`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`INTELLECTUAL VENTURES MANAGEMENT, LLC
`Petitioner
`
`V.
`
`XILINX, INC.
`Patent Owner
`
`Case IPR2012-00018
`
`Patent 7,566,960
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`PETITIOE‘IER’S OPPOSITION TO PATENT GWNERE’S
`
`SECOND SUBSTITUTE MOTION TO AMEND
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`
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`TAELE OF CONTENTS
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`I.
`
`Statement of Relief Requested .......................................................................... 1
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`11. Overview ........................................................................................................... 1
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`III. Patent Owner’s Second Substitute Motion to Amend Goes Far Beyond “the
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`Sole Purpose of Complying with the Idle Free Decision” ................................ 2
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`IV. Substitute Claims 14-21 Should Be Rejected Under 35 U.S.C. § 112 ............. 4
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`V. Substitute Claims 14-26 Are Unpatentable ....................................................... 5
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`A. Alexander Discloses the New Limitations in Substitute Claims 14 and
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`22 ................................................................................................................ 5
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`1. Alexander Pre-Dates the ‘960 Patent ........................................................ 5
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`2. New Matter from Proposed Claim Amendments Is Identical to Alexander
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`6
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`3.
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`Ground 10: Substitute Claims 14—18, 20-24 and 26 Are Obvious Under
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`35 § U.S.C. 103 Based on Chakravorty ‘362, Siniaguine, and Alexander ........ 7
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`4.
`
`Ground 11: Substitute Claims 19 and 25 Are Obvious Under 35 U.S.C. §
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`103 Based on Chakravorty ‘362, Siniaguine, Alexander, and Patel .................. 8
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`5.
`
`Ground 12: Substitute Claims 14-18, 20-24, and 26 Are Obvious Under
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`35 § U.S.C. 103 Based on Siniaguine, Ma, Chakravorty ‘3 62, and Alexander. 8
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`6.
`
`Ground 13: Substitute Claims 19 and 25 Are Obvious Under 35 U.S.C. §
`
`103 Based on Siniaguine, Ma, Chakravorty ‘362, Alexander, and Patel .......... 9
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`B. Pasco and Bellaar Disclose the New Limitations in Substitute Claims
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`14 and 22 ................................................................................................... 10
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`IPR2012-00018
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`Patent 7,566,960
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`1.
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`Pasco and Bellaar Pre-Date the ‘960 Patent ............................................ 10
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`2.
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`Pasco and Bellaar Disclose the New Matter from the Proposed Claim
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`Amendments ..................................................................................................... 1 0
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`3.
`
`Ground 14: Substitute Claims 14-18, 20-24, and 26 Are Obvious Under
`
`35 U.S.C. § 103 Based on Chakravorty ‘362, Siniaguine, Pasco, and Bellaar 12
`
`4.
`
`Ground 15: Substitute Claims 19 and 25 Are Obvious Under 35 U.S.C. §
`
`103 Based on Chakravorty ‘362, Siniaguine, Pasco, Bellaar, and Patel .......... 13
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`5.
`
`Ground 16: Substitute Claims 14-18, 20-24, and 26 Are Obvious Under
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`35 § U.S.C. 103 Based on Siniaguine, Ma, Chakravorty ‘362, Pasco, and
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`Bellaar .............................................................................................................. l4
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`6.
`
`Ground 17: Substitute Claims 19 and 25 Are Obvious Under 35 U.S.C. §
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`103 Based on Siniaguine, Ma, Chakravorty ‘362, Pasco, Bellaar, and Patel .. 15
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`VI. Conclusion ....................................................................................................... 15
`
`ii
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`
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`1.
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`Statement of Relief Requested
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`Petitioner opposes Patent Owner’s Second Substitute Motion to Amend for
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`the reasons set forth in its Petition (Paper 6), in its Reply to Patent Owner
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`Response, and below.
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`11.
`
`Overview
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`Patent Owner attempts to circumvent the Board’s Order of July 24, 2013
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`(“Board’s Order”; Paper 24) in the submission of its Second Substitute Motion to
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`Amend (Paper 26). The Board permitted Patent Owner to submit the Second
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`Substitute Motion to Amend for “the sole purpose of complying with the Idle Free
`
`decision.” Paper 24. But Patent Owner’s submission goes far beyond What was
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`permitted by the Board’s Order.
