US 11641661

US Patent 11641661, titled "Methods and apparatuses for determining quasi co-location (QCL) assumptions for beam operations," was issued to Hannibal IP LLC on May 2, 2023, from an application filed on May 6, 2021. The inventors are Chien-Chun Cheng, Tsung-Hua Tsai, Yu-Hsin Cheng, and Wan-Chen Lin.

Abstract:
The patent describes a method and User Equipment (UE) for beam operations in wireless communication. The method involves a UE monitoring multiple Control Resource Sets (CORESETs) within an active Bandwidth Part (BWP) of a serving cell in a time slot. It then applies a Quasi Co-Location (QCL) assumption from a specific CORESET to receive a Downlink (DL) Reference Signal (RS). This specific CORESET is characterized by being associated with a monitored search space that has the lowest CORESET Identity (ID) among all monitored CORESETs. Additionally, the UE can receive Downlink Control Information (DCI) scheduling a Physical Downlink Shared Channel (PDSCH) from a Physical Downlink Control Channel (PDCCH), and apply the QCL assumption used for the PDCCH reception to the PDSCH, especially when the time difference (scheduling offset) between the PDCCH and PDSCH is less than a threshold.

Plain-Language Overview of Independent Claims:

• Independent Claim 1 (User Equipment): This claim describes a User Equipment (UE) designed for beam operations. It includes computer-readable media and a processor that enables the UE to:

  1. Monitor CORESETs: Observe at least some of the configured Control Resource Sets (CORESETs) within a specific active frequency band (BWP) of a serving cell during a time slot.
  2. Receive Scheduled DL RS: Acquire Downlink Control Information (DCI) that schedules a Downlink Reference Signal (DL RS). This action is specifically triggered when the time gap between the end of the Physical Downlink Control Channel (PDCCH) carrying the DCI and the beginning of the DL RS resource is smaller than a predetermined limit (threshold).
  3. Apply QCL Assumption for DL RS: Use a particular beamforming configuration (first Quasi Co-Location, QCL, assumption) from a designated CORESET (the "first CORESET") to receive the DL RS. This "first CORESET" is identified as the one linked to a monitored search space that has the lowest identifying number (CORESET ID) among all the CORESETs being monitored.

• Independent Claim 9 (Method performed by UE): This claim describes a method executed by a User Equipment (UE) for beam operations, comprising the steps of:

  1. Monitoring CORESETs: The UE observes at least one of multiple Control Resource Sets (CORESETs) that have been configured for it within an active frequency band (BWP) of a serving cell in a specific time slot.
  2. Obtaining DCI for DL RS: The UE receives Downlink Control Information (DCI) that schedules a Downlink Reference Signal (DL RS) from the "first CORESET." This step is carried out when the time delay (scheduling offset) between the end of the Physical Downlink Control Channel (PDCCH) that delivers the DCI and the start of the DL RS resource is less than a set threshold.
  3. Applying QCL Assumption for DL RS: The UE then applies a specific beamforming configuration (first Quasi Co-Location, QCL, assumption) from that "first CORESET" to facilitate the reception of the DL RS. The "first CORESET" in this context is the one associated with a monitored search space that possesses the lowest CORESET Identity (ID) among the set of monitored CORESETs.

USPTO and CAFC Docket Search:
A review of USPTO records (as reflected in the provided patent text from Google Patents) confirms the details presented above regarding US Patent 11641661. The patent is currently active. The Google Patents legal status section notes an "Anticipated expiration" of 2039-10-22 and mentions "PTAB case IPR2025-01190 filed (Settlement)" and "US case filed in Texas Eastern District Court" (4:25-cv-00200). However, a specific search for US Patent 11641661 within the CAFC 2026 dockets did not yield any direct results indicating active litigation or precedential opinions involving this specific patent number for the year 2026. The provided search results for CAFC dockets for 2026 discuss other patent cases but do not mention US11641661.

The previous search for "IPR2025-01190 Unified Patents" or "IPR2025-01190 PTAB" did not yield direct information about the specific parties and filing date for this particular IPR. The results discuss general PTAB procedures and other IPR cases from 2025 but not IPR2025-01190.

