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Paper No. 24
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`TOSHIBA CORPORATION
`Petitioner
`
`
`v.
`
`INTELLECTUAL VENTURES II LLC
`Patent Owner
`____________________
`
`Case No. IPR2014-00418
`Patent 5,500,819
`
`____________________
`
`
`
`
`
`PETITIONER TOSHIBA CORPORATION’S
`DEMONSTRATIVE EXHIBITS
`
`Mail Stop “Patent Board”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandra, VA 22313-1450
`
`WEST\258354545.1
`
`

`
`
`
`
`
`
`Case IPR2014-00418
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that a true copy of the foregoing PETITIONER
`
`TOSHIBA CORPORATION’S DEMONSTRATIVE EXHIBITS was served
`
`electronically via e-mail on May 1, 2015, in its entirety on the following:
`
`Lori A. Gordon
`Email: lgordon-PTAB@skgf.com
`
`Michael D. Specht
`Email: mspecht-PTAB@skgf.com
`
`Christian A. Camarace
`Email: ccamarace-PTAB@skgf.com
`
`Donald J. Coulman
`Email: dcoulman@intven.com
`
`Tim R. Seely
`Email: tim@intven.com
`
`May 1, 2015
`
` /Gianni Minutoli/
`Gianni Minutoli
`Registration No. 41,198
`
`DLA PIPER LLP (US)
`11911 Freedom Drive, Suite 300
`Reston, Virginia 20190-5602
`Phone: (703) 773-4045
`Fax: (703) 773-5064
`
`Lead Counsel for Petitioner
`
`
`Dated:
`
`
`
`
`WEST\258354545.1
`
`
`
`1
`
`
`
`

`
`Inter Partes Review of
`U.S. Patent No. 5,500,819
`IPR2014-00418
`
`Toshiba Corporation
`Petitioner
`v.
`Intellectual Ventures II LLC
`Patent Owner
`
`Petitioner Toshiba Corporation’s Demonstratives
`
`Oral Hearing: May 6, 2015
`
`Petitioner Toshiba Corporation – TOSH-1010 1
`
`

`
`Instituted Ground
`
`• Claims 1-11 and 17-19 – Obvious over
`Ogawa ‘577 (Ex. 1003), Ogawa ‘045 (Ex. 1005), and
`JP ‘832 (Ex. 1006)
`
`Institution Decision (Paper 7) at 19
`
`Petitioner Toshiba Corporation – TOSH-1010 2
`
`

`
`’819 Patent Specification
`
`1:5-10 (Cited in Petition at 3)
`
`2:50-64 (Cited in Paper 7 at 3-4)
`
`Goals: improve page accesses
`and block transfers
`
`To achieve these goals, the
`specification discloses a
`memory comprising:
`• an array of memory cells
`• address decode circuitry
`• sense amplifiers
`• control circuitry
`
`Petitioner Toshiba Corporation – TOSH-1010 3
`
`

`
`’819 Patent Specification
`
`2:50-64 (Cited in Paper 7 at 3-4)
`
`The disclosed memory also
`comprises:
`• “At least two sets of
`latching circuitry,” each
`“coupled to the master
`sense amplifiers”
`
`Petitioner Toshiba Corporation – TOSH-1010 4
`
`

`
`’819 Patent Specification
`
`Figure 2 (Cited in Petition at 3-4)
`
`Petitioner Toshiba Corporation – TOSH-1010 5
`
`

`
`’819 Prosecution History: Applicant’s Remarks
`
`Ex. 1002 at 59 (’819 File History – Applicant’s Response to Office Action)
`(Cited in Reply at 3)
`
`Petitioner Toshiba Corporation – TOSH-1010 6
`
`

`
`’819 Patent – Claim 1
`
`•
`•
`
`Challenged claim 1
`“Control circuitry” only
`required to “control
`writing of said data
`through the master
`read/write circuitry to a
`second row in the array
`• No limitation requiring
`“said data” to be written
`to the second row in the
`array from the same
`slave circuitry to which it
`was transferred
`
`Petitioner Toshiba Corporation – TOSH-1010 7
`
`Claim 1 (Cited in Reply at 2-3)
`
`

`
`’819 Patent – Claim 17
`
`•
`•
`
`Challenged claim 17
`Because claim 18 recites
`shifting “the data”
`within the slave sense
`amplifiers as a substep
`of writing the data to
`different cells in the
`array, there can be no
`limitation that “the data”
`be written to the array
`from the same slave
`sense amplifiers where
`the data was latched
`
`Petitioner Toshiba Corporation – TOSH-1010 8
`
`Claim 17 (Cited in Reply at 2-3)
`
`

`
`Patent Owner’s Argument
`
`Patent Owner argues:
`“The disclosed memory
`system ‘advantageously
`provide[s] for efficient block
`moves/copies of data within
`memory’ by using the same
`bank of slave circuitry—e.g.,
`slave sense amplifiers bank
`210.”
`
`7:51-67 (Cited in Patent Owner Response at 2)
`
`Patent Owner Response at 4
`
`However, the challenged claims do not recite the limitations of the
`cited embodiment. Absent a clear indication of intent, it is improper
`to import un-recited limitations from an embodiment into the claims.
`
`Reply at 4-6
`
`Petitioner Toshiba Corporation – TOSH-1010 9
`
`

`
`Ogawa ’577 (claims 1, 17)
`
`Ogawa ’577 discloses:
`•
`“a memory”
`•
`“an array of rows and columns of
`volatile memory cells”
`
`Petition at 13 (claim [1Pre], [1a])
`
`Ogawa ’577 discloses “a memory
`including an array of memory cells
`arranged in rows and columns, each
`said row associated with a conductive
`wordline and each said column
`associated with a conductive bitline”
`
`Petition at 28 (claim [17Pre])
`
`Petitioner Toshiba Corporation – TOSH-1010 10
`
`Ex. 1003 at Fig. 2 (Cited in Petition at 13, 28)
`
`

