UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Paper No.
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`INTELLECTUAL VENTURES MANAGEMENT, LLC
`
`Petitioner
`
`V.
`
`XILINX, INC.
`Patent Owner
`
`Case IPR2012-00023
`
`Patent 7,994,609
`
`Issue Date: August 9, 2011
`Title: SHIELDING FOR INTEGRATED CAPACITORS
`
`Before Sally C. Medley, Karl D. Easthom, and Justin T. Arbes
`Administrative Patent Judges
`
`PATENT OWNER’S FIRST MOTION TO AMEND
`
`BY XILINX UNDER 37 C.F.R. § 42.121
`
`
`
`Paper No.
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`INTELLECTUAL VENTURES MANAGEMENT, LLC
`
`Petitioner
`
`V.
`
`XILINX, INC.
`Patent Owner
`
`Case IPR2012-00023
`
`Patent 7,994,609
`
`Issue Date: August 9, 2011
`Title: SHIELDING FOR INTEGRATED CAPACITORS
`
`Before Sally C. Medley, Karl D. Easthom, and Justin T. Arbes
`Administrative Patent Judges
`
`PATENT OWNER’S FIRST MOTION TO AMEND
`
`BY XILINX UNDER 37 C.F.R. § 42.121
`
`
`
`IPR20l2—00023
`
`Patent Owner’s First Motion to Amend
`
`Xilinx provides this paper concurrently with its Response in the above-listed
`
`IPR. This paper includes the following:
`
`0 A proposed new claim listing is provided at page 2 of this paper.
`
`0 A discussion of the proposed changes is provided at page 11 of this paper.
`
`0 A description of the support for the proposed claims is provided at page 12
`
`of this paper.
`
`0 A description of patentably distinct features for the proposed claims is
`
`provided at page 15 of this paper.
`
`
`
`Patent Owner’s First Motion to Amend
`
`lPR20l2~0OO23
`
`1.
`
`Claim Listing
`
`Xilinx proposes the following listing of claims:
`
`1-17 (Cancelled)
`
`18. (Original) A capacitor in an integrated circuit ("IC") comprising:
`
`a first plate formed in a first conductive layer of the 1C;
`
`a second plate formed in a substrate of the 1C;
`
`a gate dielectric layer disposed between the first plate and the second plate;
`
`a shield plate formed in a second conductive layer of the IC having a
`
`perimeter electrically connected the second plate so as to form an electrical shield
`
`around the first plate; and
`
`a plurality of contacts formed between the shield plate and the second plate;
`
`wherein the shield plate has a gap through which an electrical contact to the
`
`first plate extends, and the shield plate, the plurality of contacts, and the second
`
`plate provide electrical shielding for the first plate.
`
`19. (Original) The capacitor of claim 18 wherein the first conductive layer
`
`is a first poly layer, the substrate comprises silicon and second plate is formed in
`
`an N—well of the substrate and the shield plate is formed in a second poly layer of
`
`the IC.
`
`
`
`Patent Owner’s First Motion to Amend
`
`IPR2012-00023
`
`20. (New, substitute for original claims 1 and 8) A capacitor in an
`
`integrated circuit ("IC“) comprising:
`
`a core capacitor portion having a first plurality of conductive elements
`
`electrically connected to and forming a first part of a first node of the capacitor
`
`formed in a first conductive layer of the IC and a second plurality of conductive
`
`elements electrically connected to and forming a first part of a second node of the
`
`capacitor formed in the first conductive layer, the first plurality of conductive
`
`elements alternating with the second plurality of conductive elements in the first
`
`conductive layer, and a third plurality of conductive elements electrically
`
`connected to and forming a second part of the first node formed in a second
`
`conductive layer adjacent to the first conductive layer, each of the conductive
`
`elements in the third plurality of conductive elements is adjacent to a conductive
`
`element electrically connected to and forming a third part of the first node, and at
`
`least portions of some of the second plurality of conductive elements overlying and
`
`vertically coupling to at least portions of some of the third plurality of conductive
`
`elements;
`
`a shield capacitor portion having a fourth plurality of conductive elements
`
`formed in at least the first conductive layer of the IC, the second conductive layer
`
`of the IC, a third conductive layer of the IC, and a fourth conductive layer of the
`
`
`
`IPR20l2-00023
`
`
`Patent Owner’s First Motion to Amend
`
`IC, the first conductive layer and the second conductive layer each being between
`
`the third conductive layer and the fourth conductive layer, the shield capacitor
`
`portion being electrically connected to and forming a second part of the second
`
`node of the capacitor and surrounding the first plurality of conductive elements and
`
`the third plurality of conductive elements; and
`
`a reference shield electrically connected to a reference node of the IC other
`
`than the second node of the capacitor, the shield capacitor portion being disposed
`
`between the reference shield and the core capacitor portion.
`
`21. (New, substitute for original claim 2) A capacitor in an integrated
`
`circuit ("IC“) comprising:
`
`a core capacitor portion having a first plurality of conductive elements
`
`electrically connected to and forming a first part of a first node of the capacitor
`
`formed in a first conductive layer of the IC and a second plurality of conductive
`
`elements electrically connected to and forming a first part of a second node of the
`
`capacitor formed in the first conductive layer, the first plurality of conductive
`
`elements alternating with the second plurality of conductive elements in the first
`
`conductive layer, and a third plurality of conductive elements electrically
`
`connected to and forming a second part of the first node formed in a second
`
`conductive layer adjacent to the first conductive layer, at least portions of some of
`
`
`
`Patent Owner’s First Motion to Amend
`
`IPR2012-00023
`
`the second plurality of conductive elements overlying and vertically coupling to at
`
`least portions of some of the third plurality of conductive elements;
`
`a shield capacitor portion having a fourth plurality of conductive elements
`
`formed in at least the first conductive layer of the IC, the second conductive layer
`
`of the IC, a third conductive layer of the IC, and a fourth conductive layer of the
`
`IC, the first conductive layer and the second conductive layer each being between
`
`the third conductive layer and the fourth conductive layer, the shield capacitor
`
`portion being electrically connected to and forming a second part of the second
`
`node of the capacitor and surrounding the first plurality of conductive elements and
`
`the third plurality of conductive elements; and
`
`a reference shield electrically connected to a reference node of the IC other
`
`than the second node of the capacitor, the shield capacitor portion being disposed
`
`between the reference shield and the core capacitor portion;
`
`wherein the third conductive layer is a metal layer of the IC and the fourth
`
`conductive layer is a poly layer of the IC, the shield capacitor portion including a
`
`first node shield plate formed in the metal layer from a plurality of metal stripes
`
`and a second node shield plate formed in the poly layer.
`
`22. (New, substitute for original claim 3) The capacitor of claim 20
`
`wherein the shield capacitor portion includes a first node shield plate formed in the
`
`
`
`IPR20l2—00O23
`
`
`Patent Owner’s First Motion to Amend
`
`third conductive layer and a second node shield plate formed in the fourth
`
`conductive layer and further comprising a first conductive curtain extending from
`
`the first node shield plate to the second node shield plate and a second conductive
`
`curtain extending from the first node shield plate to the second node shield plate.
`
`23. (New, substitute for claim 4) The capacitor of claim 20 wherein the
`
`capacitor is a switching capacitor, the first node is a top node of the switching
`
`capacitor and the second node is a bottom node of the switching capacitor.
`
`24. (New, substitute for claim 5) The capacitor of claim 20 wherein the
`
`reference node is a VDD node.
`
`25. (New, substitute for claim 6) The capacitor of claim 20 wherein the
`
`reference node is an analog ground node.
`
`26. (New, substitute for claim 7) The capacitor of claim 20 wherein the first
`
`plurality of conductive elements comprises a first plurality of conductive strips
`
`extending along a first direction, the second plurality of conductive elements
`
`comprises a second plurality of conductive strips extending along the first
`
`direction, and the third plurality of conductive elements comprises a third plurality
`
`
`
`IPR2012-00023
`
`
`Patent Owner’s First Motion to Amend
`
`of conductive strips extending along a second direction orthogonal to the first
`
`direction.