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`Even assuming that Patent Owner’s Second Substitute Motion to Amend did
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`not violate the Board’s Order, the proposed amendments do not provide any
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`patentable subject matter. Specifically, the proposed amendments include subject
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`matter that is identical to the subject matter disclosed in the Alexander prior art
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`reference. Additionally, the Pasco and Bellaar prior art references disclose the new
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`matter from the substitute claims. Thus, based on at least the prior art presented in
`
`the Petition, and the art identified herein, substitute claims 14—26 are not
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`patentable.
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`IPR2012-00018
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`Patent 7,566,960
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`111. Patent Owner’s Second Substitute Motion to Amend Goes Far Beyend
`“the Sole Purpose of Compiying with the Idle Free Becision”
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`Patent Owner’s original Motion to Amend lacked a claim listing, thus
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`circumventing the page limit. See Paper 20. Patent Owner then submitted a
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`Substitute Motion to Amend to cure this deficiency. See Paper 22. Patent Owner
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`then sought the Board’s permission to file yet another Substitute Motion to Amend
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`to comply with the Idle Free decision. The Board granted the Patent Owner
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`permission to submit a Second Substitute Motion to Amend for the very limited
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`and “sole purpose of complying with the Idle Free decision.” Paper 24. Patent
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`Owner’s Second Substitute Motion to Amend goes far beyond what was needed to
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`comply with the Idle Free decision. As such, the Motion should be denied.
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`Moreover, given that the Patent Owner has had three attempts to submit a proper
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`Motion to Amend, no further Motions or accommodations should be permitted.
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`Rather than simply provide a second substitute motion to comply with the
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`Idle Free decision, Patent Owner inappropriately seeks to dramatically revise and
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`correct numerous problems with its ill-formed Substitute Motion to Amend. For
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`example, Patent Owner impermissibly uses the Second Substitute Motion to
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`Amend as a vehicle to correct numerous 35 U.S.C. § 112 issues present in its
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`Substitute Motion to Amend. For example, in the claim listing from Patent
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`Owner’s Substitute Motion to Amend, claim 19 recites “wherein at least one of the
`
`interposing structure structares comprises an AC load structure to match a
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`
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`IPR2012-00018
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`Patent 7,566,960
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`characteristic impedance includes a layer comprising epoxy and fiberglass.” Paper
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`22. The meaning of this limitation is unascertainable and thus suffers from section
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`112 written description issues. Dr. Neikirk, Patent Owner’s technical expert,
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`confirms this. See IVM 1013, p. 41, 11. 2-11 (noting that “there’s a grammatical
`
`problem here”). The other substitute claims—claims 14-18 and 20-26—in the
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`claim listing from Patent Owner’s Substitute Motion to Amend suffer from similar
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`deficiencies.
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`Additionally, the Patent Owner attempts to remove numerous limitations
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`that were added in the Substitute Motion to Amend. For example, claim 14 of the
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`Substitute Motion to Amend included the limitation of: “at least one of the
`
`intemoser interposing structures electrically coupling a respective first micro—bump
`
`in a first position in the array of micro-bumps to a respective first landing pad...”
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`In the Second Substitute Motion of Amend, the Patent Owner removes these added
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`limitations, such that the element reads as: “the interposer electrically coupling a
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`first micro-bump in a first position in the array of micro—bumps to a first landing
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`pad ....” Removal of limitations was not necessary for the “sole purpose of
`
`complying with the Idle Free decision.” Rather than amend the claims for the “sole
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`purpose of complying with the Idle Free decision,” Patent Owner attempts to
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`correct poorly-constructed claim amendments that are fraught with limitations
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`having unclear meanings and 35 U.S.C. § 112 issues.
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`IPR2012-00018
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`Patent 7,566,960
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`Patent Owner also adds limitations in the claims from the Second Substitute
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`Motion to Amend. For example, in the Substitute Motion to Amend, claim 14
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`includes “a plurality of tiled interposing structure structures.” See Paper 22, p. 1. In
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`the Second Substitute Motion to Amend, claim 14 not only includes “a plurality of
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`tiled interposing structures” but also “the plurality of tiled interposing structures
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`being held together using an elastomer.” See Paper 26, p. 3. Similar modifications
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`were made to claim 22. In adding the “elastomer” limitation to claims 14 and 22,
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`Patent Owner impermissibly takes another opportunity to amend its claims.
