Patent No. 7,296,121
`IPR2015-00158
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`SONY CORPORATION; SONY ELECTRONICS INC.;
`SONY MOBILE COMMUNICATIONS AB; AND
`SONY MOBILE COMMUNICATIONS (USA) INC.
`Petitioners
`v.
`
`MEMORY INTEGRITY, LLC
`Patent Owner
`
`U.S. Patent No. 7,296,121
`
`
`
`Inter Partes Review Case No. 2015-00158
`
`
`
`MEMORY INTEGRITY, LLC’S REPLY IN SUPPORT OF
`MOTION TO AMEND PURSUANT TO 37 C.F.R. § 42.121
`
`
`
`
`IPR2015-00158
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`SONY CORPORATION; SONY ELECTRONICS INC.;
`SONY MOBILE COMMUNICATIONS AB; AND
`SONY MOBILE COMMUNICATIONS (USA) INC.
`Petitioners
`v.
`
`MEMORY INTEGRITY, LLC
`Patent Owner
`
`U.S. Patent No. 7,296,121
`
`
`
`Inter Partes Review Case No. 2015-00158
`
`
`
`MEMORY INTEGRITY, LLC’S REPLY IN SUPPORT OF
`MOTION TO AMEND PURSUANT TO 37 C.F.R. § 42.121
`
`
`
`
`
`Patent No. 7,296,121
`IPR2015-00158
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`
`TABLE OF CONTENTS
`
`I. MI’S MOTION COMPLIED WITH THIS BOARD’S REQUIREMENTS ......... 1
`
`A. MI Properly Relied on the Effective Filing Date of the '347
`Application .............................................................................................. 1
`
`B. MI’s Expert Adequately Analyzed and Discussed the Prior Art ............ 2
`
`C. The Proposed Substitute Claims are Supported by the Disclosure ......... 7
`
`II. THE SGI ORIGIN SYSTEM IS DISTINGUISHABLE ...................................... 8
`
`III. CONCLUSION .................................................................................................. 12
`
`
`
`
`
`
`
`i
`
`
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`Patent No. 7,296,121
`IPR2015-00158
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`EXHIBIT LIST
`
`Description
`Declaration of Vojin Oklobdzija, Ph.D. in Support of
`Patent Owner’s Replies in Support of Motions to
`Amend
`
`
`
`ii
`
`
`
`2042
`
`Exhibit No.
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`
`
`
`
`
`
`TABLE OF AUTHORITIES
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`Patent No. 7,296,121
`IPR2015-00158
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` Page(s)
`
`Cases
`
`Apple, Inc. v. Memory Integrity, LLC,
`
`Case No. IPR2015-00172, Paper No. 16 at (May 11, 2015) ................................. 9
`
`Idle Free Sys., Inc. v. Bergstrom, Inc.,
`
`Case No. IPR2012-00027, Paper No. 26 (PTAB Jun. 11, 2013) ........................... 6
`
`In re Koller,
`
`613 F.2d 819 (CCPA 1980) ................................................................................... 2
`
`International Flavors & Fragrances Inc. v. The United States of America,
`
`Case NO. IPR2013-00124, Paper No. 12 (PTAB May 20, 2014) ......................... 7
`
`REG Synthetic Fuels LLC v. Neste Oil OYJ,
`
`Case No. No. IPR2014-00192, Paper No. 48 (PTAB Jun. 5, 2015) ...................... 3
`
`Regulations
`
`37 C.F.R. § 1.57(c) ..................................................................................................... 1
`
`37 C.F.R. § 42.53(d)(5)(ii). ........................................................................................ 8
`
`M.P.E.P. § 608.1(p)(2)(B) (9th Ed., ER9-07.2015, Oct. 2015) ................................. 2
`
`M.P.E.P. § 608.1(p)(I)(B) (8th Ed., Rev. 2., May 2004) ........................................... 1
`
`iii
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`
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`
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`Petitioners argue that the present motion to amend should be denied. Each
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`of Petitioners’ arguments lack merit, as discussed below.