`
`27. (New, substitute for claim 9) The capacitor of claim 26 further
`
`comprising a fourth plurality of conductive elements formed in a fifth conductive
`
`layer of the IC disposed between the fourth conductive layer and the second
`
`conductive layer and electrically connected to and forming a fourth part of the first
`
`node, the fourth plurality of conductive elements extending along the first
`
`direction, and a fifth plurality of conductive elements electrically connected to and
`
`forming a third part of the second node formed in the fifth conductive layer
`
`extending along the first direction alternating with the fourth plurality of
`
`conductive elements in the fifth conductive layer.
`
`28. (New, substitute for claimlO) The capacitor of claim 20 wherein the
`
`first plurality of conductive elements comprises a first plurality of conductive strips
`
`extending along a first direction, the second plurality of conductive elements
`
`comprises a second plurality of conductive strips extending along the first
`
`direction, and the third plurality of conductive elements comprises a third plurality
`
`of conductive strips extending along the first direction.
`
`
`
`IPR2012-00023
`
`
`Patent Owner’s First Motion to Amend
`
`29. (New, substitute for claim 12) The capacitor of claim 20 further
`
`comprising a second reference shield connected to a second reference node of the
`
`IC, the reference shield being disposed between the second reference shield and the
`
`shield capacitor portion.
`
`30. (New, substitute for claim 13) A capacitor in an integrated circuit
`
`("IC") comprising:
`
`a core capacitor portion having a first plurality of conductive elements
`
`electrically connected to and forming a first part of a first node of the capacitor
`
`formed in a first conductive layer of the IC and a second plurality of conductive
`
`elements electrically connected to and forming a first part of a second node of the
`
`capacitor formed in the first conductive layer, the first plurality of conductive
`
`elements alternating with the second plurality of conductive elements in the first
`
`conductive layer, and a third plurality of conductive elements electrically
`
`connected to and forming a second part of the first node formed in a second
`
`conductive layer adjacent to the first conductive layer, at least portions of some of
`
`the second plurality of conductive elements overlying and vertically coupling to at
`
`least portions of some of the third plurality of conductive elements;
`
`a shield capacitor portion having a fourth plurality of conductive elements
`
`formed in at least the first conductive layer of the IC, the second conductive layer
`
`
`
`IPR2012-00023
`
`
`Patent Owner’s First Motion to Amend
`
`of the 1C, a third conductive layer of the IC, and a fourth conductive poly layer of
`
`the IC, the first conductive layer and the second conductive layer each being
`
`between the third conductive layer and the fourth poly conductive layer, the shield
`
`capacitor portion being electrically connected to and forming a second part of the
`
`second node of the capacitor and surrounding the first plurality of conductive
`
`elements and the third plurality of conductive elements, and
`
`a reference shield electrically connected to a reference node of the IC other
`
`than the second node of the capacitor, the shield capacitor portion being disposed
`
`between the reference shield and the core capacitor portion, wherein the reference
`
`shield includes a substrate portion of a substrate of the 1C, a first conductive
`
`curtain extending from the substrate portion, and a second conductive curtain
`
`extending from the substrate portion.
`
`31. (New, substitute for claim 14) The capacitor of claim 30 wherein the
`
`substrate portion comprises an N-well of the substrate of the IC.
`
`32. (New, substitute for claim 15) The capacitor of claim 30 wherein the
`
`reference shield is a first cup shield having an open top.
`
`_10_
`
`
`
`Patent Owner’s First Motion to Amend
`
`IPR20l2-00023
`
`33. (New, substitute for claim 16) The capacitor of claim 32 further
`
`comprising a second reference shield connected to a second reference node of the
`
`IC, the second reference shield including a second reference shield plate extending
`
`across the open top of the first cup shield.
`
`34. (New, substitute for claim 17) The capacitor of claim 33 wherein the
`
`second reference shield is a second cup shield.
`
`II.
`
`Discussion of Proposed Changes
`
`The proposed amendment cancels original claims 1-17, retains original
`
`claims 18-19, and adds new claims 20-34. In total, 17 original claims are cancelled
`
`and 15 substitute claims are added.
