Paper N0._
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`INTELLECTUAL VENTURES MANAGEMENT, LLC
`Petitioner
`
`V.
`
`Patent of 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 RESPONSE
`
`

`

`Patent Owner’s Response
`IPR2012-00023
`
`TABLE OF CONTENTS
`
`Table of Authorities ........................................................... : ...................................... 3
`
`I.
`
`Original Claims 2, 8-9, and 18-19 Are Valid .................................................... 5
`
`A. Original claim 2 is valid ............................................................................... 5
`
`1.
`
`Paul does not teach the claimed shield plate in poly ................................. 6
`
`2. Anthony does not teach the claimed shield plate in poly .......................... 7
`
`B. Original claim 8 is valid ............................................................................. 10
`
`1.
`
`Paul only has layers of alternating conducting elements ........................ 12
`
`2. Brennan only has plate layers .................................................................. 13
`
`There is no reason to replace one of Paul’s alternating layers with one
`3.
`of Brennan’s plate layers, except for hindsight .............................................. 14
`
`C. Original claim 9 is valid ............................................................................. 15
`
`D. Original claim 18 is valid ........................................................................... 16
`
`E.
`
`Original claim 19 is valid ........................................................................... 17
`
`II. Amended Claims ............................................................................................. 18
`
`A.
`
`B.
`
`C.
`
`D.
`
`Proposed claim 20 is valid .......................................................................... 18
`
`Proposed claim 21 is valid .......................................................................... 18
`
`Proposed claim 27 is valid .......................................................................... 19
`
`Proposed claim 30 is valid .......................................................................... 19
`
`111. Conclusion ..................................................................................................... 20
`
`Certificate of Service ............................................................................................... 21
`
`

`

`Patent Owner’s Response
`IPR2012—00023
`
`TABLE OF AUTHORITIES
`
`Cases
`
`In re Fine, 837 F.2d 1071 (Fed. Cir. 1988) ............................................................. 15
`
`In re Gordon, 733 F.2d 900 (Fed. Cir. 1984) ......................................................... 15
`
`Statutes
`
`35 U.S.C. § 103 ....................................................................................... 5,10,16,17
`
`35 U.S.C. § 311 ....................................................................................... 5,10,16,17
`
`35 U.S.C.§316 ......................................................................................................... 4
`
`Rules
`
`37 C.F.R. § 42.220 .................................................................................................... 4
`
`

`

`Patent Owner’s Response
`1PR201 2-00023
`
`Patent Owner Xilinx, Inc. (“Xilinx”) provides this response under 35 U.S.C.
`
`§ 316(a)(8) and 37 C.F.R. § 42.220. The Petition filed by Intellectual Ventures
`
`Management (“IVM”) on September 17, 2012 requesting inter partes review of
`
`claims 1-19 of US. Patent No. 7,994,609 (the “’609 Patent,” Ex. IVMlOOl)
`
`proposed six different Grounds of rejections, which were granted by the Board on
`
`February 12, 2013.
`
`Concurrently with this filing, Xilinx files a separate Motion to Amend that
`
`presents reasons why the proposed substitute claims are still further distinguished
`
`from the prior art of record. Since the proposed substitute claims recite all of the
`
`limitations of the original independent claims, the arguments presented in this
`
`Response apply equally to the proposed substitute claims. Nevertheless, Xilinx
`
`requests that the Board consider the substitute claims only if it determines that the
`
`original claims are invalid.
`
`The next section below is directed to original claims, and explains why the
`
`identified claims are valid over the prior art. The following section is directed to
`
`the claims for which an amendment has been proposed, and explains why the
`
`amended claims are valid over the prior art.
`
`

