Obviousness

Obviousness Analysis of U.S. Patent 11,212,838

Introduction

This analysis examines the obviousness of U.S. Patent No. 11,212,838, titled "Method and apparatus for transmitting uplink data on uplink resources," under 35 U.S.C. § 103. The patent, issued on December 28, 2021, is directed to methods and apparatuses for a wireless transmit/receive unit (WTRU) to manage uplink resources based on a timer. An invention is considered obvious if the differences between the subject matter sought to be patented and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art. This analysis will consider combinations of prior art references to demonstrate that the claims of the '838 patent would have been obvious to a person of ordinary skill in the art of wireless communications in 2008, the earliest priority year of the patent.

Claim Analysis

The independent claims of the '838 patent are central to this analysis. Independent claim 1 recites a WTRU comprising a receiver, a transmitter, and a processor. The key limitations of this claim are:

1. Receiving a radio resource control (RRC) message indicating uplink resources for the WTRU and medium access control (MAC) timer information.
2. Transmitting uplink data based on the indicated uplink resources.
3. Deactivating the indicated uplink resources in response to a MAC timer expiring.
4. The MAC timer is configured based on the MAC timer information indicated by the received RRC message.

Independent claim 6 mirrors these limitations in a method format. The core of the claimed invention lies in the deactivation of allocated uplink resources based on the expiration of a MAC timer, where the timer's configuration is provided via an RRC message.

Prior Art Landscape

A review of the prior art cited during the prosecution of the '838 patent, as well as other relevant art in the field of wireless communications prior to 2008, reveals several key references that, in combination, render the claims of the '838 patent obvious. The primary references considered in this analysis are:

• US 2009/0086671 A1 ("'671 application"): This application, which shares a common assignee and inventors with the '838 patent, discloses methods for terminating transmission of a message in an enhanced random access channel (E-RACH). It explicitly discusses the use of timers to control the duration of resource allocation.
• US 7,643,419 B2 ("'419 patent"): This patent describes a method and apparatus for implementing a data lifespan timer for enhanced dedicated channel (E-DCH) transmissions. It teaches the concept of de-allocating resources after a timer expires.
• 3GPP Technical Specifications (e.g., TS 25.321, TS 25.331): The 3rd Generation Partnership Project (3GPP) standards existing before 2008 extensively detail the functioning of RRC and MAC layers in UMTS networks. These specifications describe the use of RRC messages for configuring various parameters and MAC layer functions, including resource allocation and control.

Obviousness Combinations

1. Combination of the '671 application and 3GPP Standards

The '671 application discloses the core concept of using a timer to manage the allocation of uplink resources. Specifically, it teaches a WTRU releasing E-DCH resources upon the expiry of an associated timer. The motivation for this is to prevent a single WTRU from monopolizing shared resources for an extended period, thereby improving overall system efficiency and fairness.

While the '671 application describes the use of a timer for resource de-allocation, it may not explicitly detail the configuration of this timer via an RRC message as claimed in the '838 patent. However, a person of ordinary skill in the art at the time would have been intimately familiar with the 3GPP standards. The 3GPP specifications, such as TS 25.331, establish the RRC protocol as the standard mechanism for configuring and controlling the behavior of a WTRU. This includes setting up radio bearers, configuring MAC and physical layer parameters, and managing mobility.

Therefore, it would have been a natural and obvious design choice for a skilled engineer to implement the timer configuration described in the '671 application using the well-established RRC signaling framework. The motivation to do so would be to leverage the existing, standardized control plane for managing WTRU parameters, ensuring interoperability and consistent behavior across different network implementations. A person of ordinary skill would have recognized that RRC messaging is the appropriate and standard way to convey such configuration information (the MAC timer information) to the WTRU. This combination would thus render the limitations of the independent claims of the '838 patent obvious.

2. Combination of the '419 patent and 3GPP Standards

The '419 patent also teaches the use of a timer to control the lifespan of data in an E-DCH context, leading to the de-allocation of resources. The patent describes that upon the expiration of a "data lifespan timer," the WTRU may discard data and implicitly release the associated resources.

Similar to the argument above, while the '419 patent provides the concept of a timer-based resource release, the implementation detail of configuring this timer via an RRC message would have been obvious to a person of ordinary skill in the art by referencing the prevailing 3GPP standards. The motivation to combine these teachings is rooted in the fundamental principles of cellular network design. The RRC layer is responsible for the control and configuration of the radio interface. When a new timer-based mechanism for resource management is introduced at the MAC layer, the most logical and predictable approach for configuring that timer is through the RRC protocol. This ensures that the network has control over the WTRU's behavior and can adjust the timer values based on network load, quality of service requirements, and other operational parameters.

A skilled engineer, when tasked with implementing the timer-based de-allocation taught in the '419 patent, would have naturally turned to RRC signaling as the standard and efficient method for communicating the timer's configuration to the WTRU. This would not have required any inventive step but would have been a straightforward application of established design principles in wireless communication systems.

Motivation to Combine

The primary motivation to combine the teachings of either the '671 application or the '419 patent with the established 3GPP standards stems from the desire for standardization, interoperability, and efficient network control. A person of ordinary skill in the art would seek to implement new features within the existing architectural framework of the cellular system. Using RRC messaging for configuring a MAC layer timer is a direct application of this principle. It avoids the need to create a new, proprietary signaling mechanism and ensures that the network can dynamically manage resource allocation policies.

Furthermore, the problem addressed by the '838 patent – the efficient management of uplink resources in a shared channel environment – was a well-known challenge in wireless communications. The use of timers to prevent resource hogging and to release inactive resources was a common and well-understood technique. The specific implementation detail of configuring such a timer via an RRC message would have been an obvious and logical step for anyone skilled in the art of 3GPP system design.

Conclusion

Based on the analysis of the prior art, the independent claims of U.S. Patent No. 11,212,838 would have been obvious to a person of ordinary skill in the art at the time of the invention. The core concept of using a timer to deactivate uplink resources is taught by prior art references such as the '671 application and the '419 patent. The further limitation of configuring this timer via an RRC message would have been an obvious implementation choice for a skilled engineer, as it represents the standard and established method for configuring WTRU parameters within the 3GPP framework. The motivation to combine these teachings is clear and compelling, driven by the fundamental principles of cellular network design and the need for standardized and efficient control mechanisms. Therefore, the claims of the '838 patent do not meet the non-obviousness requirement of 35 U.S.C. § 103.