`
`Proposed claim 20 is identical to original independent claim 1, except that it
`
`now includes the claim limitation recited in original claim 8 (which depends on
`
`claim 1).
`
`Proposed claim 21 is identical to original claims 1 and 2 (claim 2 depends on
`
`claim 1). The scope of proposed claim 21 is exactly the same as that of original
`
`claim 2, the only difference being that claim 21 is written in independent form.
`
`Proposed claims 22-29 are identical to original claims 3-7, 9-10, and 12,
`
`respectively, the only difference being that proposed claims 22-29 depend on
`
`_11_
`
`
`
`Patent Owner’s First Motion to Amend
`
`IPR2012-00023
`
`proposed claim 20, while original claims 3-7, 9-10, and 12 depend on original
`
`claim 1, which as discussed above, would be cancelled.
`
`Proposed claim 30 is identical to original independent claim 13, except that
`
`the claimed “fourth conductive layer” is recited as being a “poly” layer.
`
`Proposed claims 31-34 are identical to original claims 14-17, respectively,
`
`the only difference being that the proposed claims depend on proposed claim 30,
`
`while claims 14-17 depend on original claim 13, which as discussed above, would
`
`be cancelled.
`
`III.
`
`Support for Claimed Subject Matter
`
`Support for the proposed claims is provided below, with reference to the as-
`
`filed specification and drawings of the originally filed application. A copy of the
`
`originally filed application is provided in Exhibit IVM-1003.
`
`The limitations presented in proposed claim 20 are the same as those listed
`
`in issued claims 1 and 8, and in as-filed claims 1, 5, and 12. In addition, Figs. 2A-
`
`2D and specification paragraphs [0025]-[0043] describe the four layers of
`
`conductive elements arranged as claimed.
`
`Proposed claim 21 is identical to issued claim 2, except that it is written in
`
`independent form. Proposed claim 21 also includes all of the limitations listed in
`
`_12_
`
`
`
`Patent Owner’s First Motion to Amend
`
`IPR2012-00023
`
`as-filed claims 1, 2, and 5. In addition, Figs. 2A-2D and specification paragraphs
`
`[O025]—[0O43] describe the four layers of conductive elements arranged as claimed.
`
`Proposed claim 22 is identical to issued claim 3 and as-filed claim 3, except
`
`that it depends on proposed claim 20, discussed above. Multiple conductive
`
`curtains are shown in Figs. 2C-2D.
`
`Proposed claim 23 is identical to issued claim 4 and as-filed claim 4, except
`
`that it depends on proposed claim 20, discussed above. A switching capacitor is
`
`described in Fig. 1 and in specification paragraphs [0020]-[0O25].
`
`Proposed claim 24 is identical to issued claim 5 and as-filed claim 9, except
`
`that it depends on proposed claim 20, discussed above. A VDD node is shown in
`
`Figs. 2B—2D.
`
`Proposed claim 25 is identical to issued claim 6 and as-filed claim 10, except
`
`that it depends on proposed claim 20, discussed above. A ground node is shown in
`
`Figs. 2C-2D.
`
`Proposed claim 26 is identical to issued claim 7 and as-filed claim 11, except
`
`that it depends on proposed claim 20, discussed above. Layers of orthogonal
`
`conductive strips are shown in Figs. 2A-2D.
`
`Proposed claim 27 is identical to issued claim 9 and as-filed claim 13, except
`
`that it depends on proposed claim 20, discussed above. A fifth plurality of
`
`conductive elements is shown in Figs. 2A-2D.
`
`_.13_
`
`
`
`Proposed claim 28 is identical to issued claim 10. The claimed arrangement
`
`Patent Owner’s First Motion to Amend
`
`IPR20l2—O0023
`
`of conductive strips is shown in the combination of Figs. 2B and 3A.
`
`Proposed claim 29 is identical to issued claim 12 and as—f1led claim 21,
`
`except that it depends on proposed claim 20, discussed above. The claimed
`
`arrangement of two reference shields is shown in Fig. 2D.
