Inter Partes Review of
`U.S. Patent Nos.
`6,445,645 and 6,385,128
`IPR2014-00426 and IPR2014-00427
`GSI Technology, Inc. (“GSI”)
`Petitioner
`v.
`Cypress Semiconductor Corporation (“Cypress”)
`Patent Owner
`
`Petitioner GSI Technology, Inc.’s Demonstratives
`Oral Hearing: April 14, 2015
`
`1
`
`
`U.S. Patent Nos.
`6,445,645 and 6,385,128
`IPR2014-00426 and IPR2014-00427
`GSI Technology, Inc. (“GSI”)
`Petitioner
`v.
`Cypress Semiconductor Corporation (“Cypress”)
`Patent Owner
`
`Petitioner GSI Technology, Inc.’s Demonstratives
`Oral Hearing: April 14, 2015
`
`1
`
`
`
`Overview of Petitioner’s Positions
`
`’645 Patent
`• Claims 1‐3 anticipated by Ono
`• Claims 1‐3 obvious in view of Ono and Yamauchi
`
`’128 Patent
`• Claims 1‐4 anticipated by Ono
`• Claims 1‐4 obvious in view of Ono and Yamauchi
`
`2
`
`
`
`US Patent Nos.
`6,445,645 and 6,385,128
`
`‘645 patent , Ex. 1001 at Cover Page
`(IPR2014‐00426)
`
`‘128 patent, Ex. 1001 at Cover Page
`(IPR2014‐00427).
`
`3
`
`
`
`’645 and ’128 Patents: Overview
`
`‘645 patent , Ex. 1001 at Abstract,
`Figures 2, 5 (IPR2014‐00426)
`
`4
`
`
`
`Claims of ’645 and ’128 Are Similar
`
`‘645 patent , Ex. 1001 (IPR2014‐
`00426)
`
`Both patents cover transferring
`data on both edges of a clock
`signal.
`
`‘128 patent , Ex. 1001 (IPR2014‐
`00427)
`
`5
`
`
`
`PTAB’s Claim Construction Rulings
`
`“in response to”
`
`Claim Term
`
`“transferring…data bits either to or from a…random
`address”
`“periodic signal”
`
`“read/write control signal”
`“complementary”/”complementary signal”
`
`“independent”
`
`Constructions Adopted by the Board
`“initiated as a result of” – Board agreed with
`Patent Owner that requiring direct causation
`would be improper
`No construction adopted.
`
`“any signal that has an oscillating waveform,
`the frequency of which may be predicted
`and/or controlled in accordance with
`techniques known in the art, and that can be
`configured to control one or more circuit
`functions performed as part of a read
`operation or a write operation
`“periodic signal”
`“opposite”/”separate signal that is opposite the
`first signal”
`“structure having separate data ports”
`
`6
`
`
`
`Japanese Publication JP 64-043894A (Ono)
`
`Ono, Cover Page, Ex. 1005 (IPR2014‐00426)
`
`7
`
`
`
`Japanese Publication JP 64-043894A (Ono)
`
`Ono, Figs. 1‐2, Ex. 1005 (IPR2014‐00426)
`
`8
`
`
`
`Ono Anticipates Claim 1 of the ’645
`
`‘645 patent , Ex. 1001 (IPR2014‐
`00426)
`Ono discloses transferring data in
`response to rising edge of CLK1 and
`rising edge of CLK2.
`
`Figure 2, Ex. 1005 (IPR2014‐00426)
`
`Figure 1, Ex. 1005 (IPR2014‐00426)
`
`9
`
`
`
`Ono Anticipates Claim 1 of the ’645
`
`The rising edge of CLK1 and the rising edge of CLK2 are complementary
`transitions:
`
`Figure 2, Ex. 1005 (IPR2014‐00426)
`
`Ono also teaches using the rising edge and falling edge of ONE clock signal
`instead of the rising edges of CLK1 and CLK2:
`
`Ex. 1005 at 614, right col. ll. 25‐28 (IPR2014‐00426)
`
`Figure 1, Ex. 1005 (IPR2014‐00426)
`
`10
`
`
`
`Ono Discloses “Independently”
`Transferring Data Required by Claim 1
`
`“independent”
`
`Claim Term
`
`Constructions Adopted by the Board
`“structure having separate data ports”
`
`Write Data Port
`
`Read Data Port
`
`11
`
`
`
`Cypress’s Arguments Are Inconsistent
`
`• Cypress insists that Ono does not disclose transferring data in response to CLK1 and CLK2
`because the pipeline control circuit is initiating the data transfers. Paper 15 at 21‐23
`(IPR2014‐00426).
