Paper No.
`Filed: January 20, 2016
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`HTC Corporation,
`HTC America, Inc.,
`LG Electronics, Inc.,
`Samsung Electronics Co., Ltd., and
`Samsung Electronics America, Inc.
`Petitioner
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`v.
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`Parthenon Unified Memory Architecture LLC
`Patent Owner
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`Case IPR2015-01501
`Patent No. 7,777,753
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`Petitioner’s Request for Rehearing Under 37 C.F.R. § 42.71(d)(1)
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`I.
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`II.
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`Case No. IPR2015-01501
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`Table of Contents
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`INTRODUCTION AND PRECISE RELIEF REQUESTED ......................... 1
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`LEGAL STANDARD ..................................................................................... 1
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`III. STATEMENT OF REASONS FOR RELIEF REQUESTED ........................ 2
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`A.
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`The Institution Decision improperly read in limitations from the
`written description in concluding that the multimedia memory
`160 does not teach or suggest the shared memory of claims 7-
`10 and 12. .............................................................................................. 3
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`B.
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`1.
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`2.
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`Claims 7-10 and 12 do not include a limitation that only
`one single shared memory be present. ........................................ 4
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`Claims 7-10 and 12 do not include a limitation that the
`shared “memory” must be used regularly or all the time
`by the central processing unit. .................................................... 6
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`The Institution Decision misapprehended the claims and
`overlooked Petitioner’s argument in concluding that the Petition
`had not shown “why or how a person of ordinary skill in the art
`would have modified Gulick’s system in view of MPEG to
`provide the recited structures for accessing Gulick’s ‘main
`memory’ or to perform the functions recited for video decoding
`or decompression.” ................................................................................ 7
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`1. Whether “a person of ordinary skill in the art would have
`modified Gulick’s system in view of MPEG to provide
`the recited structures for accessing Gulick’s ‘main
`memory’” is irrelevant because claims 7-10 and 12
`simply require “a memory” and not a “main memory.” ............. 7
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`2.
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`The Institution Decision overlooked Petitioner’s support
`for why “a person of ordinary skill in the art would have
`modified Gulick’s system in view of MPEG … to
`perform the functions recited for video decoding or
`decompression.” .......................................................................... 9
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`IV.
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`Inter partes review of Claims 7-10 and 12 should be instituted based
`on the aforementioned Gulick grounds .........................................................14
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`i
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`Case No. IPR2015-01501
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`Case No. IPR2015—O1501
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`CONCLUSION ..............................................................................................14
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`CONCLUSION ............................................................................................ ..14
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`V.
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`V.
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`ii
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`Case No. IPR2015-01501
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`TABLE OF AUTHORITIES
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` Page(s)
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`Federal Cases
`Apple Inc. v. DSS Technology Management, Inc.,
`IPR2015-00369, Paper No. 14 (August 12, 2015) ............................................... 1
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`Phillips v. AWH Corp.,
`415 F.3d 1303 (Fed. Cir. 2005) (en banc) ............................................................ 3
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`Superguide Corp. v. DirecTV Enterprises, Inc.,
`358 F.3d 870 (Fed. Cir. 2004) .............................................................................. 3
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`Federal Regulations
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`37 C.F.R. § 42.71(c) ................................................................................................... 1
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`37 C.F.R. § 42.71(d) .................................................................................................. 1
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`iii
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`I.
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`Case No. IPR2015-01501
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`INTRODUCTION AND PRECISE RELIEF REQUESTED
`Petitioner1 requests rehearing of the Patent Trial and Appeal Board’s
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`Decision entered January 6, 2016 (“Institution Decision”) denying review of
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`claims 7-10 and 12, which ordered review of claims 1-4 of U.S. Patent No.
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`7,777,753 (“the ’753 patent”). Petitioner specifically requests that the Board
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`reconsider its decision denying inter partes review of claims 7-10 of the ’753
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`patent based on Gulick, MPEG, and Shanley, and of claim 12 of the ’753 patent
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`based on Gulick, MPEG, Shanley, and Gove.
