SMART EXHIBIT 1003
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`SMART EXHIBIT 1003
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`SMART EXHIBIT 1003
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`AMENDED INFRINGEMENT CHART
`
`Patent:
`Patent Claim(s)
`
`U.S. Patent No. 6,243,315
`1
`
`Company:
`
`SMART MODULAR TECHNOLOGIES INC. (“SMART
`MODULAR”)
`
`PRODUCTS CONSIDERED
`
`1.
`2.
`3.
`
`DDR2 (all versions)
`DDR3 (all versions)
`DDR4 (all versions)
`
`PRELIMINARY DISCUSSION
`
`Memory systems incorporating DDR2, DDR3, and DDR4 memory products infringe
`claim 1 of the ‘315 Patent; and there are substantially no non-infringing uses of DDR2, DDR3,
`and DDR4 memory products. