device that may be
`
`actively involved in a substantially continuous service with the network,” such as “a
`
`voice call, a download, a content streaming, or the like.” Id., 3:47-51. The ’196
`
`patent further describes “interval use devices” that “may have applications that
`
`require intermittent updating such as, for example, social networking applications,
`
`email, Really Simple Syndication (RSS) feeds, map updates, game update, sports
`
`score update, or the like.” Id., 4:10-13. Because of the intermittent use of such
`
`applications, “during the second coverage configuration, the interval use devices
`
`may be on a less capable network.” Id., 4:14-15.
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`02198-00092/14565213.3
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`
`B.
`
`Prosecution History of the ’196 patent
`
`The ’196 Patent originated with the filing of U.S. Patent Application No.
`
`Petition for Inter Partes Review
`U.S. Patent No. 8,554,196
`
`13/321,792 (“the ’792 App.”) on November 21, 2011. Ex. 1001, Cover. The ’196
`
`Patent claims ultimate priority to PCT Application No. PCT/US2011/049003, which
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`was filed on August 24, 2011. Id. The Patentee also petitioned to join the Patent
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`Prosecution Highway program based on the PCT application, which was granted on
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`March 7, 2012. Ex. 1002, 244; Ex. 1003, ¶¶54-55.
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`After joining the Patent Prosecution Highway program, the ’196 Patent had a
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`brief prosecution history consisting only of a single rejection. In that non-final
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`rejection, the examiner rejected all claims under 35 U.S.C. § 103(a) as unpatentable
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`over Vendryes (U.S. Patent No. 6,546,259) in view of Gale et al. (U.S. Patent App.
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`Pub. No. 2011/0223925). Ex. 1002, 70. In response, the applicant amended the
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`claims to specify that the continuous use device is “actively involved in a
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`substantially continuous service with the network.” Ex. 1002, 42-60. The applicant
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`also argued that Gale does not disclose continuous service with the network. Id.
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`Following those amendments, the examiner allowed the claims. Id., 33.
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`VI. OVERVIEW OF THE PRIOR ART
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`A. Chitrapu (Ex. 1005)
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`U.S. Patent Pub. No. 2005/0261028 (“Chitrapu”) was published on November
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`24, 2005 and is therefore prior art under pre-AIA §102(b).
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`Chitrapu discloses a base station that provides network coverage using three
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`types of beams: (1) omni-directional beams for initial handshaking, (2) cover beams
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`for intermittent usage such as broadcasting and paging, and (3) center beams for
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`high-throughput, high quality-of-service transmissions. Ex. 1003, ¶¶58-59.
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`Chitrapu discloses “a base station” that provides network coverage to “a plurality of
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`WTRUs,” i.e., “wireless transmit/receive units” that include “any ... type of device
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`capable of operating in a wireless environment.” Ex. 1005, ¶18, 11; Fig. 3A. For
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`example, in Figure 3A, omni-directional beam 206 and cover beam 204 both provide
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`network coverage to devices 216 and 218 (and additional devices not shown). Ex.
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`1003, ¶58.
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`Chitrapu further discloses that when “new cover beams need to be deployed
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`to bring additional WTRUs [i.e., devices] within the coverage areas of a cover beam,”
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`the system “may adjust [a pre-existing] cover beam ... and deploy an additional
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`center beam ... focused” on the device. Ex. 1005, ¶24. For example, in Figure 3A,
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`device 226 is not currently being covered by a cover or center beam. Ex. 1003, ¶59.
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`B. Wong (Ex. 1006)
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`U.S. Patent No. 8,548,525 (“Wong”) was published on January 1, 2009. It is
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`therefore prior art under pre-AIA §102(b).
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`Wong teaches a system where “various narrow and/or wide antenna patterns
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`may be selected ... for directing to particular portions of [a] service area ... and the
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`initial scheduling plan invoked by scheduler 242 may be adapted.” Ex. 1006, 8:51-
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`54. In a “highly simplified representation,” Figure 4 of Wong depicts “4
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`substantially 90° antenna patterns [411-414]”, which together “provide illumination
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`of service area 121.” Id., 8:56-67; Ex. 1003, ¶60.