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`The Board’s Order did not permit Patent Owner to make the type of claim
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`amendments discussed above. See Paper 24. Patent Owner has been given three
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`opportunities to file a complaint Motion to Amend. But, since each of these
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`Motions is deficiencient, Patent Owner’s Motions to Amend should be denied.
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`IV.
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`Substitute Claims 14-21 Should Be Rejected Under 35 U.S.C. § 112
`
`Claim 14 from Patent Owner’s Second Substitute Motion to Amend recites:
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`an interposing structure
`
`comprising a plurality of tiled
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`interposing structures disposed inside the integrated circuit
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`package between the integrated circuit die and the inside
`
`surface of the integrated circuit package, the plurality of tiled
`
`interposing structures being held together using an elastomer,
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`the interposer electrically coupling a first micro-bump in a first
`
`position in the array of micro-bumps to a first landing pad
`
`located opposite to the first position and to a second landing
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`IPR2012-00018
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`Patent 7,566,960
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`pads in the array of landing pads.
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`Emphasis added.
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`The term “the interposer” lacks antecedent basis and it is unclear what it refers
`
`to—e.g., does it refer to the “interposing structure,” the “plurality of tiled
`
`interposing structures,” or maybe one of the “plurality of tiled interposing
`
`structures?
`
`Substitute claim 14 should therefore be rejected based on at least 35 U.S.C.
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`§ 112, second paragraph, due to indefiniteness and lack of clarity. Based on their
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`dependencies from claim 14, substitute claims 15-21 should also be rejected.
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`V.
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`Substitute Clairns 14-26 Are Unpatentable
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`IVM provides below eight new grounds of rej ection under 35 U.S.C. § 103
`
`for substitute claims 14—26. These grounds of rejections include Chakravorty ‘3 62
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`(IVM 1009) and Siniaguine (IVM 1003) as primary references and the following
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`secondary references: Alexander (IVM 1017), Patel (IVM 1004), Ma (IVM 1008),
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`Pasco (IVM 1018, and Bellaar (IVM 1019).
`
`A.
`
`Alexander Biscioses the New Limitations in Substitute Claines 14 and 22
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`1.
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`Alexander i’re-Dates the ‘950 Patent
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`US. Patent No. 6,891,258 to Alexander et al. was filed on December 6,
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`2002, prior to the filing date of the ‘960 patent (“Alexander”; IVM 1016).
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`Alexander also has a different inventive entity than the ‘960 patent. Alexander thus
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`IPR2012-00018
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`Patent 7,566,960
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`qualifies as prior art under 35 U.S.C. § 102(e).1
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`2.
`
`New Matter from Froposed Claim Amendments Is Identical to
`Alexander
`
`a)
`
`Alexander Discloses “a Plurality of Tiled interposing Structures”
`
`In support of the “interposing structure comprising a plurality of tiled
`
`interposing structures disposed inside the integrated circuit package between the
`
`integrated circuit die and the inside surface of the integrated circuit package”
`
`limitation, Patent Owner points to paragraphs [0081] and [0082] from the
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`originally-filed ‘960 patent specification and FIG. 8. See Paper 26, pp. 7-8.
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`Paragraphs [0081] and [(7082] are identical to column 8, lines 12-27 in Alexander.
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`1 Alexander is assigned to Xilinx, lists a common inventor as the ‘968
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`patent, and has the term “interposer” in its title. See IVM 1020. Thus, Patent
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`Owner’s allegation that it “is not aware of any circuit die assembly prior art that
`
`discloses an interposer comprising ‘a plurality of tiled interposing structures,’ nor
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`is the Patent Owner aware of any circuit die assembly prior art that discloses a
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`‘plurality of tiled interposing structures being held together using an
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`elastomer”’(Paper 24, pp. 14-15) fails to satisfy Idle Free because it does not
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`include a representation about the “specific technical disclosure” of Alexander, and
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`further because it is an unsupported, conclusory allegation. Idle Free Systems, Inc.
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`v. Bergstrom, Inc., Case IPR2012-00027, Paper 26 (June 11, 2013), p. 7.
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`Patent 7,566,960
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`FIG. 8 from the ‘960 patent is also identical to FIG. 8 from Alexander. Indeed, Dr.
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`Neikirk confirms that “looking at the ‘960 [patent], there is a Figure 8, and it is
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`certainly very similar, if not the same [as Figure 8 from Alexander].” IVM 1013, p.
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`32, 11. 22-24. Alexander therefore discloses the “plurality of tiled interposer
`
`structures” limitation.