`

`1.
`
`Original Claims 2, 8-9, and 18-19 Are Valid
`
`The following discussion shows why original claims 2, 8-9, and 18—19 are
`
`Patent Owner’s Response
`IPR2012-00023
`
`valid.
`
`A.
`
`Original claim 2 is valid
`
`IVM-asserts, as to Ground 2, that original claim 2 is obvious over Paul in
`
`View of Anthony. Xilinx will show that this proposed rejection does not meet the
`
`legal requirements for obviousness under 35 U.S.C. § 103, especially under the
`
`requirements under 35 U.S.C. § 311(b) that a ground for inter partes review be
`
`“only on the basis of prior art consisting of patents or printed publications.”
`
`Original claim 2 recites:
`
`wherein the fourth conductive layer is a poly layer of the IC, the
`
`shield capacitor portion including
`
`a second node shield plate
`
`formed in the poly layer.
`
`This claim draws support from, e.g., Figure 2B of the ’609 patent (reproduced
`
`below). As shown below, the capacitor includes two nodes T and B. Node B
`
`includes shield plate B’, which is made of polysilicon. A reference shield 224/225
`
`is also provided in addition to (and separate from) the nodes of the capacitor and
`
`the shield plate B’. The reference shield 224/225 is annotated in the figure, and in
`
`this example is connected to the reference voltage VDD.
`
`lVM-lOOl at 6:45-46 and
`
`7:31-32.
`
`

`

`Patent Owner’s Response
`IPR2012—00023
`
`connected to VDD
`
`“5
`
`
`
`
`
`
`
`_______________________
`
` reference shield—————>
`
`
`
`
`
`
`]
`
`ll| :
`
`.
`,
`I
`;
`BS:T7
`T6
`:Tstas
`II L__-__ _ -c------1_.'---‘- - ---_-:
`’ ——————————————————
`
`shield plate, formed in
`poly and connected to
`a capacitor node—
`
`‘
`
`Claim 1 (upon which claim 2 depends) clearly distinguishes the “shield
`
`capacitor portion” (which includes the “shield plate”) from the “reference shield.”
`
`Claim 1 recites that “the shield capacitor portion [is] electrically connected to and
`
`form[s] a second part of the second node of the capacitor,” while “the reference
`
`shield [is] electrically connected to a reference node of the IC.”I As will be
`
`shown below, neither Paul nor Anthony teach or suggest a “shield plate” that is
`
`“formed in the poly layer” and is “part of the second node of the capacitor.”
`
`1.
`
`Paul does not teach the claimed shield plate in poly
`
`As agreed by IVM, “Paul does not disclose that the fourth layer [for the
`
`shield capacitor portion] is a poly layer of the IC or that a second node shield is
`
`formed in the poly layer.” Paper 3 (Petition) at 24.
`
`1
`
`Dependent claims 5 and 6 recite that the reference node is either VDD or
`
`ground.
`
`

`

`Patent Owner’s Response
`IPR2012—00023
`
`2.
`
`Anthony does not teach the claimed shield plate in poly
`
`IVM-relies on Anthony for this claim element. Id. Specifically, the Petition
`
`cites Anthony as stating: “[a]s an alternative to the use of a metal layer as shown
`
`in FIG. 3B
`
`the bottom shield plate 36 can be implemented with a polysilicon or
`
`diffusion layer.” Paper 3 at 24, citing IVM—1007 at 4:49—52. FIGS. 38 and 4 of
`
`Anthony is reproduced and annotated below.
`
`38
`
`M3
`
`
`
`
`
`37
`
`
`
`E :
`
`39I
`E
`
`\\;\V\\\\\\\\>>>>\\
`I
`
`~7/1'\1’////////
`‘
`g
`g ‘\~\\\\\\\\\>1
`
`
`3. :l///
`
`I
`”I//////////////~
`
`
`{\\\\\\\\\\\\\\\\\\\
`
`
`
`
`
`
`
`
`Anthony,FIG. 4
`
`w
`
`