`
`I. MI’S MOTION COMPLIED WITH THIS BOARD’S REQUIREMENTS
`Petitioners argue that MI’s motion to amend failed to comply with this
`
`Board’s requirements for a motion to amend. Each of Petitioners’ arguments fail.
`
`A. MI Properly Relied on the Effective Filing Date of the '347
`Application
`
`First, Petitioners argue that it was improper for MI to rely on the effective
`
`filing date of the ’347 Application in analyzing the proposed substitute claims.
`
`Opp. at 2-3. In particular, Petitioners argue that proposed substitute claims 27-341
`
`are not supported because they “require[] multiple incorporation by references” of
`
`“essential material.” Id. (citing to 37 C.F.R. § 1.57(c)). Thus, Petitioners argue MI
`
`should have expressly addressed Koster. Opp. at 2-3.
`
`However, under the rules of the Patent Office, both now and at the time the
`
`application for the ’121 Patent was filed, the limitations on multiple incorporation
`
`by reference “do not apply to applications relied on only to establish an earlier
`
`effective filing date under 35 U.S.C. 119 or 35 U.S.C. 120.” M.P.E.P.
`
`§ 608.1(p)(I)(B) (8th Ed., Rev. 2., May 2004); M.P.E.P. § 608.1(p)(2)(B) (9th Ed.,
`
`
`1 Petitioners do not dispute that this argument is irrelevant to proposed substitute
`
`claim 26 in IPR2015-00159, did not rely on such material.
`
`
`
`1
`
`
`
`ER9-07.2015, Oct. 2015). In particular, the rules provide that “[i]ncorporation by
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`reference in the earlier application of . . . a U.S. patent or application which itself
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`incorporates ‘essential material’ by reference . . . is not critical in the case of a
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`‘benefit’ application.” Id. Thus, MI was entitled to rely on multiple incorporation
`
`by reference in establishing that the proposed substitute claims are entitled to the
`
`priority of the filing date of the ’347 Application, and there was no need to offer
`
`opinions expressly discussing later prior art references, including Koster.2
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`B. MI’s Expert Adequately Analyzed and Discussed the Prior Art
`Secondly, Petitioners argue that MI’s motion fails because MI “fails to even
`
`mention, much less explain, why the claims are patentable over the” SGI Origin
`
`system. Opp. at 3. However, there is no requirement in filing a motion to amend
`
`that the Patent Owner include a separate express, discussion or opinion of every
`
`piece of prior art of record or otherwise known to the Patent Owner. See REG
`
`
`2 To the extent that Petitioners also argue that multiple incorporation by reference
`
`renders the proposed substitute claims invalid for lack of written description (as
`
`opposed to priority), that argument fails because original claims 17-25 of the ’161
`
`Application as filed are identical to claims 16-24 as issued, and provide support for
`
`the allegedly essential material. Ex. 1002 at 57-60 ; In re Koller, 613 F.2d 819,
`
`823-24 (CCPA 1980) (original claims constitute their own description).
`
`
`
`2
`
`
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`Synthetic Fuels LLC v. Neste Oil OYJ, No. IPR2014-00192, Paper No. 48 at 19-20
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`Patent No. 7,296,121
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`(PTAB Jun. 5, 2015) (granting motion to amend, and rejecting argument that
`
`Patent Owner was required to expressly distinguish certain known references).
`
`Indeed, in many cases, as here, there are dozens of pieces of prior art of record, Ex.
`
`1001 (references cited), and thus it would be impossible to file a motion to amend
`
`which complied with this Board’s page limitations and restrictions on
`
`incorporation of arguments while presenting a separate express discussion of each
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`piece of prior art. There was no particular reason to believe that, at the time MI’s
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`motion was filed, that the SGI Origin system was of particular importance. Ex.