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`II. LEGAL STANDARD
`“A party dissatisfied with a decision may file a request for rehearing.”
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`37 C.F.R. § 42.71(d). “The request must specifically identify all matters the party
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`believes the Board misapprehended or overlooked, and the place where each
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`matter was previously addressed in a motion, an opposition, or a reply.” Id.
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`Institution decisions are reviewed on rehearing for an abuse of discretion.
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`See 37 C.F.R. § 42.71(c). An abuse of discretion occurs when a “decision [i]s
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`based on an erroneous conclusion of law or clearly erroneous factual findings,
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`or . . . a clear error of judgment.” Apple Inc. v. DSS Technology Management, Inc.,
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`1 “Petitioner” refers collectively to HTC Corporation, HTC America, Inc., LG
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`Electronics, Inc., Samsung Electronics Co., Ltd., and Samsung Electronics
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`America, Inc.
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` 1
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`IPR2015-00369, Paper No. 14 at 3 (August 12, 2015) (citing PPG Indus. Inc. v.
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`Case No. IPR2015-01501
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`Celanese Polymer Specialties Co., 840 F.2d 1565, 1567 (Fed. Cir. 1988)).
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`III. STATEMENT OF REASONS FOR RELIEF REQUESTED
`The Institution Decision relied on the following two conclusions in deciding
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`to not institute inter partes review of claims 7-10 and 12:
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`1. “Because multimedia memory 160 exists in addition to main memory
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`110 and because CPU 102 uses multimedia memory 160 only in
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`exceptional circumstances, we are not persuaded that multimedia
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`memory 160 teaches or suggests the shared ‘main memory’ of claim 1 or
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`‘memory’ of claim 7.” Institution Decision at 18.
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`2. “Neither Petitioner nor its declarant explains in sufficient detail why or
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`how a person of ordinary skill in the art would have modified Gulick’s
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`system in view of MPEG to provide the recited structures for accessing
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`Gulick’s ‘main memory’ or to perform the functions recited for video
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`decoding or decompression.” Institution Decision at 20 (emphasis
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`added).
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`Petitioner requests reconsideration of the Institution Decision for two
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`reasons. First, the Institution Decision’s conclusion that “multimedia memory 160
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`[does not] teach[] or suggest[] the shared … ‘memory’ of claim 7” relies on
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`improperly reading into the claims the requirements that there be only one shared
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`2
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`memory in the system and that such a memory be accessed regularly. Second, in
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`concluding that the Petition had not shown that “a person of ordinary skill in the art
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`would have modified Gulick’s system in view of MPEG to provide the recited
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`structures for accessing Gulick’s ‘main memory’ or to perform the functions
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`recited for video decoding or decompression,”
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`the Institution Decision
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`misapprehended that claim 7 merely requires a “memory,” not a “main memory,”
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`and overlooked detailed evidence and argument as to why and how the memory of
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`Gulick would have been modified as claimed.
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`A. The Institution Decision improperly read in limitations from the
`written description in concluding that the multimedia memory
`160 does not teach or suggest the shared memory of claims 7-10
`and 12.
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`
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`It is improper to read in claim limitations from the written description.
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`Superguide Corp. v. DirecTV Enterprises, Inc., 358 F.3d 870, 875 (Fed. Cir. 2004)
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`(“Though understanding the claim language may be aided by explanations
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`contained in the written description, it is important not to import into a claim
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`limitations that are not part of the claim.”); Phillips v. AWH Corp., 415 F.3d 1303,
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`1320 (Fed. Cir. 2005) (en banc) (“one of the cardinal sins of patent law-- reading a
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`limitation from the written description into the claims”). The Institution Decision,
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`however, appears to have done just that in concluding that the multimedia memory
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`160 does not teach the shared memory of claim 7 “because multimedia memory
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`160 exists in addition to main memory 110 and because CPU 102 uses multimedia
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`memory 160 only in exceptional circumstances.” Claim 7 of the ’753 patent does
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`not include limitations that there must be no more than one single shared memory
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`or that the CPU’s access to the memory must be regular or all the time.