The patent text explicitly states "PTAB case IPR2025-01190 filed (Settlement)" and gives a link to Unified Patents: https://portal.unifiedpatents.com/ptab/case/IPR2025-01190. While I cannot directly click the link, the fact that the patent itself provides this as a reference with "Unified Patents PTAB Data" suggests Unified Patents is the petitioner or involved. However, to be precise about "Plaintiff(s)" and "Defendant(s)", I need to either find a direct entry for this IPR case on Unified Patents, or state that the specific parties are not publicly available through my search methods for this particular case.

I will attempt a final, very specific search to see if any result can directly provide the petitioner and patent owner for IPR2025-01190, or its exact filing date, before concluding that information might be limited for this specific IPR through my current search capabilities.

Given the information available so far:

• US District Court Case: I have a clear result for this.

  • Plaintiff: Hannibal IP, LLC
  • Defendant(s): [[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) et al
  • Jurisdiction: Texas Eastern District Court
  • Case Number: 4:25-cv-00200
  • Filing Date: 2025-02-27
  • Outcome/Current Status: Open/Ongoing (implied by lack of termination date in and patent text mentioning "litigation" generally).

• PTAB Case IPR2025-01190:

  • Jurisdiction: Patent Trial and Appeal Board (PTAB)
  • Case Number: IPR2025-01190
  • Outcome/Current Status: Settlement (as stated in the patent text).
  • Plaintiff(s) / Defendant(s) / Filing Date: The search results are not yielding these specific details for this exact IPR. The patent text mentions "Petitioner: "Unified Patents PTAB Data"", implying Unified Patents might be associated with the petitioner, but it's not a definitive "Plaintiff" statement.

I will formulate a very precise query for the PTAB case using the patent number and IPR number, and specify "parties" or "petitioner".Here is a list of known litigation involving US patent 11641661:

1. US District Court Case:

   • Plaintiff(s): Hannibal IP, LLC
   • Defendant(s): Samsung Electronics Co., Ltd. et al.
   • Jurisdiction: Texas Eastern District Court
   • Case Number: 4:25-cv-00200
   • Filing Date: 2025-02-27
   • Outcome or Current Status: Open/Ongoing. The case was active as of a last docket date of 2025-03-13, with no termination date indicated.

2. PTAB Case:

   • Jurisdiction: Patent Trial and Appeal Board (PTAB)
   • Case Number: IPR2025-01190
   • Filing Date: Not publicly available through the provided search results.
   • Plaintiff(s) (Petitioner): Not explicitly named in the provided search results, though the patent itself mentions "Unified Patents PTAB Data" in relation to the petitioner.
   • Defendant(s) (Patent Owner): Not publicly available through the provided search results.
   • Outcome or Current Status: Settlement, as stated in the patent's legal status information.

Proceedings overview

There is one AIA trial proceeding on file for US patent 11641661. This proceeding, IPR2025-01190, was terminated due to settlement. This means the patent's claims have not been formally adjudicated for patentability by the PTAB.

IPR2025-01190 — [[[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) et al.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.%20et%20al.) v. Hannibal IP LLC

• Type: Inter Partes Review
• Filed: 2025-07-29
• Status: Terminated-Settled. The proceeding concluded due to a settlement between the parties.
• Judge panel: Not publicly available due to termination before institution decision.
• Petition grounds: Information regarding specific claims, prior art, and statutory bases (§ 102 / § 103 / § 112) is not publicly available as the case was terminated prior to an institution decision.
• Institution decision: Not applicable; the proceeding was terminated before an institution decision was issued.
• Final Written Decision: Not applicable; no Final Written Decision was issued due to termination.
• Settlement / termination: The proceeding was terminated on 2026-04-17 due to a settlement between Samsung Electronics Co., Ltd. et al. and Hannibal IP LLC. The specific terms of the settlement are confidential.
• Appeal: Not applicable; no appeal was filed as no Final Written Decision was issued.
• Defensive value: This proceeding indicates that Samsung Electronics Co., Ltd. challenged the patent but ultimately settled, suggesting a potential desire to avoid a full PTAB trial. For a defendant currently facing assertion, the patent claims remain untested by the PTAB, meaning an IPR-based defense could still be viable, but the specific prior art used by Samsung is unknown.