`
`b)
`
`Alexander Discloses “the Plurality of Tiled Interposing Structures Being
`Held Together Using an Elastomer”
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`In support of the “plurality of tiled interposing structures being held together
`
`using an elastomer” limitation, Patent Owner points to paragraph [0082] from the
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`originally-filed ‘960 patent specification. See Paper 26, pp. 8-9. Paragraph [0082]
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`is identical to column 8, lines 19-27 in Alexander. Indeed, in reference to the
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`elastomer disclosure in Alexander, Dr. Neikirk confirms that the elastomer from
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`Alexander “seem[s] to be the added elements” from Patent Owner’s claim
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`amendments. IVM 1013, p. 35, 11. 6-7.
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`3.
`
`Ground 10: Substitute CEaims 14-18, 28-24 and 26 Are {)bvious Under
`35 § U.S.C. 103 Based on Cfiakravorty ‘362, Siniaguine, and Alexander
`
`For similar reasons set forth in the Petition and Petitioner’s Reply to Patent
`
`Owner Response, Chakravorty ‘362 and Siniaguine disclose each and every
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`limitation of substitute claims 14—18, 20—24, and 26. See Paper 6, pp. 28-36. To the
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`extent that Chakravorty ‘362 or Siniaguine do not disclose an “interposing
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`structure comprising a plurality of tiled interposing structures disposed inside the
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`
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`Patent 7,566,960
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`integrated circuit package between the integrated circuit die and the inside surface
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`of the integrated circuit package” or a “plurality of tiled interposing structures
`
`being held together using an elastomer,” Alexander discloses these limitations—as
`
`discussed above.
`
`A person of ordinary skill in the art would combine the teachings of
`
`Chakravorty ‘362, Siniaguine, and Alexander. See IVM 1012, W 21-25. For
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`example, interposer 310 in FIG. 3 of Chakravorty ‘3 62 can be modified to have a
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`plurality of tiled interposing structures—like FIG. 8 of Alexander—to mitigate for
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`the effects of thermal expansion and/or contraction in interposer 310. See id The
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`tiled interposing structures can be held together using an elastomer. See id. This
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`modification would have been nothing more than a mere design choice that would
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`yield predictable results. See id.
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`4.
`
`Ground 11: SuEstétuEe Claims 19 and 25 Are Obvious Under 35 U.S.C. §
`103 Based on Chakravorty ‘362, Siniaguine, Alexander, and Patel
`
`For similar reasons set forth in the Petition, Patel discloses the limitations in
`
`substitute claims 19 and 25. See Paper 6, pp. 36—37. For similar reasons set forth in
`
`the Petition, a person of ordinary skill in the art would combine the teachings of
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`Chakravorty ‘362, Siniaguine, Alexander and Patel. See IVM 1012, {I 44.
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`5.
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`Grouaed 12: Substitute Claims 14-18, 20-24, and 26 Are Obvious Under
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`35 § ELSE. 103 Based on Siniaguine, ’ a, Chakravorty ‘362, and
`Alexander
`
`For similar reasons set forth in the Petition and Petitioner’s Reply to Patent
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`
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`IPR2012-00018
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`Patent 7,566,960
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`Owner Response, Siniaguine, Ma and Chakravorty ‘362 disclose each and every
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`limitation of substitute claims 14-18, 20—24, and 26. See Paper 6, pp. 38-49. To the
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`extent that Siniaguine, Ma or Chakravorty ‘362 do not disclose an “interposing
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`structure comprising a plurality of tiled interposing structures disposed inside the
`
`integrated circuit package between the integrated circuit die and the inside surface
`
`of the integrated circuit package” or a “plurality of tiled interposing structures
`
`being held together using an elastomer,” Alexander discloses these limitations—as
`
`discussed above.
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`A person of ordinary skill in the art would combine the teachings of
`
`Siniaguine, Ma, Chakravorty ‘362, and Alexander. See IVM 1012, {If 30-33. For
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`example, IC 320 in FIG. 4 of Siniaguine can be modified to have a plurality of
`
`tiled interposing structures—like FIG. 8 of Alexander—to mitigate for the effects
`
`of thermal expansion and/or contraction in interposer 310. See id. The tiled
`
`interposing structures can be held together using an elastomer. See id. This
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`modification would have been nothing more than a mere design choice that would
`
`yield predictable results. See id.
`
`6.