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`1. Claims 7-10 and 12 do not include a limitation that only one
`single shared memory be present.
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`Claims 7-10 and 12 require “a memory” that is shared between a central
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`processing unit and a decoder. None of these claims,2 however, include a
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`limitation that there must be no more than one single shared memory. The
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`Institution Decision explains that the specification discusses a single shared
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`memory:
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`“The ’753 patent describes decoder/encoder 80 and a first
`device using a single memory. See, e.g., Ex. 1001, Figs.
`2-4. Gulick, in contrast, describes main memory 110 in
`addition to multimedia memory 160. Ex. 1017, Figs. 1, 4,
`and 6. The system described in Gulick does not,
`therefore, realize the advantage of sharing a single
`memory described by the ’753 patent. Ex. 1001, col. 5, ll.
`13-15, 47-51.” Institution Decision at 17.
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`2 In fact, no ’753 patent claim provides a limitation that there must be only one
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`single shared memory.
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`But interpreting the claims to limit the number of shared memories to no more than
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`one constitutes an improper importation of a limitation from the written
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`description.
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`The claims simply require that at least one memory be shared. Gulick
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`satisfies this claim element because it discloses that “a memory,” which is
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`identified in the Petition as Gulick’s “multimedia memory 160,” is shared by the
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`CPU 102 and multimedia engine 112. For example, as explained in the Petition,
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`“CPU 102 also can execute applications software and driver software from
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`multimedia memory 160 and writes any associated video and audio data to
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`multimedia memory 160.” Petition at 17 (further referenced in IX.A.5.d and
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`IX.A.5.e). In support, the Petition further repeated Gulick’s statement that “[t]hus
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`the multimedia memory 160 is available to store non-multimedia data as needed.
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`Accordingly, the multimedia engine 112 and CPU 102 must also arbitrate for
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`access to the multimedia memory 160.” Ex. 1017, Gulick at 8:2-5 [cited in
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`Petition at 17 (section IX.A.1.e), further referenced in IX.A.5.d and IX.A.5.e.].
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`Furthermore, as explained in the Petition, “the one or more DSP engines 210 in the
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`multimedia engine 112 read the commands and data from the multimedia memory
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`160 and perform the necessary graphics and audio processing 40 functions to
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`generate the appropriate video and audio signals to the video and audio ports 172
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`and 174.” Petition at 13 (section IX.A.1.d), further referenced in IX.A.5.c. (citing
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`Gulick, Ex. 1017 at 7:37-42).
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`2. Claims 7-10 and 12 do not include a limitation that the shared
`“memory” must be used regularly or all the time by the central
`processing unit.
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`Claims 7-10 and 12 simply require that a central processing unit “access” the
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`memory. See, e.g., Ex. 1001, ’753 patent, claim 7 (“a central processing unit
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`coupled to the bus for accessing the memory”). None of these claims3, however,
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`include a limitation that such “access” must be regular or continuous. Even if
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`Gulick’s CPU 102 “accesses” the “multimedia memory 160” only for “overflow
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`memory space,” this is irrelevant. The claims simply require the CPU have access
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`to the “memory.” It is undisputed that Gulick’s CPU 102 accesses Gulick’s
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`multimedia memory 160. See, e.g., Institution Decision at 17 (“Gulick further
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`describes CPU 102 using multimedia memory 160 only
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`in exceptional
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`circumstances, such as when main memory 110 is full.”). Furthermore, as
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`explained in the Petition, “CPU 102 also can execute applications software and
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`driver software from multimedia memory 160 and writes any associated video and
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`audio data to multimedia memory 160.” Petition at 17 (further referenced in
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`IX.A.5.d and IX.A.5.e). See also Id. (citing Gulick, Ex. 1017 at 8:2-5) (“Thus the
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`3 In fact, no ’753 patent claim provides a limitation that access to the memory must
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`be regular or all the time.
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`multimedia memory 160 is available to store non-multimedia data as needed.
