Paper No.
`
`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 IPR201 2-00023
`
`Patent 7,994,609
`
`Title: SHIELDING FOR INTEGRATED CAPACITORS
`
`PATENT OWNER’S PRELIMINARY RESPONSE
`
`BY XILINX, INC. UNDER 37 C.F.R. §§ 42.107
`
`
`
`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 IPR201 2-00023
`
`Patent 7,994,609
`
`Title: SHIELDING FOR INTEGRATED CAPACITORS
`
`PATENT OWNER’S PRELIMINARY RESPONSE
`
`BY XILINX, INC. UNDER 37 C.F.R. §§ 42.107
`
`
`
`Patent Owner’s Preliminary Response
`IPR2012-00023
`
`TABLE OF CONTENTS
`
`Introduction ............................................................................................................. .. 3
`
`I.
`
`Critical Failures in the Petition ....................................................................... .. 3
`
`A. Ground 1 Fails For Neglecting To Address An Explicit Statement That
`Teaches-Away From the Proposed Obviousness Combination .......................... .. 3
`
`Prior Art Must be Considered In Its Entirety, Including Disclosures
`1.
`That Teach Away From the Claims ................................................................ .. 4
`
`Paul Teaches Separate Embodiments ofa Capacitor, including those
`2.
`in FIGS. 8 and I3 ............................................................................................ .. 4
`
`3.
`
`Paul Teaches Not to Combine the Embodiments of FIGS. 8 and 13 ...... .. 6
`
`B. Grounds 2-4 Fail for the Same Reason as Ground 1 .................................. .. 7
`
`C. Ground 5 Fails For Not Considering All Claim Elements ......................... .. 8
`
`I. A Capacitor is Formed ofa First Plate and a Second Plate .................... .. 8
`
`2. Anthony shows a Different Type of Shielded Capacitor ........................ .. 9
`
`IVM Fails to Show a Capacitor that Reads Upon the Claim Language
`3.
`including a Second Plate ofthe Capacitor formed in a Substrate ................. ..
`
`D.
`
`IVM Failed to Identify All Real Parties in Interest .................................. ..
`
`I
`
`l
`
`I
`
`I
`
`II. Conclusion ..................................................................................................... .. 16
`
`Certificate of Service ............................................................................................. .. 17
`
`
`
`Patent Owner’s Preliminary Response
`IPR2012—00023
`
`INTRODUCTION
`
`Patent Owner Xilinx, Inc. (“Xilinx”) submits the following preliminary
`
`response to the Petition filed by Intellectual Ventures Management (“IVM”) on
`
`September 17,2012 requesting inter partes review of claims 1-19 ofU.S. Patent
`
`No. 7,994,609 (the “’609 Patent”). The Petition proposes six different Grounds of
`
`rejections. As will be shown below, several of these proposed Grounds are legally
`
`deficient, and should not be adopted in the present proceeding.‘ Furthermore, and
`
`as also shown below, IVM has not fully and completely identified the real party in
`
`interest, and for this reason alone, Xilinx respectfully requests that the Board
`
`decline to institute inter partes review of the ’609 patent.
`
`1.
`
`Critical Failures in the Petition
`
`There are several critical failures in the Petition, addressed separately below.
`
`Ground 1 Fails For Neglecting To Address An Explicit Statement
`A.
`That Teaches-Away From the Proposed Obviousness Combination
`
`IVM asserts, as to Ground 1, that Claims 1, 3, 5, 6, and 10-12 are obvious
`
`under 35 U.S.C. § 103(a) by U.S. Patent No. 6,737,698 to Paul et al. (“Paul”).
`
`Specifically, IVM claims that the combination oftwo different embodiments of
`
`Paul renders the challenged claims obvious. As explained below, however, Paul
`
`explicitly states n_ot to combine these two embodiments, making a finding of
`
`1 Xilinx will address the merits of all of the Grounds that are adopted for the
`present proceeding in its Patent Owner Response.
`
`_3_
`
`
`
`Patent Owner’s Preliminary Response
`IPR20l2—00023
`
`obviousness highly unlikely, especially since lVM’s petition does not acknowledge
`
`or address this teaching in Paul. Moreover, Paul was cited and considered during
`
`the original prosecution of the ’609 patent. Thus, no trial is warranted because
`
`IVM’s Petition fails to establish a likelihood of success on Ground 1.