`
`Ground 13: Substitute Claims 19 and 25 Are {)bvious Under 35 USE. §
`103 Based 0:1 Siniaguine, Ma, Chakravorty ‘362, Alexander, and Patel
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`For similar reasons set forth in the Petition, Patel discloses the limitations in
`
`substitute claims 19 and 25. See Paper 6, pp. 50-51. Also, for similar reasons set
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`forth in the Petition, a person of ordinary skill in the art would combine the
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`IPR2012-00018
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`Patent 7,566,960
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`teachings of Siniaguine, Ma, Chakravorty ‘3 62, Alexander, and Patel. See IVM
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`1012, fi 45.
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`B.
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`Pasco and Bellaar Disclose the New Limitations in Substitute Ciaims 14
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`and 22
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`1.
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`Pasco and Bellaar Pre-Date the ‘960 Patefit
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`U.S. Patent No. 6,319,829 to Pasco et al. was issued on November 20, 2001,
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`well over one year prior to the filing date of the ‘960 patent (“Pasco”; IVM 1017).
`
`U.S. Patent No. 6,002,168 to Bellaar et al., titled “Microelectronic Component
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`with Rigid Interposer,” was issued on December 14, 1999, well over one year prior
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`to the filing date of the ‘960 patent (“‘Bellaar”; IVM 1018). Both Pasco and Bellaar
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`qualify as prior art under at least 35 U.S.C. § 102(b).
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`2.
`
`Pasco and Bellaar Disclose the
`Amendments
`
`ew Matter from the Proposed Claim
`
`a)
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`Pasco Biscloses “a Pluralit'y of Tiled Iéterposing Structures”
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`In reference to FIG. 4 (reproduced below), Pasco discloses a segmented
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`interposer 48 with a plurality of equal—sized interposers 20 arranged in a planar
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`manner above a printed circuit board (PCB) 50. See IVM 1012, fi 37. Segmented
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`interposer 48 provides interconnections between a substrate 44 (e. g., part of a
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`multichip module 40) and PCB 50 using solder balls 46. See id. Segmented
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`interposer 48 mitigates stresses on solder balls 46 due to the effects of different
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`thermal coefficients of expansion (TCE). See id. Interposers 20 can be considered
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`“tiled interposing structures” since they are the same structure (e. g., as understood
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`10
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`by the common nomenclature “20” used for each of the three structures) that can
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`be arranged in a side-by-side pattern (as illustrated in FIG. 4). This is consistent
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`with Dr. Neikirk’s interpretation of the term “tiled interposing structures.” See
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`XLNX 2008, p. 6 (“One of ordinary skill in the art would interpret ‘tiled
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`interposing structures’ to refer to a regular pattern of side by side interposing
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`structures”).
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`
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`FIG. 4 of Pasco
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`b)
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`Bellaar Discloses Interposing Structures “Being Held Together Using an
`Elasfomer”
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`Bellaar discloses that a plurality of interposing structures can be held
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`together using an elastomer. See IVM 1012, ‘l 38. For example, Bellaar discloses
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`an elastomer that can be used to control spacing/separation between interposers.
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`See id. Bellaar uses the elastomer to create a compliant layer, or compliant spacer,
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`between a rigid interposer and a flexible interposer. See id. The elastomer can be
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`used to compensate for mismatches in the coefficient of thermal expansion
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`between a chip and the rigid interposer and/or between the rigid interposer and the
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`flexible interposer. See id.
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`11
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`c)
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`Combination of Pasco and Bellaar Is Proper
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`A person of ordinary skill in the art would combine the teachings of Pasco
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`and Bellaar. See IVM 1012, '11 39. For example, the elastomer of Bellaar can be
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`used to hold together interposers 20 in segmented interposer 48 of Pasco. See id. In
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`referring to FIG. 4 of Pasco, substrate 44 and PCB 50 can be manufactured from
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`materials different from interposers 20, thus having a different coefficient of
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`thermal expansion than interposers 20. See id. The elastomer of Bellaar can be
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`used to control the spacing/separation between interposers 20—e.g., lateral shifts
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`in solder balls 46—relative to substrate 44 and PCB 50 under various thermal
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`conditions. See id. For ease of explanation, the combination of the segmented
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`interposer of Pasco with the elastomer of Bellaar (holding interposers 20 together)
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`will be referred to herein as “the modified segmented interposer of Pasco/Bellaar.”