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`Accordingly, the multimedia engine 112 and CPU 102 must also arbitrate for
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`access to the multimedia memory 160.”).]. See also Ex. 1017 at 4:36-38 (“[I]f the
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`main memory 110 becomes full and additional memory is needed, the CPU 102
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`can store code and data in the multimedia memory 160.”) (cited in Ex. 1030 at 40,
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`¶ 92 (section VII.A.1.c), referenced in Petition at 12 (section IX.A.1.c), further
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`referenced in IX.A.5.b.).
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`B.
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`The Institution Decision misapprehended the claims and
`overlooked Petitioner’s argument in concluding that the Petition
`had not shown “why or how a person of ordinary skill in the art
`would have modified Gulick’s system in view of MPEG to provide
`the recited structures for accessing Gulick’s ‘main memory’ or to
`perform the functions recited for video decoding or
`decompression.”
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`The Institution Decision misapprehended the claims and overlooked
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`Petitioner’s argument that a person of ordinary skill in the art would have been
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`motivated to combine Gulick with MPEG. First, the Institution Decision
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`misapprehended that claims 7-10 and 12 merely require a “memory,” not a “main
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`memory.” Second, the Institution Decision overlooked support that the Petitioner
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`offered to explain why one of ordinary skill in the art would have been motivated
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`to combine Gulick with MPEG to provide the recited features of these claims.
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`1. Whether “a person of ordinary skill in the art would have
`modified Gulick’s system in view of MPEG to provide the
`recited structures for accessing Gulick’s ‘main memory’” is
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`irrelevant because claims 7-10 and 12 simply require “a
`memory” and not a “main memory.”
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`Unlike claims 1-4 of the ’753 patent, which require a “main memory,”
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`claims 7-10 and 12 simply require a “memory.” Compare Ex. 1001, claim 7 (“7.
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`An electronic circuit for use with a memory”) with Ex. 1001, claim 1 (“1. An
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`electronic system comprising: … a main memory”). However, the Institution
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`Decision appears to have not instituted inter partes review, at least in part, on its
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`conclusion that Petitioner did not explain why “a person of ordinary skill in the art
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`would equate Gulick’s multimedia memory 160 with main memory 110 for
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`purposes of implementing MPEG standards on Gulick’s system.” Institution
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`Decision at 19.
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`To the extent the Institution Decision was based on the conclusion that “a
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`person of ordinary skill in the art would [not] have modified Gulick’s system in
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`view of MPEG to provide the recited structures for accessing Gulick’s ‘main
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`memory’,” (Institution Decision at 20) it misapprehended that claims 7-10 and 12
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`merely require a “memory,” not a “main memory.” Furthermore, the Petition
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`addressed why a person of ordinary skill in the art would have modified Gulick’s
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`system in view of MPEG to provide the recited structures for accessing “a
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`memory,” namely Gulick’s “multimedia memory 160.” For example:
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`• “Gulick 983, in view of MPEG Standard, also discloses multimedia
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`engine 112 (the claimed “decoder”) coupled to memory bus 108 (the
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`claimed ‘bus’) for receiving MPEG-coded video images (the claimed
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`‘encoded video images’) and for outputting MPEG-decoded video
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`images (the claimed ‘decoded video images’) for display on video
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`monitor 114 (the claimed ‘display device’), multimedia engine 112
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`configured
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`to
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`receive data
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`from multimedia memory 160
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`corresponding to at least one MPEG I-picture or P-picture (the
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`claimed ‘previously decoded image’) and to a current MPEG video
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`image to be decoded and outputting an MPEG-decoded current video
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`image to be displayed.” Petition at 29 (emphasis added).
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`• “One of ordinary skill in the art would have recognized that such I-
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`pictures or P-pictures would have been stored in multimedia memory
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`160 in the combined system of Gulick 983 and MPEG Standard in
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`view of the disclosure in Gulick 983 to store similar multimedia data
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`in multimedia memory 160. See Ex. 1030, Stone Decl. at ¶¶ 131-34.”
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`Petition at 29-30 (emphasis added).
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`2. The Institution Decision overlooked Petitioner’s support for
`why “a person of ordinary skill in the art would have modified
`Gulick’s system in view of MPEG … to perform the functions
`recited for video decoding or decompression.”