`
`Proposed claim 30 is identical to issued claim 13 and as—filed claims 1, 5,
`
`and 6. Figs. 2A-2D and specification paragraphs [0025]—[0O43] describe the four
`
`layers of conductive elements and conductive curtains arranged as claimed.
`
`Proposed claim 31 is identical to issued claim 14 and as-filed claim 7, except
`
`that it depends on proposed claim 30, discussed above. The use of an N-well
`
`substrate, as claimed, is shown in Figs. 2B-2D.
`
`Proposed claim 32 is identical to issued claim 15 and as-filed claim 8, except
`
`that it depends on proposed claim 30, discussed above. A cup-shaped reference
`
`shield is shown in Fig. 2C.
`
`Proposed claim 33 is identical to issued claim 16, except that it depends on
`
`proposed claim 32, discussed above. A second reference shield is shown in Fig.
`
`2C.
`
`Proposed claim 34 is identical to issued claim 17, except that it depends on
`
`proposed claim 33, discussed above. A second cup-shaped reference shield is
`
`shown in Fig. 2C.
`
`__14_
`
`
`
`Patent Owner’s First Motion to Amend
`
`lPR20l2-00023
`
`IV.
`
`Patentably Distinct Features of Proposed Claims
`
`Proposed claim 20 is the same as original claim 1, except that it adds the
`
`following patentably distinct feature:
`
`each of the conductive elements in the third plurality of
`conductive elements is adjacent to a conductive element
`electrically connected to the first node.
`
`This claim element is taken directly from original claim 8, which depends on
`
`original claim 1. As described in the present response with respect to original
`
`claim 8, the prior art does not show a capacitor with a layer of conductive elements
`
`all connected to the same node, adjacent another layer with conductive elements
`
`alternating between the two nodes.
`
`Proposed claim 30 is the same as original claim 13, except that it further
`
`limits the claimed fourth conductive layer to be a “poly” layer. This is patentably
`
`distinct from the prior art because fourth conductive layer is part of the shield
`
`capacitor portion, which is connected to and part of the second node of the
`
`capacitor and the second plurality of conductive elements.
`
`Proposed claim 21 is the same as original claim 2, but written in independent
`
`form. All of the other remaining proposed claims are amended only to update the
`
`corresponding base claim (proposed claim 20 or 30, discussed above). The Patent
`
`Owner Response filed concurrently herewith identifies patentably distinct features
`
`in these claims, but these features existed in the claims as originally issued.
`
`_15_
`
`
`
`V.
`
`Conclusion
`
`Patent Owner’s First Motion to Amend
`
`IPR20l2-00023
`
`Accordingly, the present motion for claim amendments should be adopted.
`
`Respectfulli submitted,
`
`David M. O’Dell
`
`Registration No. 42,044
`
`HAYNES AND BOONE, LLP
`
`Customer No. 27683
`
`Telephone: 972/739-8635
`Facsimile: 214/200-0808
`
`Attorney Docket No.: 42299.45
`
`Dated:
`
`May 7, 2013
`
`R.330636.l
`
`_16-
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Patent Owner’s First Motion to Amend
`
`IPR2012-00023
`
`INTELLECTUAL VENTURES MANAGEMENT, LLC
`Petitioner
`
`V
`XILINX, INC.
`Patent Owner
`
`Case IPR2012-00023
`
`Patent 7,994,609
`
`Title: SHIELDING FOR INTEGRATED CAPACITORS
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.205, that
`
`service was made on IVM-as detailed below.
`
`Date ofservice May 7, 2013
`
`Manner ofservice Electronic Mail (lgordon@skgf.com; rsterne@skgf.com)
`
`Documents served Patent Owner Response;
`
`Patent Owner’s First Motion to Amend By Xilinx Under 37
`
`C.F.R § 42.121;
`
`Xilinx’ Exhibit List; and
`
`Exhibits: XLNX-2006 through XLNX-2007
`
`Persons served STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`1100 NEW YORK AVENUE, N.W.
`
`WASHINGTON DC 20005
`
`/David M. O’Dell/
`
`David M. O’Dell
`
`Registration No. 42,044
`
`..17_
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