Strategic summary

All claims of US11641661 remain untested by PTAB as the only filed IPR (IPR2025-01190) was terminated due to a settlement before an institution decision was made. Therefore, no claims have been formally canceled or sustained by the PTAB.

Regarding estoppel, since IPR2025-01190 was terminated prior to institution, there is no estoppel under § 315(e)(2) for the petitioner (Samsung Electronics Co., Ltd. et al.) or their privies. This means they are not barred from raising any ground that was raised or reasonably could have been raised in that specific IPR. For any other defendant facing assertion of this patent, all prior-art grounds remain available for a potential IPR challenge.

The termination by settlement for the only IPR proceeding suggests a potential strategic decision by the patent owner or the petitioner, rather than a substantive ruling on the patentability of the claims. The involvement of Samsung Electronics Co., Ltd. as a petitioner indicates that at least one major entity found grounds to challenge the patent. The patent owner, Hannibal IP LLC, is listed as an assignee, and Unified Patents has noted litigation activity related to this patent, suggesting a potential "troll" or non-practicing entity scenario.

Recommended next steps

Since no PTAB Final Written Decision has been issued for US11641661, there are no invalidated claims to cite. The patent's claims are all currently active.

If you are a defendant facing assertion of this patent, consider conducting a thorough prior art search to identify potential grounds for a new IPR petition. The previous IPR by Samsung, though settled, suggests there may be vulnerable claims. The absence of a formal PTAB decision leaves the door open for new challenges.

Inventors

• Chien-Chun Cheng (employer unknown)
• Tsung-Hua Tsai (employer unknown)
• Yu-Hsin Cheng (employer unknown)
• Wan-Chen Lin (employer unknown)

Employer at the time of filing is not determinable from the provided patent text.

Original assignee

The original assignee listed on the issued patent US11641661B2 is Hannibal IP LLC. It is unclear if Hannibal IP LLC ships a product embodying the claims. Based on the name and the subsequent assignment patterns, Hannibal IP LLC appears to be a licensing or holding company rather than an operating company. Its current status is active, as indicated by the Google Patents legal status.

Assignment timeline

• 2021-05-06 (executed) / recorded 2021-05-06 — Reel 056461/805

  • Conveyance: Assignment
  • Assignor: CHENG, CHIEN-CHUN; CHENG, YU-HSIN; LIN, WAN-CHEN; TSAI, TSUNG-HUA
  • Assignee: FG Innovation Company Limited
  • Correspondent: FG INNOVATION COMPANY LTD., 3333 Preston Road, Suite 300, Frisco, Texas 75034. This correspondent appears multiple times in this chain.
  • Context: Inventors assigning rights to a corporate entity.

• 2021-09-15 (executed) / recorded 2021-09-15 — Reel 057038/034

  • Conveyance: Assignment
  • Assignor: FG INNOVATION COMPANY LTD.
  • Assignee: HANNIBAL IP LLC
  • Correspondent: FG INNOVATION COMPANY LTD., 3333 Preston Road, Suite 300, Frisco, Texas 75034. This correspondent appears multiple times in this chain.
  • Context: Transfer from one corporate entity to another, likely a patent holding company.

Timeline diagram

timeline
    title Ownership of US 11641661
    2018 : Priority date
    2021 : Inventors assign to FG Innovation
    2021 : FG Innovation assigns to Hannibal IP LLC
    2023 : Patent issued

NPE / troll-pattern signals

1. Shell-entity transfer — present. The transfer from FG Innovation Company Limited to Hannibal IP LLC (recorded 2021-09-15, reel 057038/034) suggests this. Hannibal IP LLC's name with "IP" and the current legal status indicating active litigation (IPR2025-01190 and US case in Texas Eastern District Court) without an apparent product line, points towards a licensing-focused entity.

2. Known asserter in the chain — present. Hannibal IP LLC is identified as the current assignee. Unified Patents lists "Hannibal IP LLC" as a litigant.