`

`mm \‘m -
`
`
`
`
`
`Patent Owner’s Response
`IPR2012—00023
`
`.. -— - reference
`shield
`
`’
`
`- ’ capacitor
`nodes
`
`
`
`
`szl/l/l/l/l/l/lllfi 32
`
`
`n¢&\\\\\\\\\\w»<
`v ‘1)
`E
`
`
`
`
`
`
`_ _
`, ’
`
`, reference
`shield
`
`A!
`_
`V
`WW
`
` FIG. 4
`
`Anthony, FIG. 4
`
`Anthony states that the capacitor 30 is formed by “plates 33 and 34” and
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`“terminals 31 and 32.” IVM-1007, 4:35-38. These plates are formed in
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`“additional layers of metal.” IVM-1007, 413-4. The capacitor 30 of FIG. 4 is
`
`shielded by features including the metal plate 35, and the diffused layer 46. IVM-
`
`1007, 4:66—5:2. In other words, Anthony’s capacitor in FIG. 4 has a first plate 33
`
`and a second plate 34 where both plates are formed of metal layers overlying the
`
`substrate, not in poly or in the diffusion. Anthony’s reference shield plate 36/46
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`is formed in the metal layer (36) and in the diffusion layer (46), and is not
`
`connected to either node of the capacitor. Even if reference shield plate 36/46 was
`
`in poly, it is still not connected to a node of the capacitor.
`
`—8——
`
`

`

`Patent Owner’s Response
`IPR2012-00023
`
`Thus, bottom shield plate 36/46 is a reference shield, 2 and is never shown or
`
`suggested as being connected to or part of the capacitor node. This configuration
`
`is different from claim 2 of the’609 patent, which recites a shield capacitor portion
`
`that is both “electrically connected to and forming a
`
`part of the second node of
`
`the capacitor” and that is “formed in the poly layer.”
`
`It is noted that a similar argument was made in Xilinx’s Preliminary
`
`Response, with respect to claims 18 and 19. The Board responded that “dielectric
`
`interposing the two plates” is a capacitor structure. Paper 1 l at 12. However, this
`
`argument does not apply for claim 2 because the claim has additional limitations
`
`for the capacitor. Specifically, claim 2 recites that the “node shield plate” be a part
`
`of the claimed “second node of the capacitor,” which is also connected to a layer
`
`with a “second plurality of conductive elements” that alternate with the first
`
`plurality of conductive elements. The shield plate 36/46 of Anthony is not
`
`connected to any alternating conductive elements.
`
`Thus, the above-identified claim element is neither taught nor suggested by
`
`the cited prior art publications. To the extent IVM-relies on its expert declaration
`
`to teach this claim element, such would be outside the legal bounds of inter partes
`
`[Q
`
`lVM-1007 at 4:59.
`
`IVM—later admits that the shield plate 36 is a reference
`
`shield, in a different ground of rejection. Paper 3 at 28.
`
`

`

`Patent Owner’s Response
`IPR2012—00023
`
`review under 35 U.S.C. § 311(b). Accordingly, the proposed rejection for original
`
`claim 2 should not be adopted.
`
`It is further noted that the Motion to Amend filed herewith proposes to
`
`replace original claim 2 with proposed claim 21. Proposed claim 21 is exactly the
`
`same as original claim 2 and original claim 1 (upon which claim 2 depends),
`
`except that it is a single independent claim. That is, the scope of original claim 2 is
`
`exactly the same as the scope of proposed claim 21, and the analysis above applies
`
`equally to both.
`
`B.
`
`Original claim 8 is valid
`
`IVM—asserts, as to Ground 3, that claim 8 is obvious over Paul in view of
`
`Brennan. Xilinx will show that this proposed rejection does not meet the legal
`
`requirements for obviousness under 35 U.S.C. § 103, especially under the
`
`requirements under 35 U.S.C. § 311(b) that a ground be “only on the basis ofprior
`
`art consisting of patents or printed publications.”
`
`Original claim 8 recites:
`
`[a third plurality of conductive elements in a second conductive
`
`layer adjacent to and orthogonal to the conductive elements in
`
`the first conductive layer wherein] each of the conductive
`
`elements in the third plurality of conductive elements is
`
`adjacent to a conductive element electrically connected to the
`
`first node.
`
`-10_
`
`