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`This modification would have been nothing more than a mere design choice that
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`would yield predictable results. See id.
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`3.
`
`Ground 14: Substitute Claims 14-18, 20-24, and 26 AFC vaious Under
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`35 U.S.C. § 163 Based on Chakravorty ‘362, Siniaguine, Pasco, and
`Bellaar
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`For similar reasons set forth in the Petition and Petitioner’s Reply to Patent
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`Owner Response, Chakravorty ‘362 and Siniaguine disclose each and every
`
`limitation of substitute claims 14-18, 20—24, and 26. See Paper 6, pp. 28—36. To the
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`extent that Chakravorty ‘362 or Siniaguine do not disclose an “interposing
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`12
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`Patent 7,566,960
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`structure comprising a plurality of tiled interposing structures disposed inside the
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`integrated circuit package between the integrated circuit die and the inside surface
`
`of the integrated circuit package” or a “plurality of tiled interposing structures
`
`being held together using an elastomer,” the modified segmented interposer of
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`Pasco/Bellaar discloses these limitations—as discussed above.
`
`A person of ordinary skill in the art would combine the teachings of
`
`Chakravorty ‘362, Siniaguine, Pasco, and Bellaar. See IVM 1012, W 40-41. For
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`example, interposer 310 in FIG. 3 of Chakravorty ‘362 can be modified to
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`implement the features of the modified segmented interposer of Pasco/Bellaar to
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`mitigate the stress on solder balls 301 and 311 due to the effects of different
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`thermal coefficients of expansion. See id. For example, the modified segmented
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`interposer of Pasco/Bellaar can compensate for mismatches in the coefficient of
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`thermal expansion between IC die 300 and the modified segmented interposer and
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`between the modified segmented interposer and primary substrate 320. See id. This
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`modification would have been nothing more than a mere design choice that would
`
`yield predictable results. See id.
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`4.
`
`Ground 15: Substitute Claims 19 and 25 Are vaious Under 35 U.S.C. §
`103 Based on Chakravorty ‘362, Siniaguine, Pascg, Bellaar, and Patel
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`For similar reasons set forth in the Petition, Patel discloses the limitations in
`
`substitute claims 19 and 25. See Paper 6, pp. 36-3 7. Also, for similar reasons set
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`forth in the Petition, a person of ordinary skill in the art would combine the
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`13
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`IPR2012-00018
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`Patent 7,566,960
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`teachings of Chakravorty ‘362, Siniaguine, Pasco, Bellaar, and Patel. See IVM
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`1012, f 44.
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`5.
`
`Ground 16: Subsiitute Claims 14-18, 20-24, and 26 Are {)bvious Under
`
`35 § U.S.C. 103 Based on Siniaguine, Ma, Chakravorty ‘362, Pasco, and
`Bellaar
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`For similar reasons set forth in the Petition and Petitioner’s Reply to Patent
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`Owner Response, Siniaguine, Ma, and Chakravorty ‘362 disclose each and every
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`limitation of substitute claims 14-18, 20-24, and 26. See Paper 6, pp. 38—49. To the
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`extent that Siniaguine, Ma or Chakravorty ‘362 do not disclose an “interposing
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`structure comprising a plurality of tiled interposing structures disposed inside the
`
`integrated circuit package between the integrated circuit die and the inside surface
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`of the integrated circuit package” or a “plurality of tiled interposing structures
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`being held together using an elastomer,” the modified segmented interposer of
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`Pasco/Bellaar discloses these limitations—as discussed above.
`
`A person of ordinary skill in the art would combine the teachings of
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`Siniaguine, Ma, Chakravorty ‘3 62, Pasco, and Bellaar. See IVM 1012, W 42-43.
`
`For example, IC 320 in FIG. 4 of Siniaguine can be modified to have a plurality of
`
`tiled interposing structures—like FIG. 8 of Alexander—to implement the features
`
`of the modified segmented interposer of Pasco/Bellaar to compensate for
`
`mismatches in the coefficient of thermal expansion between IC 310 and the
`
`modified segmented interposer and between the modified segmented interposer
`
`14
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`and wiring substrate 330. See id. This modification would have been nothing more
`
`than a mere design choice that would yield predictable results. See id.
`
`6.