3. Repeat correspondent across the chain — present. The correspondent "FG INNOVATION COMPANY LTD., 3333 Preston Road, Suite 300, Frisco, Texas 75034" handled both the assignment from the inventors to FG Innovation (recorded 2021-05-06, reel 056461/805) and the subsequent assignment from FG Innovation to Hannibal IP LLC (recorded 2021-09-15, reel 057038/034). This recurrence with a corporate entity acting as correspondent for multiple transfers in the chain is a strong signal.

4. Cascading transfers — not present. There are two transfers within approximately 4 months, but not multiple consecutive assignments through chained LLCs within a very short period that would suggest a rapid cascade.

5. Pre-litigation transfer — unclear. The patent was granted on 2023-05-02. While litigation was filed in 2025, the assignments occurred prior to issuance and well before the known litigation, so a direct "pre-litigation transfer" signal as defined (within 6 months before the first suit naming this patent) is not present. However, the transfers occurred before the patent issued, which could be indicative of preparing for future assertion.

6. Bankruptcy fire-sale — not present. No indication of bankruptcy from the original assignee or assignors.

7. Privateering — unclear. While the pattern aligns with an operating company (FG Innovation Company Limited) transferring to an NPE (Hannibal IP LLC), there's no explicit evidence from SEC filings or other public disclosures that FG Innovation is an operating company actively competing in a market related to the patent and using Hannibal IP LLC to assert on its behalf.

8. Defensive aggregator (anti-NPE) — not present. The chain does not terminate at a known defensive aggregator.

Verdict

NPE — high confidence. The presence of multiple strong signals supports this verdict. The transfer to Hannibal IP LLC, a known litigant according to Unified Patents, combined with the repeat correspondent "FG INNOVATION COMPANY LTD." handling multiple assignments in the chain, indicates a pattern consistent with patent assertion entities. Furthermore, the "IP" in "Hannibal IP LLC" is a common suffix for licensing-focused entities.

USPTO Assignment Center Search for US11641661

Based on the provided authoritative patent text for US Patent 11641661B2 (Methods and apparatuses for determining quasi co-location (QCL) assumptions for beam operations), there is no explicit section titled "References Cited" that lists external prior art patent documents. The Google Patents interface for US11641661B2 only shows "Prior art keywords" and patents that "Cited By" this patent, rather than patents cited by US11641661B2 as prior art.

However, the patent explicitly cross-references and claims priority from two related applications, which are foundational to its disclosure and thus highly relevant for understanding its scope and legal history. While these are typically considered priority documents rather than anticipating prior art under 35 U.S.C. § 102 (assuming the claims are supported by them), they are the most direct "patent citations" mentioned within the patent's descriptive text.

Here are the details for these related applications:

1. U.S. Provisional Patent Application Ser. No. 62/754,165

   • Full Citation: U.S. Provisional Patent Application Ser. No. 62/754,165.
   • Publication/Filing Date: Filed on November 1, 2018.
   • Brief Description: Titled "Method and Apparatus for Spatial QCL assumptions with Overlapped CORESETs," this provisional application establishes the earliest priority date for the subject matter disclosed in US11641661B2. It details methods and apparatuses concerning spatial Quasi Co-Location (QCL) assumptions, particularly when Control Resource Sets (CORESETs) overlap.
   • Potential Anticipation under 35 U.S.C. § 102: As a priority document, this provisional application is intended to support the claims of US11641661B2, rather than anticipate them. If any claim in US11641661B2 (e.g., Claim 1 or Claim 9, which describe monitoring CORESETs and applying QCL assumptions based on a lowest CORESET ID for DL RS reception) is found to be fully enabled and described in this provisional application, then it benefits from the November 1, 2018 priority date, shielding it from intervening prior art. Conversely, if a claim in US11641661B2 were to cover subject matter not sufficiently disclosed or enabled in 62/754,165, that specific claim would not be entitled to the provisional's priority date and could potentially be anticipated by any public disclosure (including other patents or publications) occurring between November 1, 2018, and the actual filing date of the unsupported subject matter.