`
`Prior Art Must be Considered In Its Entirety, Including
`1.
`Disclosures That Teach Away From the Claims
`
`The above heading for the present section of this response is the same as the
`
`heading for MPEP 2141.03.Vl, which states the fundamental legal principal that “a
`
`prior art reference must be considered in its entirety, i.e., as a whole, including
`
`portions that would lead away from the claimed invention.” Id., citing W.L. Gare
`
`& Associates, Inc. v. Gar/ock, Inc., 721 F.2d 1540 (Fed. Cir. 1983).
`
`In the W.L.
`
`Gore case, the Court reversed the district court’s finding of obviousness because
`
`the district court “disregarded” the fact that the prior art taught against the
`
`combination. Id. at 1550-1551. As will be shown below, the Petitioner did not
`
`address the prior art (Paul) as a whole, and has thus failed this fundamental
`
`principal of establishing an obviousness rejection under 35 U.S.C. § lO3(a).
`
`Paul Teaches Separate Embodiments ofa Capacitor,
`2.
`including those in FIGS. 8 and 13
`
`The claims ofthe ‘609 patent are directed to a capacitor with a unique
`
`shielding arrangement. Paul teaches several types ofshielded capacitors, all of
`
`which are different from the claims ofthe ’609 patent. One embodiment of Paul is
`
`
`
`Patent Owner’s Preliminary Response
`IPR20l2—0OO23
`
`provided in FIG. 8 and illustrates a capacitor and shields, as annotated below. The
`
`shields of the capacitor of FIG. 8 are connected to “node A” or “node B”, which
`
`are nodes of the capacitor?
`
`shieldsg ’
`\‘
`
` ’
`
`~ capacitor
`
`FIG. 13 shows another embodiment having, capacitor and shields, as annotated
`
`below.
`
`The Petition relies on yet another embodiment of Paul, FIG. 1 2, to support its
`2
`contention that the bottom plate 810 can be connected to node A rather than node
`B.
`
`
`
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`
`Patent Owner’s Preliminary Response
`IPR2OI2—O0023
`
`§
`
`‘ \
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`ca acitor
`
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`
`FIG. 13
`
`In this Figure 13 embodiment, the shields are connect to ground and not to the
`
`nodes of the capacitors. It is noted that the top shield and bottom shield of both
`
`embodiments are formed on METAL 1 layer and METAL 4 layer respectively.
`
`3.
`
`Paul Teaches Not to Combine the Embodiments of FIGS. 8
`
`and 13
`
`Paul teaches that the embodiment of FIG. 13 is an alternative embodiment to
`
`that of FIG. 8:
`
`The shields of the present invention may take on numerous
`
`forms in addition to the examples described above.
`
`FIG. 13
`
`shows an example of a capacitor 1300 where the top and
`
`bottom shields 1308 and 1310 are connected to a third node,
`
`shown in this example as reference voltage (e.g., ground) rather
`
`than to nodes A or B [as shown in FIG. 8].
`
`
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`Patent Owner’s Preliminary Response
`IPR2012—00O23
`
`Paul at 4:60-64. Thus, Paul teaches when applying a shield connected to a
`
`reference voltage, one does not apply a shield connected to a node of the
`
`capacitor.3 The Petition does not address this language at all.
`
`This teaching applies with full force to IVM’s attempt to assert two separate
`
`Paul embodiments against the ’609 patent. Here, Paul teaches two embodiments
`
`and further teaches that they should not be combined. But IVM ignores this
`
`teaching, and combines them anyway. This is not a proper basis for finding a
`
`claim obvious, particularly where the examiner already evaluated the prior art
`
`during prosecution. Thus, the Petition relies on an improper obviousness
`
`combination that cannot demonstrate a reasonable likelihood that any claim is
`
`unpatentable. No trial should be ordered as to Ground 1.
`
`B.
`
`Grounds 2-4 Fail for the Same Reason as Ground 1
`
`As a foundational basis for Grounds 2, 3, and 4 ofthe Petition, IVM relies
`
`on its disclosures presented in Ground 1 of the Petition without providing any
`
`teachings that would cure the defects noted above for Ground 1. (Petition at 23-
`
`44.) Because ofthis reliance, IVM fails to demonstrate a reasonable likelihood
`
`that any claim is unpatentable. No trial should be ordered as to Grounds 2-4.