`

`Patent Owner’s Response
`IPR2012—00023
`
`
`For the sake of example, FIG. 2A from the ‘609 patent is reproduced and annotated
`
`below, the annotations corresponding to the terms in claim 8:
`
`
`
`
`\ third plurality of
`conductive elements
`
`in second
`
`conductive layer
`
`FIG. 2A from ‘609 patent
`
`As can be seen in the figure, the claimed “first conductive layer” (referred to
`
`as metal 3, or M3 in the ‘609 patent) includes alternating conductive elements from
`
`the top node (T) and the bottom node (B). The claimed “second conductive layer”
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`(referred to as metal 2, or M2 in the patent) only includes conductive elements
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`from the top node (T). The ‘609 patent refers to this latter type of layer, where
`
`there are no alternating conductive elements, as a “plate” layer. IVM-lOOl at 5:57-
`
`58. The ‘609 patent explains the benefit of having a plate layer adjacent to a layer
`
`of alternating conductive elements as follows:
`
`_11_
`
`

`

`Patent Owner’s Response
`IPR2012-00023
`
`the core capacitor portion 201 . .. has interleaved top and bottom
`
`node conductive filaments that provide high specific lateral
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`capacitance in the M1 and M3 metal layers, and vertical
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`capacitance between the bottom node elements in M1 and M3
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`and the top node elements in M2, which is adjacent to both M1
`
`and M3. IVM—lOOl at 6:33-38, emphasis added.
`
`In addition, the conductive elements in the first conductive layer are “orthogonal”
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`to the conductive elements in the second conductive layer, as recited by claim 7
`
`(upon which claim 8 depends). See also, the Declaration of Richard A. Blanchard,
`
`PhD. (Ex. XLNX—2006) at 182-34.
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`Thus, the capacitor recited in claim 8 includes a specific lateral capacitance
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`and vertical capacitance. The ‘609 patent discusses lateral spacing requirements
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`(the spacing between two elements in the same layer) which define lateral
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`capacitance, and vertical spacing requirements (the spacing between two adjacent
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`layers) which define vertical capacitance, and how these are effected by the design
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`rules and process technology. IVM-lOOl at 6:64-7:17; see also, XLNX-2006 at
`
`fll32—34.
`
`].
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`Paul only has layers of alternating conducting elements
`
`Paul does not teach a plate layer (the claimed second layer) having a
`
`plurality of conducting elements connected to a common node. Specifically,
`
`Paul’s FIG. 13 teaches two interior layers having a plurality of conducting
`
`_12_
`
`

`

`Patent Owner’s Response
`
`IPR2012-00023
`
`elements, the layers in Metal 3 and Metal 2. FIG. 13 of Paul is reproduced below.
`
`In both these interior layers, the conducting elements alternate between node A and
`
`node B. There is no interior layer of conducting elements that do not alternate (a
`
`plate layer).3 See also, XLNX-2006 at 1126-27.
`
`alternating
`conductive elements
`
`METAL 1-—>
`
`METAL 2~—*
`
`Paul, FIG. 13
`
`2.
`
`Brennan only has plate layers
`
`Brennan is directed to a capacitor with only plate layers, and no layers with
`
`alternating conducting elements. Brennan extolls the benefits of using only plate
`
`layers, stating that they “simplify planar capacitor fabrication at the metal
`
`interconnect layer and via layers.” IVM-1009, 3:28-30. Brennan further describes
`
`the benefits of using “slotted” capacitor plates, including improved quality of
`
`planar capacitor plates and that the trace and slot widths in a plate layer provide
`
`3
`
`FIG. 13 of Paul was used by IVM—in the Petition. Paper 3 at 42.
`
`_13_
`
`