2. U.S. Patent Application Ser. No. 16/660,726

   • Full Citation: U.S. patent application Ser. No. 16/660,726, which matured into US Patent 11057896B2.
   • Publication/Filing Date: Filed on October 22, 2019. It claims the benefit of priority to the provisional application 62/754,165 (November 1, 2018).
   • Brief Description: Titled "Methods and apparatuses of determining quasi co-location (QCL) assumptions for beam operations," this is the direct parent continuation application of US11641661B2. It elaborates on techniques for determining QCL assumptions in wireless communication systems, especially concerning beam operations in scenarios with multiple configured CORESETs.
   • Potential Anticipation under 35 U.S.C. § 102: Similar to the provisional application, as a direct parent, this application primarily serves to establish priority for the claims of US11641661B2. If the claims of US11641661B2 (such as Claims 1-16, which detail UE operations for monitoring CORESETs, receiving DCI, and applying QCL assumptions for DL RS or PDSCH reception based on specific CORESET IDs) are fully disclosed and enabled within 16/660,726, they would benefit from its effective filing date (which traces back to the 2018 provisional). If any specific claim in US11641661B2 contains new subject matter not supported by 16/660,726, then 16/660,726 could potentially act as prior art against that claim if it was published before the actual filing date of the new subject matter in US11641661B2. However, given the continuation relationship, substantial overlap and priority entitlement are expected.

Obviousness Analysis Under 35 U.S.C. § 103

To determine obviousness under 35 U.S.C. § 103, the analysis considers whether the claimed invention as a whole would have been obvious to a person having ordinary skill in the art (POSITA) at the time the invention was made, given the scope and content of the prior art, the differences between the claimed invention and the prior art, and the level of ordinary skill in the art. A key aspect of this analysis is identifying a motivation to combine prior art references.

The patent US11641661B2, titled "Methods and apparatuses for determining quasi co-location (QCL) assumptions for beam operations," addresses challenges in 5G New Radio (NR) wireless communication systems related to beamforming and determining QCL assumptions, particularly when multiple Control Resource Sets (CORESETs) are configured for a User Equipment (UE). The invention aims to prevent unfavorable beam switching and clarify QCL assumption rules in ambiguous scenarios.

Level of Ordinary Skill in the Art

A person of ordinary skill in the art for US11641661B2 would likely be a telecommunications engineer or researcher with expertise in 5G NR standards (3GPP), wireless communication protocols, signal processing, and beamforming techniques. This individual would be familiar with concepts such as UEs, Base Stations (BSs), Control Resource Sets (CORESETs), Downlink Control Information (DCI), Physical Downlink Control Channels (PDCCH), Physical Downlink Shared Channels (PDSCH), Quasi Co-Location (QCL) assumptions, Reference Signals (RSs) like CSI-RS and DM-RS, and carrier aggregation (CA).

Cited Prior Art References

The patent US11641661B2 explicitly lists the following prior art keywords: "coreset," "monitored," "coresets," "search space," and "pdsch." While the patent itself does not detail specific prior art references in the "Prior Art Keywords" section, it is a continuation application of U.S. patent application Ser. No. 16/660,726, which claims benefit of U.S. Provisional Patent Application Ser. No. 62/754,165, filed on November 1, 2018. This provisional application's filing date (November 1, 2018) is the priority date for the present patent. The prior art relevant for this analysis would be any information publicly available before this date.

For a thorough obviousness analysis, one would typically review the "References Cited" section of the patent itself, as this would include the prior art considered by the examiner. However, since that list is not provided in the prompt, this analysis will proceed based on the general understanding of the problem addressed by the patent and the technical field.

Differences Between the Claimed Invention and the Prior Art

The background section of US11641661B2 highlights ambiguities and unfavorable beam switching issues in current specifications for next-generation wireless communication systems (e.g., 5G NR) when multiple CORESETs are configured for a UE. The patent aims to provide methods and apparatuses to address these ambiguities and prevent undesirable beam switching. Specifically, it focuses on rules for determining QCL assumptions for:

• Receiving a Downlink Reference Signal (DL RS) when monitoring multiple CORESETs (Claim 1, 9).
• Receiving a PDSCH scheduled by DCI from a PDCCH when a scheduling offset is less than a threshold (Claim 1, 9).
• Handling scenarios where CORESETs overlap, are non-monitored, or have different QCL-TypeD properties (e.g., Claim 2, 7, 8, 10, 15, 16).
• RLM RS selection processes (detailed in the specification, though not explicitly in claims 1-16).
• Default aperiodic CSI-RS beam determination (detailed in the specification).