`
`Ogawa ’577 (claims 1, 17)
`
`Ogawa ’577 discloses “addressing
`circuitry for providing access to
`selected ones of said memory cells”
`
`Petition at 13-14 (claim [1b])
`
`Ogawa ’577 discloses “selecting a row
`in the array”
`
`Petition at 29 (claim [17a])
`
`Petitioner Toshiba Corporation – TOSH-1010 11
`
`Ex. 1003 at Fig. 6 (Cited in Petition at 14, 29)
`
`

`
`Ogawa ’577 (claims 1, 17)
`
`Ex. 1003 at Fig. 2 (Cited in Petition at 14-15, 29)
`
`Ogawa ’577 discloses “master
`read/write circuitry for reading and
`writing data into said selected ones of
`said cells”
`
`Petition at 14-15 (claim [1c])
`
`Ogawa ’577 discloses “sensing the
`bitlines of the array to read data stored
`in the cells of the selected row with a
`bank of master sense amplifiers”
`
`Petition at 29 (claim [17b])
`
`Petitioner Toshiba Corporation – TOSH-1010 12
`
`

`
`Ogawa ’577 (claim 1)
`
`Ex. 1003 at Fig. 2 (Cited in Petition at 15)
`
`Ogawa ’577 discloses “first slave
`circuitry for storing data for exchange
`with said master read/write circuitry”
`
`Petition at 15 (claim [1d])
`
`Ogawa ’577 discloses “second slave
`circuitry for storing data for exchange
`with said master read/write circuitry”
`
`Petition at 15 (claim [1e])
`
`Petitioner Toshiba Corporation – TOSH-1010 13
`
`

`
`Ogawa ’577 (claim 1)
`
`Ex. 1003 at Fig. 2 (Cited in Petition at 15-16)
`
`Ogawa ’577 inherently discloses
`“control circuitry for controlling
`exchange of data between said master
`read/write circuitry and said first and
`second slave circuitry”
`
`Petition at 15-16 (claim [1f])
`
`Petitioner Toshiba Corporation – TOSH-1010 14
`
`

`
`Ogawa ’577 (claim 1)
`
`Ex. 1003 at Fig. 2 (Cited in Petition at 16-17)
`
`Ogawa ’577 inherently discloses control
`circuitry to “control sensing by said
`master read/write circuitry of
`data from a said row in said array
`selected by said addressing circuitry”
`
`Petition at 16-17 (claim [1g])
`
`Petitioner Toshiba Corporation – TOSH-1010 15
`
`

`
`Ogawa ’577 (claims 1, 17)
`
`Ogawa ’577 inherently discloses control
`circuitry to “control transfer of said data
`from said master read/write circuitry to
`a selected one of said first and second
`slave circuitry”
`
`Petition at 17 (claim [1h])
`
`Ogawa ’577 discloses “latching the data
`read from the cells of the selected row
`in a bank of slave sense amplifiers”
`
`Ex. 1003 at Fig. 2 (Cited in Petition at 17, 30)
`
`Petition at 30 (claim [17c])
`
`Petitioner Toshiba Corporation – TOSH-1010 16
`
`

`
`Ogawa ’577 (claims 1, 17)
`
`The combination of Ogawa ’577 with
`Ogawa ’045 discloses control circuitry
`to “control writing of said data through
`said master read/write circuitry to a
`second said row in said array selected
`by said addressing circuitry”
`
`Petition at 17-25 (claim [1i])
`
`The combination of Ogawa ’577 with
`Ogawa ’045 discloses “writing the data
`stored in the slave sense amplifiers
`through the master sense amplifiers to
`different cells in the array”
`
`Petition at 30 (claim [17d])
`
`Petitioner Toshiba Corporation – TOSH-1010 17
`
`Ex. 1003 at Fig. 2 (Cited in Petition at 18, 30)
`
`

`
`Writing “Through” a Sense Amplifier
`
`Ex. 1008 at 6:47-62 (Cited in Reply at 9)
`
`Patent Owner does not dispute that it
`was well known to write data to a
`memory array “through” a sense
`amplifier. In fact, Patent Owner’s
`Expert, Dr. Huber, is a named inventor
`of a 1981 patent that discloses writing
`data to memory through a sense
`amplifier.
`
`Reply at 9
`
`Petitioner Toshiba Corporation – TOSH-1010 18
`
`

`
`Ogawa ’577 (claim 19)
`
`Ex. 1003 at 4:6-18 (Cited in Petition at 37)
`
`The combination of Ogawa ’577, Ogawa
`’045 and JP ’832 discloses the method of
`claim 17, wherein “said step of writing
`comprises the step of writing data from the
`slave sense amplifiers to cells of a different
`row in the array”
`
`Petition at 37 (claim 19)
`
`Petitioner Toshiba Corporation – TOSH-1010 19
`
`

`
`JP ’832 (claim 7)
`
`Ex. 1006 at Fig. 1 (Cited in Petition at 37-51)
`
`Claim 7 (Cited in Petition at 37-51)
`
`Petitioner Toshiba Corporation – TOSH-1010 20
`
`

`
`Conclusion
`
`•
`
`Claims 1-11 and 17-19 of the ’819 patent are invalid as
`obvious over Ogawa ’577 in combination with one or more
`of Ogawa ’045 and JP ’832
`
`Reply at 15
`
`Petitioner Toshiba Corporation – TOSH-1011 21

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