`

`Patent Owner’s Response
`IPR2012-00023
`
`“filtering of relatively high frequency EMI noise.” IVM-1009, 6:58—7z9; see also,
`
`XLNX-2006 at 1122-23.
`
`There is no reason to replace one of Paul’s alternating
`3.
`layers with one of Brennan’s plate layers, except for hindsight
`
`The capacitor of claim 8 has more conductive elements connected to one
`
`node than to the other. Specifically for claim 8, the first node of the capacitor is
`
`connected to all of the first and third pluralities of conducting elements, while the
`
`second node of the capacitor is connected to only the second plurality of
`
`conducting elements. Thus, the capacitor ofclaim 8 is unbalanced, as to the
`
`coupling of each node, and therefore serves as a switching capacitor. See IVM-
`
`1001 at l:63—2:8; see also, original claim 4; XLNX-2006 at 1130-34.
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`In contrast, both Paul and Brennan are directed to balanced capacitors. Paul
`
`teaches a capacitor in which the layers of conducting elements are always
`
`balanced. XLNX—2006 at $126. Likewise, Brennan teaches a capacitor with equal
`
`numbers of plate layers (balanced). XLNX-2006 at 1123.
`
`In the Declaration of Morgan Johnson, Mr. Johnson has constructed a
`
`modified figure, labeled FIG. G, that is supposedly based, at least in part, on FIG.
`
`13 of Paul and FIG. 4 of Brennan. IVM1002 at 44-46. The capacitor described in
`
`FIG. G has converted the balanced capacitor of Paul (and the balanced capacitor of
`
`Brennan) into an unbalanced transistor by inserting the middle (the so—called 2nd
`
`layer) of the capacitor connected to node “B,” and relabeling the bottom plate (the
`
`_14_
`
`

`

`Patent Owner’s Response
`IPR2012-00023
`
`so—called 4th layer) as being connected to node “A”. That is, the capacitor of FIG.
`
`G now includes two plates connected to node A, one connected to node B, and two
`
`layers with elements connecting to A and B in an alternating manner. This new
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`arrangement goes well beyond the scope of either Paul or Morgan. That is, this is
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`not merely adding another set of nodes to perform their known function, but this is
`
`changing the functional operation of the resulting capacitor in a way not previously
`
`described. See XLNX-2006 at 1135. “If a proposed modification would render the
`
`prior art invention being modified unsatisfactory for its intended purpose, then
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`there is no suggestion or motivation to make the proposed modification.” In re
`
`Gordon, 733 F.2d 900 (Fed. Cir. 1984).
`
`It is noted that the Motion to Amend filed herewith proposes to replace
`
`original claim 8 with proposed claim 20. Proposed claim 20 includes the above-
`
`identified element from claim 8, as well as the entirety of original claim 1 (upon
`
`which claim 8 depends). The analysis above for claim 8 applies equally to
`
`proposed claim 20.
`
`C.
`
`Original claim 9 is valid
`
`Claim 9 depends on claim 8, which as discussed above, is nonobvious over
`
`the prior art. Accordingly, claim 9 is nonobvious over the prior art. In re Fine,
`
`837 F.2d 1071 (Fed. Cir. 1988).
`
`-15_
`
`

`

`Patent Owner’s Response
`IPR2012—00023
`
`It is noted that the Motion to Amend filed herewith proposes to replace
`
`original claim 9 with proposed claim 27. Proposed claim 27 is exactly the same as
`
`original claim 9, except that claim 9 depends on claim 8, and proposed claim 27
`
`depends on proposed claim 20. As discussed above with reference to claim 8,
`
`proposed claim 20 should be allowed, and therefore, so should proposed claim 27.
`
`D.
`
`Original claim 18 is valid
`
`IVM-asserts, as to Ground 5, that claim 18 is obvious over Anthony in view
`
`of Marotta. Xilinx will show that this proposed rejection does not meet the legal
`
`requirements for obviousness under 35 U.S.C. § 103, especially under the
`
`requirements under 35 U.S.C. § 31 l(b) that a ground be “only on the basis of prior
`
`art consisting of patents or printed publications.”
`
`Original claim 18 recites: “a second plate formed in a substrate of the IC.”
`
`lVM-relies on Anthony to teach this claim element. Paper 3 at 46. But as
`
`discussed above with reference to original claim 2, and admitted by IVM-
`
`previously in the petition, the shield plate 36/46 of Anthony is not a plate of the
`
`capacitor, but is reference shield. See above at p. 7; and see Paper 3 at 28.
`
`Accordingly, for the same reasons discussed above with reference to claim 2, the
`
`proposed rejection for claim 18 should not be adopted.
`
`—16—
`
`