`
`2042 ¶ 8. Indeed, that system was merely discussed in one section of a multi-
`
`hundred page textbook. Ex. 1020 (citing Ex. 1017 at 596-622). MI’s expert
`
`performed the required review and analysis of the prior art, and it was not one of
`
`the references that he identified as the most material (and therefore requiring
`
`express discussion). Ex. 2019 ¶ 11; Ex.2042 ¶ 8. Certainly, as REG Synthetic
`
`Fuels demonstrates, a patent owner does not fail to comply with its initial burden
`
`in filing a motion to amend simply because a petitioner can identify a new prior art
`
`system among the sea of prior art, or that a petitioner’s expert disagrees with the
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`patent owner’s expert regarding the weight and importance of the prior art or what
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`are the most material references in the prior art. Moreover, as discussed below,
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`there are material differences between the SGI Origin reference and the proposed
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`
`
`3
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`
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`substitute claims.
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`Similarly, Petitioners’ argument that “MI did not identify that the Pong and
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`Koster references disclosed the newly proposed coherent and non-coherent
`
`interface limitation in the substitute claims” also lacks merit. Opp. at 3. MI’s
`
`expert analyzed the coherent and non-coherent interface limitation of the proposed
`
`substitute claims, compared it to the prior art as a whole, and opined that they do
`
`“not teach having a coherent protocol interface and a non-coherent protocol
`
`interface, and certainly does not teach coupling them to a probe filtering unit.” Ex.
`
`2019 ¶¶ 11, 13; Ex. 2042. ¶¶ 4-6. Moreover, MI’s expert identified a reference
`
`“which [he] believe[s] reflects the state of the art of coherent and non-coherent
`
`interfaces” and explained why it did not practice the newly added limitations. Ex.
`
`2019 ¶ 12; Ex. 2042 ¶ 5.
`
`Furthermore, Petitioners’ arguments that Pong and Koster teach these
`
`limitations are meritless. As discussed above, MI was entitled to rely on the
`
`effective filing date of the ’347 Application for the substitute claims, obviating any
`
`need to discuss Koster. Moreover, neither Koster nor Pong discuss a probe
`
`filtering unit coupled to coherent and non-coherent interfaces. Ex. 2042 ¶ 5.
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`Indeed, Petitioners merely point out that Pong and Koster have “a path from
`
`controller to main memory.” Opp. at 3. But, Petitioners’ arguments rely on
`
`misconstruing MI’s expert’s testimony—he did not testify that every “path to main
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`
`
`4
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`
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`memory” is a non-coherent interface. Ex. 2042 ¶ 6. Rather, Petitioners posed an
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`incomplete, “hypothetical” example of “a system with a probe filtering unit, and it
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`has paths going to cache memory, and then it has a separate path going to main
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`memory.” Id. MI’s expert’s response simply indicated which of those paths could
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`be a non-coherent interface in that incomplete hypothetical, assuming that the
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`system possessed both coherent and non-coherent interfaces. Id.
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`Contrary to Petitioners’ argument that MI “admit[s]” that every memory
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`path is a non-coherent interface, MI proposed that a “non-coherent protocol
`
`interface” be construed as “an interface for communicating with components in a
`
`computer system without regard to maintaining cache coherency.” Mot. at 16; Ex.
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`1016 at 88:12-13. Petitioners have not challenged that construction. Nothing in
`
`Koster or Pong teaches that the path between the controller and the main memory
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`in their respective systems satisfies that construction. Indeed, neither reference
`
`discusses non-coherent operations at all. Ex. 2042 ¶ 5. Pong describes itself as
`
`directed to “asynchronous cache coherence method and a multiprocessor system
`
`that employs an asynchronous cache coherence protocol” and identifies a single
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`cache-coherent “Memory Control Path.” Id. If Pong and Koster did support both
`
`coherent and non-coherent operations, nothing suggests that are performed by
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`physically or logically separate coherent and non-coherent interfaces, as opposed
`
`to a single, shared coherent/non-coherent interface. Id. ¶¶ 5-6.
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`
`
`5
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`
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`Sony Petitioners in the -158 IPR complain that MI failed to provide
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`testimony as to the “significance and usefulness of the feature(s) added.”