`
`Ground 17: Substitute Claims 19 and 25 Are Obvious Under 35 U.S.C. §
`103 Based on Siniaguine, Ma, Chakravorty ‘362, Pasco, BeEEaar, arid
`Patel
`
`For similar reasons set forth in the Petition, Patel discloses the limitations in
`
`substitute claims 19 and 25. See Paper 6, pp. 50-51. Also, for similar reasons set
`
`forth in the Petition, a person of ordinary skill in the art would combine the
`
`teachings of Siniaguine, Ma, Chakravorty ‘362, Pasco, Bellaar and Patel. See IVM
`
`1012,1145.
`
`V1. Conclusion
`
`For the reasons set forth above, Patent Owner’s Motions to Amend should
`
`be denied.
`
`Respectfiilly submitted,
`
`Date: August 27, 2013
`
`K
`
`By-W
`
`Michael D. Specht, Lead Counsel (Reg. No. 54,463)
`Robert Greene Sterne, Backup Counsel
`
`STERNE, KESSLER, GOLDSTEIN 8; Fox P.L.L.C.
`1 100 New York Avenue, NW
`Washington, DC. 20005
`(202) 371-2600
`
`Attorneys for Petitioner
`Intellectual Ventures Alanagement, LLC
`
`15
`
`
`
`EXHiBIT LIST
`
`
`|
`
`Intellectual
`
`Ventures
`
`DESCRIPTION
`
`Management,
`
`
`
`1001
`US. Patent No. 7,566,960 to Conn
`
`1002
`
`Declaration of Morgan T. Johnson in Support of Petition for
`Inter Partes Review of U.S. Patent No. 7,566,960
`
`
`
`1003
`US. Patent No. 6,61 1,419 to Chakravorty
`
`
`
`1004
`US. Patent No. 6,730,540 to Siniaguine
`
`
`1005
`US. Patent No. 6,469,908 to Patel et a1.
`
`
`1006
`US. Patent No. 6,680,218 to Chung et al.
`
`
`1007
`US. Patent No. 6,970,362 to Chakravorty
`
`
`1008
`US. Patent No. 6,423,570 to Ma et a1.
`
`
`1009
`US. Patent Appl. Pub. No. 2002/0053728 to Isaak et a1.
`
`1010
`
`Curriculum Vitae of Morgan T. Johnson
`
`1011
`
`Declaration of Morgan T. Johnson in Support of Petitioner’s
`Reply to Patent Owner Response to Petition
`
`Declaration of Morgan T. Johnson in Support of Petitioner’s
`1012
`Opposition to Patth Owner’s Second Substitute Motion to
`
`Amend
`
`
`1013
`Deposition Transcript of Dr. Dean Neikirk
`
`
`
`
`
`
`
`1014
`
`Lau et al., Chip Scale Package: Design, Materials, Process,
`Reliability, and Applications, 19, McGraw—Hill, 1999
`
`
`The American Heritage Dictionary, 484, Houghton Mifflin
`Company, 1985 (1982)
`1015
`
`
`1016
`
`1017
`
`US. Patent No. 6,891,258 to Alexander et a1.
`
`
`US. Patent No. 6,319,829 to Pasco et al.
`
`
`1018
`US. Patent No. 6,602,168 to Bellaar et al.
`
`1019
`
`1020
`
`US. Patent and Trademark Office Assignment Record for US.
`Patent No. 6,891,258 to Alexander et a1.
`
`Updated Curriculum Vitae of Morgan T. Johnson
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 27th day of August 2013, a true and correct copy
`
`of the foregoing PETITIONER’S OPPOSITION TO PATENT OWNER’S
`
`SECOND SUBSTITUTE MOTION TO AMEND was served upon the following
`
`counsel for Patent Owner, Xilinx Inc.:
`
`David L. McCombs, Lead Counsel
`ATTN: IP DOCKETING
`
`HAYNES AND BOONE, LLP
`
`2323 Victory Avenue, Suite 700
`Dallas, TX 75219
`
`
`david.mccombs@haynesboone.com
`
`Thomas B. King
`HAYNES AND BOONE, LLP
`
`18100 Von Karman, Suite 750
`
`Irvine, CA 92612
`
`
`thomas.king@haynesboone.com
`
`mil/Ow
`
`
`
`Michael D. Specht, Lead Counsel (Reg. No. 54,463)
`
`STERNE, KESSLER, GOLDSTE‘IN & Fox P.L.L.C.
`
`1 100 New York Avenue, NW
`Washington, DC. 20005
`(202) 371-2600
`
`Attorney for Petitioner
`Intellectual Ventures Management LLC
`
`