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`
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`Wong teaches that the scheduler could cycle to another coverage
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`configuration which uses narrow beams by selecting antenna patterns depicted in
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`Figure 5, where “antenna pattern 413 has been replaced with antenna patterns 513
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`and 514,” both of which are narrower than the beam in antenna pattern 413. Ex.
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`1006, 12:58-59; Ex. 1003, ¶61. In particular, “[a]ntenna pattern 514 provides a more
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`narrow beam antenna pattern consistent with the higher utilization of the
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`corresponding portion of service area 121.” Id., 12:64-67.
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`C. Dinan (Ex. 1007)
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`U.S. Patent No. 8,285,291 (“Dinan”) was filed on February 2, 2010 and
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`published on August 4, 2011. It is therefore prior art under pre-AIA §102(a) and
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`(e).
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`Dinan teaches a “operating a dual-mode 3G/4G communications device
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`capable of operating in either a 3G or 4G network when in an area with overlapping
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`3G and 4G coverage.” Ex. 1007, 7:19-22. Thus, as depicted in Figure 1, “dual-
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`mode device 110 is in a coverage overlap area with acceptable 3G and 4G network
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`access.” Id., 12:45-46; Ex. 1003, ¶62.
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`Dinan further describes an algorithm for determining whether a device is
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`assigned 3G or 4G service. Ex. 1003, ¶63. In particular, Dinan uses “QoS
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`categories” to “assign relatively higher or lower priority to various application
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`types.” Ex. 1007, 11:48-49. For example, “streaming of high definition (HD) video,
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`video conferencing, and voice (e.g., VoIP) may be assigned a highest QoS category,
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`i.e., category ‘C1’, while applications of lesser relative importance or with less
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`stringent data latency requirements may be assigned lower QoS categories ‘C2’ or
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`‘C3’.” Id., 11:49-54. A higher QoS category will be given priority to 4G service,
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`whereas a lower QoS category will often be assigned 3G service. Id., 15:3-38; Ex.
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`1003, ¶63.
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`VII. CLAIM CONSTRUCTION
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`Petitioners have applied the ordinary and customary meaning of the claim
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`terms as they would have been understood by a POSITA at the time of the alleged
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`invention, in the context of the ’196 patent and its prosecution history. Phillips v.
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`AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (en banc). Petitioners do not believe
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`any term needs to be expressly construed beyond its plain and ordinary meaning.
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`Ex. 1003, ¶¶56-57.
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`VIII. DETAILED EXPLANATION OF INVALIDITY GROUNDS
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`The following grounds establish a reasonable likelihood that the Petitioners
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`will prevail with respect to the Challenged Claims. Ex. 1003, ¶¶64-231.
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`A. Ground 1: Claims 1-5, 7, 10, 12, 14, 17, 18, 20, and 21 are Rendered
`Obvious in View of Chitrapu
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`1.
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`Claim 1
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`(a)
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`1[pre]: A method for providing network coverage for
`a group of devices in an area comprising:
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`To the extent the preamble is limiting, Chitrapu discloses this limitation. Ex.
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`1003, ¶64. Chitrapu discloses “a base station” that provides network coverage to “a
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`plurality of WTRUs,” i.e., “wireless transmit/receive units” that include “any ... type
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`of device capable of operating in a wireless environment.” Ex. 1005, ¶18, 11; Fig.
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`3A. Figure 3A depicts the base station 203 providing coverage for those devices in
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`an area around the base station using, for example, omni-directional beam 206, cover
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`beams 202, 204, and center beams 212, 214, and 208. Id. For example, in Figure
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`3A, omni-directional beam 206 and cover beam 204 both provide network coverage
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`to devices 216 and 218 (and additional devices not shown). Ex. 1003, ¶64.
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`(b)
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`1[a]: cycling over time through a coverage sequence
`that includes providing a first coverage configuration
`and providing a second coverage configuration,
`wherein:
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`Chitrapu discloses this