`
`Merriam—Webster defines “rather than” as “to indicate negation as a
`3
`contrary choice. . .,” “and not,” and “instead of.” http://www.merriam-
`webster.com/dictionary/rather%20than.
`
`_7_
`
`
`
`Patent Owner’s Preliminary Response
`IPR2012—O0023
`
`C.
`
`Ground 5 Fails For Not Considering All Claim Elements
`
`IVM asserts, as to Ground 5, that Claims 18 and 19 are obvious under 35
`
`U.S.C. § l03(a) by U.S. Patent No. 7,439,570 to Anthony (“Anthony”) in view of
`
`U.S Patent No. 7,238,981 to Marotta (“Marotta”). IVM asserts that the
`
`combination of the capacitor of Anthony with the “gate dielectric layer” of Marotta
`
`renders the challenged claims obvious. Notably, Anthony was also considered
`
`during the original prosecution ofthe ’609 patent.
`
`As explained below, the Board should reject IVM’s Petition because it fails
`
`to show that the asserted combination has a secondplate ofa capacitor formed in a
`
`substrate as required by claim 18.
`
`1.
`
`A Capacitor is Formed ofa First Plate and a Second Plate
`
`A capacitor having a first plate and a second plate with a dielectric
`
`interposing the plates is well—known in the art. See, e.g., ’609 patent at 1:43—52.
`
`The ’609 patent includes a novel configuration of such a capacitor including the
`
`configuration ofthe shielding elements. The ’609 patent provides an embodiment
`
`that illustrates claims 18-19 in its FIG. 4B, reproduced and annotated below.
`
`
`
`Patent Owner’s Preliminary Response
`IPR20l2—00O23
`
`shield - _
`
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`
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`
`424
`
`Specifically, FIG. 4B illustrates a capacitor with “a conductive well 422 in the
`
`substrate 424 as a first plate of the capacitor. .. [and a] second plate
`
`426.” ’609
`
`patent at 10:28-31.
`
`In other words, the capacitor is formed by an overlying
`
`conductive layer as a first plate and a doped region ofa substrate as a second plate.
`
`2.
`
`Anthony shows a Different Type of Shielded Capacitor
`
`IVM relies on FIG. 4 of Anthony as reading on the claimed capacitor
`
`structure including the first and second plates. Petition at 45-46. FIG. 4 of
`
`Anthony is reproduced and annotated below.
`
`
`
`Patent Owner’s Preliminary Response
`IPRZO 12-00023
`
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`Anthony states that the capacitor 30 is formed by “plates 33 and 34” and
`
`“terminals 31 and 32.” 4:35-38. These plates are formed in “additional layers of
`
`metal.” 4:3-4. The capacitor 30 of FIG. 4 is shielded by features including the
`
`diffused layer 46. Anthony at 4:66—5:2.
`
`In other words, Anthony’s capacitor in
`
`FIG. 4 has a first plate and a second plate where both plates are formed of metal
`
`layers overlying the substrate. This is different than the challenged claims of
`
`the’609 patent, which require one plates to be made from substrate, not metal.
`
`
`
`Patent Owner’s Preliminary Response
`
`IPR2012—0O023
`
`IVM Fails to Show a Capacitor that Reads Upon the Claim
`3.
`Language including a Second Plate of the Capacitor formed in a
`Substrate
`
`IVM alleges that the substrate plate ofthe claimed capacitor is provided by
`
`the diffused layer 46 illustrated in FIG. 4 of Anthony. Petition at 45-46. This is a
`
`misreading of Anthony—as described above, Anthony specifically teaches that its
`
`capacitor 30 is provided by plates 34 and 33, neither of which is formed in the
`
`substrate as recited in claims 18-19. Moreover, diffused region 46 does not
`
`perform the function of a second plate ofa capacitor; its function is to shield the
`
`capacitor 30, which is formed by overlying metal plates. Thus, IVM is trying to
`
`use something that is not a capacitor plate to satisfy a claim element. This is not a
`
`viable obviousness argument.