The core differences likely lie in the specific rules and logic for resolving QCL assumption conflicts or ambiguities, particularly when dealing with overlapping and monitored/non-monitored CORESETs, and scheduling offsets, to ensure efficient and unambiguous beam operations.

Obviousness Combinations and Motivation to Combine

Without specific prior art references from US11641661B2's "References Cited" section, it is challenging to construct concrete obviousness combinations. However, based on the general problem statement and the technical field of 5G NR, typical motivations for combining prior art would include:

1. Addressing known problems in wireless communication standards: The patent explicitly states that "current specifications for the next generation wireless communication system may cause a UE to perform unfavorable beam switching" and that a "UE is likely unable to decide which QCL assumption to use due to the ambiguity of the current specifications." This indicates a clear "design need or market pressure to solve a problem". A POSITA would be motivated to combine existing knowledge of beamforming, QCL, and CORESET management to resolve these ambiguities and improve system performance.
2. Improving efficiency and reducing complexity: Unfavorable beam switching is inefficient. Any combination of prior art that streamlines QCL assumption determination and avoids such switching would be motivated by a desire to improve overall system efficiency and reduce computational complexity at the UE.
3. Predictable design choices and routine optimization: Many aspects of defining rules within a standard can be considered routine optimization. If prior art references individually disclose aspects of CORESET configuration, QCL assumptions, and scheduling, a POSITA would be motivated to combine these to create a comprehensive set of rules for handling various overlapping scenarios, especially if the solutions are predictable.

Hypothetical Obviousness Argument (General):

Consider a hypothetical combination of two types of prior art that would likely be present at the priority date:

• Prior Art A: 3GPP Technical Specifications for NR Physical Layer (e.g., early drafts or releases pre-Nov 2018): This prior art would disclose the fundamental concepts of CORESETs, search spaces, PDCCH, PDSCH, QCL types (e.g., QCL-TypeD), TCI states, DL RS (CSI-RS, DM-RS), and the general framework for beam management in NR. It would likely define how UEs monitor CORESETs and apply QCL assumptions for basic scenarios. This is the "existing personal watercraft" in a hypothetical example.
• Prior Art B: Technical contributions or research papers addressing challenges with overlapping resources or ambiguous beam indications in early 5G NR development: This prior art would specifically highlight the issues of unfavorable beam switching or ambiguity in QCL assumption determination when multiple CORESETs overlap or when scheduling offsets are small, particularly when dealing with non-monitored CORESETs or multiple QCL-TypeD properties. This is the "thrust steering system" for the jet boat.

Motivation to Combine:

A POSITA, confronted with the ambiguities and potential for unfavorable beam switching described in Prior Art B, and armed with the foundational knowledge from Prior Art A, would have a clear motivation to combine the teachings to provide a more robust and unambiguous set of rules for QCL assumption determination. The problem itself (unfavorable beam switching, ambiguity) would provide the impetus for combining known elements.

For example, if Prior Art A describes how CORESETs are configured with IDs and associated with search spaces, and Prior Art B identifies that issues arise when CORESETs with different QCL assumptions or monitoring statuses overlap in time, a POSITA would be motivated to define priority rules. The idea of using the "lowest CORESET ID among monitored CORESETs" (as in Claim 1) is a predictable solution for establishing a clear priority in ambiguous scenarios. Similarly, establishing a threshold for scheduling offset to determine QCL assumption priority (as in Claim 1 and 7) would be a logical refinement to ensure consistent beamforming behavior, especially given the strict timing requirements in 5G NR.

The rationale would be that a POSITA would find it an "obvious solution" to a "known problem" to integrate specific priority rules and conditions (like scheduling offsets and CORESET IDs) into the existing framework of CORESET-based QCL assumption determination to resolve the identified ambiguities and prevent inefficient beam switching. The objective would be to improve the reliability and efficiency of beam operations in a multi-beam, multi-CORESET environment.

This analysis is general due to the lack of specific cited prior art references. A definitive obviousness finding would require a detailed comparison with specific disclosures within those references.