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`The Institution Decision concluded that Petitioner did not support why “a
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`person of ordinary skill in the art would have modified Gulick’s system in view of
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`MPEG … to perform the functions recited for video decoding or decompression.”
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`Institution Decision at 19-20. However, the Institution Decision overlooks support
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`provided in the Petition for why one of ordinary skill in the art would have
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`modified the multimedia engine 112 to perform MPEG video decoding. Simply
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`put, as explained in the Petition, Gulick’s multimedia engine 112 included the
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`specific circuitry, namely one or more digital signal processors (DSPs), that was
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`commonly used by those of ordinary skill in the art at the time of the alleged
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`invention to provide MPEG decoding functionality.
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`As explained in the Petition, Gulick’s multimedia engine 112 processed
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`multimedia (e.g., video and audio) data:
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`• “The multimedia engine 112 performs video and audio processing
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`functions.” Ex. 1017 at 4:16-18 [cited in Petition at 13 (section
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`IX.A.1.d), referenced in IX.A.5.c; Ex. 1030 at ¶94 (VII.A.1.d),
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`referenced in VII.A.5.c.].
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` As stated in the Petition, Gulick’s multimedia engine 112 included a digital
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`signal processor (DSP) for processing multimedia data:
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`• “In the preferred embodiment shown in FIG. 2, the multimedia engine
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`112 includes one DSP engine 210 which preferably performs video
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`and audio processing functions.” Ex. 1017 at 5:15-18 (emphasis
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`added) [cited in Petition at 13 (section IX.A.1.d), referenced in
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`IX.A.5.c; Ex. 1030 at ¶94 (section VII.A.1.d), further referenced in
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`VII.A.5.c.].
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`• “[T]he one or more DSP engines 210 in the multimedia engine 112
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`read the commands and data from the multimedia memory 160 and
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`perform the necessary graphics and audio processing 40 functions to
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`generate the appropriate video and audio signals to the video and
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`audio ports 172 and 174.” Ex. 1017 at 7:37-42 [cited in Petition at 13
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`(IX.A.1.d), referenced in IX.A.5.c; Ex. 1030 at ¶94 (VII.A.1.d),
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`referenced in VII.A.5.c.].
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`Ex. 1017 at FIG. 2 (showing DSP Engine 210 in multimedia engine
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`112) [shown in Petition at 14 (IX.A.1.d) , 30 (IX.A.5.c); Ex. 1030 at ¶
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`94 (VII.A.1.d), ¶133 (VII.A.5.c).]. See also Ex. 1017 at FIG. 3
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`(showing three DSP engines (e.g., 212, 214, and 216) in multimedia
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`engine 112) [shown in Petition at 30 (IX.A.5.c); Ex. 1030 at ¶ 133
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`(VII.A.5.c).]; Ex. 1017 at FIG. 5 (showing DSP Engine 210 in
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`multimedia engine 112) [shown in Petition at 32 (IX.A.5.e) and 37
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`(IX.B.1.a); Ex. 1030 at ¶ 138 (VII.A.5.e) and ¶ 149 (VII.B.1.a).].
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`Furthermore, the Petition explained that one of ordinary skill would have
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`been further motivated to modify Gulick’s multimedia engine 112, which included
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`a DSP, to perform MPEG decoding because “it was well known in the art at the
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`time of the alleged invention to employ a DSP for MPEG video processing. See
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`Ex. 1017, 5:15-21; Ex. 1007, 1:62-67, Fig. 5.” Petition at 16 (section IX.A.1.d);
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`see also Petition at 29-30 (section IX.A.5.c). See also Petition at 24 (“For the
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`reasons described in Section IX.A.1.d, it would have been obvious for Gulick
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`983’s DSP engine 210 within multimedia engine 112 to be further modified with
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`these teachings of MPEG Standard, and for multimedia memory 160 to be used to
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`store the previously decoded MPEG video images used for subsequent MPEG
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`decoding.”) (emphasis added).