`
`‘‘If proposed modification would render the prior art
`
`invention being modified unsatisfactory for its intended purpose, then there is no
`
`suggestion or motivation to make the proposed modification.” MPEP 2143.V.
`
`citing In re Gordon, 733 F.2d 900 (Fed. Cir. 1984).
`
`IVM has thus failed to
`
`establish a likelihood of success on Ground 5 and no trial is warranted or required.
`
`D.
`
`IVM Failed to Identify All Real Parties in Interest
`
`Finally, IVM’s Petition should be denied because it fails to identify all ofthe
`
`real parties in interest as required by 37 C.F.R. § 42.8(b)(1). The requirement to
`
`disclose the real parties—in—interest serves the dual purpose of“assisting courts in
`
`identifying potential conflicts and to assure proper application of the statutory
`
`_1]_
`
`
`
`Patent Owner’s Preliminary Response
`IPR2012—00O23
`
`estoppel provisions.”4 IVM’s decision to identify itself as the sole real party in
`
`interest frustrates both of these purposes.
`
`It is well-known that IVM is part ofa complex web of companies with a
`
`“penchant for secrecy.”5 Those who have attempted to understand IVM’s financial
`
`interests have located over 1200 related entities.(’ IVM is also known to have a
`
`variety of“investors,” although the nature ofthese relationships varies widely.
`
`While some investors may have a purely financial stake in IVM and its associated
`
`shell companies, other companies are believed to have patent licensing
`
`arrangements with IVM.7 Additionally, IVM provides patents to companies
`
`engaged in litigation through a program termed “IP for Defense.”8 Thus, the
`
`known range ofIVM “investor” relationships is quite broad, and coupled with
`
`IVM’s acknowledged “penchant for secrecy,” the true and complete range of
`
`relationships is likely even broader.
`
`The little information that is publicly available about IVM’s financial and
`
`management structure merely raises more concerns about the inadequacy of its
`
`real—party—in—interest disclosure.
`
`In litigation, IVM has been reluctant to identify
`
`the individuals who owned and controlled it——even pursing a Motion to Seal rather
`
`4 Patent Trial Practice Guide § l.D.l.
`5 Tom Ewing & Robin Feldman, “The Giants Among Us,” 2012 STAN. TECH. L.
`REV. 1,1] 14, n. 6 (XLNX—20O1).
`‘’ Id., 11 25.
`7 1d,, 11 47.
`*‘ 1a’., W 49-50.
`
`_12_
`
`
`
`Patent Owner’s Preliminary Response
`IPR2012-00023
`
`than allow an opponent’s general counsel to review IVM’s list of interested
`
`parties.9 Yet when IVM and certain associated entities eventually revealed their
`
`owners, the federal district courtjudge recused herself from the case because ofa
`
`potential conflict of interest”)
`
`The rule that forced lVM’s disclosure in litigation——Federal Rule of Civil
`
`Procedure 7.1—- exists for the same reason as the requirement to identify the real
`
`party in interest. Specifically, it is of paramount importance that the judges on the
`
`Patent Trial and Appeal Board not be tainted by the appearance of conflict from
`
`having a financial interest in the outcome ofthe cases under their review:
`
`For example, “in the case of the Board, a conflict would
`
`typically arise when an official has an investment in a company
`
`with a direct interest in a Board proceeding. Such conflicts can
`
`only be avoided if the parties promptly provide information
`
`necessary to identify potential conflicts.” See Rules of Practice
`
`for Trials Before the Patent Trial and Appeal Board and Judicial
`
`Review of Patent Trial and Appeal Board Decisions, 77 FR
`
`9 lVM’s motion was itselfsealed and is not publicly available. See XLNX-2002 at
`15, Xilinx, Inc. v. Invention Investment Fund I LP, Case No. 5-1 1-cv-00671, Dkt.
`45 [Administrative Motion to File Under Seal Defendants’ Certificate of Interested
`Entities or Persons Pursuant to Civil Local Rule 3-16 and F.R.C.P. 7.1] (N.D. Cal.
`Apr. 12, 201 1). However, the declaration of IVM’s counsel is available and shows
`that IVM pursued its motion when Xilinx insisted that its general counsel should
`be allowed to see IVM’s list ofinterested parties. See XLNX-2003 at 2,
`Declaration of Bradford J. Black, Xilinx v. Invention Investment, Case No. 5-1 1-cv-
`
`00671, Dkt. 45-2 (N.D. Cal. Apr. 14,2011).