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`IPR2015-00158, Paper No. 26 at 3-4. However, that is not a mandatory
`
`requirement. Idle Free Sys., Inc. v. Bergstrom, Inc., Case IPR2012-00027, Paper
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`No. 26 at 7 (PTAB Jun. 11, 2013) (“patentable distinction can rely on . . .
`
`testimony . . . about the significance and usefulness of the feature(s) added.”)
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`(emphasis added). Moreover, in explaining how the prior art failed to teach those
`
`interfaces, MI’s expert pointed out the deficiencies in the prior art. Ex. 2019 ¶ 12
`
`(pointing out that prior art which “reflects the state of the art” teaches that it
`
`“cannot participate in coherence actions when it is attached to the I/O bus”) .
`
`Petitioners also criticize the amount of time that MI’s expert spent on
`
`reviewing the prior art. However, Petitioners misconstrue MI’s expert’s testimony.
`
`MI’s expert testified that he spent “in excess of 60 hours” working on the present
`
`inter partes reviews. Ex. 2042 ¶ 3. His testimony as to “five hours” and “10
`
`hours” was referring to specific categories of prior art, and, in particular, did not
`
`include, for example, his review of the specific prior art that is the subject of the
`
`pending IPRs. Id. Moreover, as he explained, “there is a large body of – of
`
`material,” so he “focused on what [he] found relevant, and [] skipped quickly over
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`those that [he] didn't.” Ex. 1016 at 22:24-23:2.
`
`Finally, Petitioners criticize MI’s expert’s declaration for not expressly
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`
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`6
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`
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`stating the legal standards he applied. Opp. at 4. No such requirement exists in
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`this Board’s rules. Indeed, this Board has granted motions to amend based on a
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`short, two-page declaration which did not recite any legal standard. International
`
`Flavors & Fragrances Inc. v. The United States of America, IPR2013-00124,
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`Paper No. 12 at 12 (PTAB May 20, 2014) (citing Ex. 2005). Also, Dr. Oklobdzija
`
`provided competent testimony demonstrating that he understood and applied the
`
`relevant legal standards. Ex. 1026 at 28:2-31:16; Ex. 1027 at 188:17-192:11.
`
`C. The Proposed Substitute Claims are Supported by the Disclosure
`Patent Owner’s motion to amend identified specific portions in the intrinsic
`
`record providing support for the proposed substitute claims. Mot. at 1-10. Despite
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`this, Petitioners argue that these limitations are not supported. Opp. at 5.
`
`However, Petitioners present no expert testimony that the proposed substitute
`
`claims are not enabled or described. Additionally, plainly contrary to the
`
`Petitioners’ argument that MI “provides no details for how” “non-coherent
`
`protocol interface” “is implemented,” the cited passage explains that it is
`
`“implemented either as a full crossbar or as a separate receive and transmit units.”
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`Mot. at 10 (citing ’161 App. At 13:11-17); see also Ex. 2006 (’347 App.) at 12:4-
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`10 (reciting the same passage). Petitioners also complain that “MI’s expert could
`
`not fix these §112 problems during his deposition,” but MI did not proffer any
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`expert testimony regarding whether the substitute claims had 112 support. Instead,
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`
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`7
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`
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`MI simply identified those portions of the specification which plainly describe
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`those features. Mot. at 1-11; Ex. 2042 ¶ 7. Thus, the questions to Dr. Oklobdzija
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`regarding enablement and written description of the proposed substitute claims
`
`were outside the scope of his direct testimony and should be disregarded. 37
`
`C.F.R. § 42.53(d)(5)(ii). Moreover, even if Dr. Oklobdzija’s testimony on this
`
`point were relevant, his testimony is that the claims are enabled and described, and
`
`that the specification provided sufficient implementation details so that one of skill
`
`in the art could implement the invention. Ex. 2042 ¶ 7. Thus, Petitioners have
`
`failed to dispel MI’s showing that the substitute claims have section 112 support.
`
`II. THE SGI ORIGIN SYSTEM IS DISTINGUISHABLE
`Finally, Petitioners argue that the proposed substitute claims are
`
`unpatentable over the Culler and Laudon references, and in particular, the SGI
`
`Origin system described in those references. However, SGI Origin is plainly
`
`distinguishable from the proposed substitute claims on a number of grounds.