`• This is contrary to Cypress’s own argument in its preliminary response. In its Decision, the
`Board agreed with Cypress that “in response to” should not require direct causation.
`
`Decision, Paper 7 at 4 (IPR2014‐00426).
`
`12
`
`
`
`Ono Anticipates Claims 2-3 of the ’645
`
`13
`
`
`
`Ono Anticipates Claim 1 of the ’128
`
`‘128 patent , Ex. 1001 (IPR2014‐
`00427)
`
`Ono discloses transferring data in
`response to rising edge of CLK1
`rising edge of CLK2.
`
`Figure 2, Ex. 1005 (IPR2014‐00426)
`
`Figure 1, Ex. 1005 (IPR2014‐00426)
`
`14
`
`
`
`Ono Anticipates Claim 2 of the ’128
`
`15
`
`
`
`Ono Anticipates Claim 3 of the ’128
`
`‘128 patent , Ex. 1001 (IPR2014‐
`00427)
`
`Ono discloses transferring data in
`response to rising edge of CLK1
`rising edge of CLK2.
`
`Figure 2, Ex. 1005 (IPR2014‐00426)
`
`Figure 1, Ex. 1005 (IPR2014‐00426)
`
`16
`
`
`
`Ono Anticipates Claim 4 of the ’128
`
`17
`
`
`
`If PTAB Finds Ono Does Not Anticipate,
`Then All Claims in ’645 and ’128 Are Rendered
`Obvious by Ono and Yamauchi
`
`18
`
`
`
`All Claims Rendered Obvious by Ono and
`Yamauchi
`
`Yamauchi teaches performing read and
`write operations alternately upon every
`rising and falling edge of ECLK/ICLK.
`
`…
`
`Yamauchi, Figure 5, Ex. 1007 (IPR2014‐00426)
`
`Yamauchi, Figure 7 and 9:37‐63, Ex. 1007 (IPR2014‐00426)
`
`19
`
`
`
`All Claims Rendered Obvious by Ono and
`5
`Yamauchi
`All claims are rendered obvious by using both edges of one clock as taught by
`Yamauchi instead of the rising edges of CLK1 and CLK2 as taught by Ono.
`(As discussed previously, Ono itself also teaches using both edges of one clock.)
`
`Ono, Figure 1, Ex. 1005 (IPR2014‐00426)
`
`Yamauchi, Figure 5, Ex. 1007 (IPR2014‐00426)
`
`
`
`All claims at issue in these IPRs are
`anticipated or rendered obvious.
`
`‘645 patent , Ex. 1001 (IPR2014‐
`00426)
`
`‘128 patent , Ex. 1001 (IPR2014‐
`00427)
`
`21
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies service pursuant to 37 C.F.R. 37 C.F.R. §§ 42.6(e)
`
`and 42.105(b) on the Patent Owner by electronic mail a copy of Petitioner’s
`
`Demonstrative Exhibits.
`
`David M. Hoffman
`Fish & Richardson
`111 Congress Avenue, Suite 810
`Austin, Texas 78701
`Email: hoffman@fr.com
`
`Thomas L. Halkowski
`Fish & Richardson
`222 Delaware Avenue, 17th Floor
`Wilmington, Delaware 19899
`Email: halkowski@fr.com
`
`Email: IPR13276-0030IP1@fr.com
`Email: IPR13276-0031IP1@fr.com
`
`
`
`Dated: April 9, 2015
`
`
`
`
`/s/ Brent Yamashita
`Brent K. Yamashita
`Registration No. 53,808
`
`DLA PIPER LLP (US)
`2000 University Avenue
`East Palo Alto, CA 94303-2214
`Telephone: 650.833.2348
`Facsimile: 650.833.2001
`
`
`
`
`
`
`
`
`1
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