`

`Patent Owner’s Response
`IPR2012-00023
`
`E.
`
`Original claim 19 is valid
`
`lVM-asserts, as to Ground 5, that claim 19 is obvious over Anthony in View
`
`of Marotta. Xilinx will show that this proposed rejection does not meet the legal
`
`requirements for obviousness under 35 U.S.C. § 103, especially under the
`
`requirements under 35 U.S.C. § 31 1(b) that a ground be “only on the basis of prior
`
`art consisting of patents or printed publications.”
`
`Claim 19 depends on claim 18, which as discussed above is nonobvious over
`
`the prior art. For this reason alone, claim 19 is nonobvious.
`
`In addition, original claim 19 recites:
`
`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 1C. (Emphasis added.)
`
`Neither of the references teaches an IC with two poly layers, one poly layer used
`
`for a second plate of the capacitor and the other poly layer used for a shield plate.
`
`See 6. g, XLNX—2006 at 1i20, 25. To the extent IVM-relies on its expert declaration
`
`to teach this claim element, such would be outside the legal bounds of inter partes
`
`review under 35 U.S.C. § 311(b). Since a double-poly layer IC is not disclosed in
`
`the prior art, the rejection of claim 19 should be withdrawn.
`
`_17_
`
`

`

`Patent Owner’s Response
`IPR2012—00023
`
`II.
`
`Amended Claims
`
`The following discussion addresses the proposed claims submitted in the
`
`Motion to Amend, filed herewith.
`
`A.
`
`Proposed claim 20 is valid
`
`In the Motion to Amend, Xilinx proposes to substitute original claim 1 with
`
`claim 20. Proposed claim 20 includes all the words and imitations from original
`
`claim 1, and adds the following claim limitation:
`
`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. This claim element is also discussed above, with reference to
`
`original claim 8, and for these reasons, proposed claim 20 is valid over the prior
`
`art.
`
`B.
`
`Proposed claim 21 is valid
`
`Xilinx proposes to substitute original claim 2 with claim 21. Claim 21 is the
`
`same as claim 2, except in independent format. That is, claim 21 includes each and
`
`every limitation of original claim 2, as well as original claim 1, upon which claim 2
`
`depends. For the exact same reasons discussed above with reference to claim 2,
`
`proposed claim 21 is valid over the prior art.
`
`—18—
`
`

`

`Patent Owner’s Response
`IPR2012-00023
`
`C.
`
`Proposed claim 27 is valid
`
`Xilinx proposes to substitute original claim 9 with claim 27. Claim 27 is the
`
`same as claim 9, except claim 9 depends on claims 1 and 8, and claim 27 depends
`
`on claim 20. As discussed above, proposed claim 20 includes limitations
`
`previously found in original claims 1 and 8. For the same reasons discussed above
`
`with reference to claim 9, proposed claim 27 is valid over the prior art.
`
`D.
`
`Proposed claim 30 is valid
`
`Xilinx proposes to substitute original independent claim 13 with independent
`
`claim 30. Claim 30 is the same as claim 13, except that it further limits the “fourth
`
`conductive layer” to be a “poly” layer. Consistent with the discussion above with
`
`reference to claim 2, Anthony does not show a shield plate in poly that is part of a
`
`capacitor node.
`
`Further, claim 30 requires a reference shield including a “substrate portion.”
`
`Anthony does not teach a capacitor including mil; a poly layer for a node and a
`
`substrate portion for a reference shield.
`
`Thus for these two reasons, proposed claim 30 is valid over the prior art.
`
`49—
`
`

`

`Patent Owner’s Response
`lPR2012—00023
`
`111. Conclusion
`
`For the reasons discussed above, Xilinx requests that the Motion to Amend
`
`be granted, and that claims 18-34 should be found valid over the prior art. In the
`
`event that the Motion to Amend is not granted, then Xilinx submits that claims 2,
`
`8-9, and 18-19 should be allowed.
`
`Respectfully 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
`
`_20_
`
`Dated: May 7, 2013
`
`Rl320631.3docx
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`

`

`Patent Owner’s Response
`
`IPR2012—00023
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`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 CPR. § 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.
`
`1 100 NEW YORK AVENUE, N.W.
`
`WASHINGTON DC 20005
`
`g?M
`
`David M. O’Dell
`
`Registration No. 42,044
`
`_21_
`
`