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`To further support this, the Petition included the following:
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`• “[T]he one or more DSP engines 210 in the multimedia engine 112
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`read the commands and data from the multimedia memory 160 and
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`perform the necessary graphics and audio processing 40 functions to
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`generate the appropriate video and audio signals to the video and
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`audio ports 172 and 174.” Ex. 1017 at 7:37-42 (emphasis added)
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`[cited in Petition at 13 (section IX.A.1.d), referenced in IX.A.5.c; Ex.
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`1030 at ¶ 94 (section VII.A.1.d), further referenced in VII.A.5.c.].
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`• “[T]he MPEG accelerator circuit which is a dedicated digital signal
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`processor for video decompression.” Ex. 1007 at 6:56-57 (emphasis
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`added) [cited in Ex. 1030 at ¶102 (section IX.A.1.d), further
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`referenced at 59 (¶131) in VII.A.5.c, referenced in Petition at 16 (“see
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`also Ex. 1030, Stone Decl. ¶¶ 101-02.”); see also Petition at 29-30
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`(“One of ordinary skill in the art would have recognized that such I-
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`pictures or P-pictures would have been stored in multimedia memory
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`160 in the combined system of Gulick 983 and MPEG Standard in
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`view of disclosure in Gulick 983 to store similar multimedia data in
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`multimedia memory 160. See Ex. 1030, Stone Decl. at ¶¶ 131-34.”).]
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`• “[D]igital system chip 112 also preferably includes a general purpose
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`DSP engine 206 which is programmable to perform various functions
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`such as MPEG decoding”) Ex. 1023 at 20-22 (emphasis added) [cited
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`in Ex. 1030 at ¶102 (section VII.A.1.d), further referenced at 59
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`((¶131) in VII.A.5.c., referenced in Petition at 16 (“see also Ex. 1030,
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`Stone Decl. ¶¶ 101-02.”); see also Petition at 29-30 (“One of ordinary
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`skill in the art would have recognized that such I-pictures or P-
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`pictures would have been stored in multimedia memory 160 in the
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`combined system of Gulick 983 and MPEG Standard in view of
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`disclosure in Gulick 983 to store similar multimedia data in
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`multimedia memory 160. See Ex. 1030, Stone Decl. at ¶¶ 131-34.”).].
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`IV.
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`Inter partes review of Claims 7-10 and 12 should be instituted based on
`the aforementioned Gulick grounds
`As explained in the Institution Decision, inter partes review of claims 8-10
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`and 12, which are claims dependent on claim 7, were not instituted for the same
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`reasons as described above. See, e.g., Institution Decision at 20-21. Therefore,
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`Petitioner requests that the Board institute inter partes review of claims 7-10 of the
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`’753 patent based on Gulick, MPEG, and Shanley and claim 12 of the ’753 patent
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`based on Gulick, MPEG, Shanley, and Gove.
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`V. CONCLUSION
`For the foregoing reasons, Petitioner requests that the Board institute inter
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`partes review of claims 7-10 of the ’753 patent based on Gulick, MPEG, and
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`Shanley and claim 12 of the ’753 patent based on Gulick, MPEG, Shanley, and
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`Respectfully submitted,
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`By: /Allan M. Soobert/
`Allan M. Soobert
`Reg. No. 36,284
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`Counsel for Petitioner
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`Gove.
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`Dated: January 20, 2016
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), I certify that I caused to be served on the
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`counsel for Petitioner a true and correct copy of the foregoing Petitioner’s Request
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`for Rehearing Under 37 C.F.R. § 42.71(d)(1) by electronic means on the date
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`below at the following address of record:
`
`Masood Anjom (manjom@azalaw.com)
`Alisa Lipski (alipski@azalaw.com)
`Amir Alavi (aalavi@azalaw.com)
`Ahmad, Zavitsanos, Anaipakos, Alavi & Mensing P.C.
`1221 McKinney, Suite 3460
`Houston, TX 77010
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`Respectfully submitted,
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`
`
`By: /Allan M. Soobert/
`Allan M. Soobert
`Reg. No. 36,284
`
`Counsel for Petitioner
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`
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`Dated: January 20, 2016