`10 XLNX-2005, Xilinx, Inc. v. Invention Investment Fund I LP, Case No. 5-1 l-cv-
`00671, Dkt. 93 (N.D. Cal. Mar. 14, 2012).
`
`213.
`
`
`
`Patent Owner’s Preliminary Response
`IPR2012—00023
`
`48612, 48617 (Aug. 14, 2012). Like administrative patent
`
`judges at
`
`the Board, “[p]atent examiners are quasi—judicial
`
`officials.” Western Elec. Co., Inc. v. Piezo Tech, Inc., 860 F.2d
`
`428, 431 (Fed. Cir. 1988) (citing Butterworth v. United States
`
`ex rel. Hoe, 112 U.S. 50, 67 (1884)). Accordingly, a clear
`
`identification of the real-party—in— interest is important to ensure
`
`that officials are able to recuse themselves in view of any
`
`conflict—of—interest apparent from the disclosure.
`
`In addition,
`
`“[t]he identity of a real party in interest might also affect the
`
`credibility of evidence presented in a proceeding.” 77 FR at
`
`48617."
`
`Reviewing IVM’s Rule 7.1 Certificate of Interest Entities (XLNX-2004)
`
`further confirms that IVM is not the only real party in interest in this proceeding.
`
`In total, 63 entities are listed as have an interest in IVM or one of its associated
`
`defendants. Several entities are listed as having a “non—f1nancia1 interest in the
`
`outcome ofthe litigation.” Other entities have a “Financial and non—f1nancial
`
`interest” in IVM itself. There is no explanation ofthe nature ofthese “financial”
`
`and “non-financial” interests. Nor is there any explanation ofthe relationships
`
`between and among IVM and various other, similarly named entities (all joined
`
`together as defendants) such as “Intellectual Ventures LLC,” “Intellectual Ventures
`
`H Notice of Roundtable on Proposed Requirements for Recordation of Real—Party—
`in-Interest Information Throughout Application Pendency and Patent Term, 77
`FED. REG. 70385, 70386-87 (Nov. 26, 2012).
`
`-14-
`
`
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`Patent Owner’s Preliminary Response
`IPR2012—O0O23
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`I LLC,” and “Invention Investment Fund I LP.” All ofthese IVM—reIated entities
`
`(and IVM itself) share all of their counseI——and have no separate counsel—
`
`suggesting that their interests are fully aligned.
`
`IVM failed to disclose even the investors that it has already revealed in its
`
`Certificate oflnterest Entities (XLNX—2004), who are fairly seen as “real parties in
`
`interest” in this matter.
`
`In fairness to the Board and to Xilinx, the Petition should
`
`be denied or dismissed for non—compliance with 37 C.F.R. § 42.8(b)(l).
`
`_15_
`
`
`
`Patent Owner’s Preliminary Response
`IPR20 1 2—00023
`
`II.
`
`Conclusion
`
`Because the Petition fails to demonstrate a reasonable likelihood that any of
`
`the claims challenged in Grounds 1-5 are invalid, inter partes review of the ’609
`
`Patent based on these Grounds should be denied. Also, because the Petition fails
`
`to fully and completely identify the real party in interest, the trial as a whole should
`
`be denied.
`
`Dated:
`
`December 19 2012
`
`R.32063 l .3docx
`
`Respectfully submitted,
`
`/DAVID M. O’DELL/
`
`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
`
`_16_
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Patent Owner’s Preliminary Response
`IPR20l2—00023
`
`INTELLECTUAL VENTURES MANAGEMENT, LLC
`V.
`
`Patent ofXlLINX, INC.
`
`Case IPR20l2—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 December 19, 2012
`
`Manner ofservice First Class Mail
`
`Documents served Preliminary Patent Owner Response;
`
`Xilinx’ Exhibit List; and
`
`Exhibits: XLNX-2001 through XLNX—2005
`
`Persons served STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`1 100 NEW YORK AVENUE, N.W.
`WASHINGTON DC 20005
`
`/DAVID M. O’DELL/
`
`David M. O’Dell
`
`Registration No. 42,044
`
`_]’7_
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