`
`As a threshold issue, the SGI Origin reference has an architecture that is plainly
`
`inconsistent with that of the proposed substitute claims. Notably, Petitioners claim
`
`that the SGI Origin “hub” is the “probe filtering unit” of the substitute claims.
`
`However, Petitioners are vague as to whether the Origin’s “hub” is part of the
`
`claimed “processing nodes” or whether the “hub” is separate from the claimed
`
`“processing nodes.” If the “hub” were part of a “processing node,” then the SGI
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`
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`8
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`
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`Origin system would be plainly inconsistent with the claims which require that the
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`“probe filtering unit” “receive probes . . . from the processing nodes.” (emphasis
`
`added). Ex. 2042 ¶¶ 9-10. Additionally, if the “hub” were part of a “processing
`
`node,” then, given SGI Origin’s speculative access to main memory, the home
`
`node/hub would be a processing node to which the received probe is always
`
`“transmitted” without being “selected.” Ex. 2042 ¶ 11; see also Apple, Inc. v.
`
`Memory Integrity, LLC, No. IPR2015-00172, Paper No. 16 at 12-14 (May 11,
`
`2015) (denying institution due to similar deficiency in a different reference’s
`
`“directory board of the home cluster”).
`
`On the other hand, if SGI’s Origin “hub” is not deemed subsumed within the
`
`claimed “processing node,” then the “hub” is not a “probe filtering unit [] operable
`
`to receive probes . . . from” a plurality of “processing nodes,” because the hub
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`receives the alleged “probe” from another hub, not from a processing node. Ex.
`
`2042 ¶¶ 12. Moreover, there is nothing to suggest that what is sent by a requesting
`
`processor in Origin is even the same as what is received by the hub at the home
`
`node (such that one could argue that the hub is indirectly receiving a “probe”
`
`“from” a processing node). Id. ¶ 13. Indeed, although the references do not
`
`discuss the specific format of the messages in SGI Origin, they strongly suggest
`
`that it is not the same message. Id. They teach that the processor connects to the
`
`hub via a “SysAD” bus, whereas the “hub” connects to other hubs via a “Craylink”
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`
`
`9
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`
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`network interface. Id. Additionally, the hub chip has significant logic between
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`these interfaces which, among other things, “hides the processors from the rest of
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`the world, so any other interface must only know the behavior of the PI [processor
`
`interface] and not of the processor and SysAD bus themselves.” Id. The
`
`messaging between hubs is also significantly different from the messaging within
`
`hubs: “[t]he router and the Hub internals use different transport formats protocols,
`
`and speeds.” Id. Moreover, the processor is ignorant as to details of the cache
`
`coherence protocol and cache coherence messages (which are instead left to the
`
`hub), and there is not even a one-to-one relationship between the processor’s
`
`outgoing messages and the outgoing messages from the hub. Id. Also, Culler
`
`teaches away from the recited structure, stating that isolating the processors in this
`
`way is beneficial. Ex. 1017 at 615 (describing this “shield[ing]” as “a key property
`
`of the design” ), at 617 (“[t]he processor itself does not have to be modified.”).
`
`Furthermore, the references demonstrate that the SGI Origin system does not
`
`have a “plurality of processing nodes interconnected by a first point-to-point
`
`architecture.” The ’121 Patent expressly states that, “[i]n a point-to-point
`
`architecture,” there are “multiple processors directly connected to each other
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`through point-to-point links.” ’121 Pat. at 4:38-40 (emphasis added); Ex. 2042 ¶
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`14. But, within a local node in SGI Origin, individual processors are connected to
`
`each other and to the hub chip by a “SySAD bus.” Ex. 2042 ¶ 14. A shared bus is
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`10
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`not a point-to-point architecture. Id. Moreover, processors in separate nodes in the
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`SGI Origin are not directly connected to each other, as required by the substitute
`
`claims and the express teachings of the ’121 Patent. Rather, the processors are
`
`connected through, inter alia, at least two hub chips (one for each node), which
`
`“hide[] [each] processor from the rest of the world, so any other interface must
`
`only know the behavior of the [hub chip’s] PI [processor interface] and not of the
`
`processor and SysAD bus themselves.” Id.3 Additionally, the communication
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`between a hub chip and its processor, the communication within a hub chip, and
`
`the communication in the network between hub chips all involve “different data
`
`transport formats protocols, and speeds.” Id. Again, Culler teaches away, stating
`
`that this indirect connection of the processors is beneficial. Ex. 1017 at 615, 617.
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`Finally, the SGI Origin system does not teach having a “probe filtering unit
`
`[which] is coupled to a coherent protocol interface and a non-coherent protocol
`
`interface.” Ex. 2042 ¶ 15. It appears that Petitioners and their experts are making
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`an inherency argument as to this limitation. Ex. 1020 ¶ 7. Neither reference states
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`that the hub is connected to both coherent and non-coherent protocol interfaces.
`
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`3 This does not mean that mere presence of some physical components between
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`processors is inconsistent with them being directly interconnected by a point-to-
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`point architecture. Ex. 2042 ¶ 14 n. 4.
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`
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`11
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`Ex. 2042 ¶ 15. Although Culler describes the hub as having a number of
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`interfaces, neither Petitioners nor their expert identify any one of those interfaces
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`as being the claimed coherent protocol interface or the claimed non-coherent
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`protocol interface. Id. Rather, Petitioners’ expert argues that the fact that “both a
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`processor and a Hub in the SGI Origin architecture are capable of communicating
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`coherent messages (e.g., cache misses) and noncoherent messages (e.g., uncached
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`I/O operations)” “mean[s] that each contains a ‘coherent protocol interface’ and
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`‘non-coherent protocol interface.’” Ex. 1020 ¶ 7. But, nothing suggests that SGI
`
`Origin uses separate coherent and non-coherent protocol interfaces as opposed to
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`shared coherent/non-coherent interfaces, i.e. handling both coherent and non-
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`coherent messages without any physical or logical separation of interfaces. Ex.
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`2042 ¶ 15. Such a shared interface is not, e.g., “an interface for communicating
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`with components in a computer system without regard to maintaining cache
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`coherency.” Id. Moreover, Culler actually suggests that SGI Origin’s I/O interface
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`processes both coherent and non-coherent transactions. Id.
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`III. CONCLUSION
`For the foregoing reason, Patent Owner respectfully requests that Patent
`
`Owner’s conditional motion to amend be granted.
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`
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`12
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`Date: December 31, 2015
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`Patent No. 7,296,121
`IPR2015-00158
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`Respectfully submitted,
`
`
`
`/Michael D. Saunders/
`Michael D. Saunders
`Admitted Pro Hac Vice
`Farney Daniels PC
`411 Borel Avenue, Suite 350
`San Mateo, California 94402
`Phone: 424-268-5210
`
`E-mail: msaunders@farneydaniels.com
`
`
`
`13
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`CERTIFICATE OF SERVICE
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`Patent No. 7,296,121
`IPR2015-00158
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`Under 37 C.F.R. §§ 42.6(e), this is to certify that I served a copy of the
`
`foregoing MEMORY INTEGRITY, LLC’S REPLY IN SUPPORT OF MOTION
`
`TO AMEND PURSUANT TO 37 C.F.R. § 42.121, along with the accompanying
`
`exhibit(s) via email on December 31, 2015 to Petitioners’ counsel of record at the
`
`following email addresses:
`
`Walter E. Hanley, Jr., Reg. No. 28,720
`Zaed M. Billah, Reg. No. 71,418
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004
`Phone: 212-425-7200
`Fax: 212-425-5288
`Email:
`MemoryIntegrityv.Sony10760-225@kenyon.com
`whanley@kenyon.com
`zbillah@kenyon.com
`
`
`Dated: December 31, 2015
`
`
`
`
`
`/Michael D. Saunders/
`Michael D. Saunders
`Admitted Pro Hac Vice
`
`
`
`14
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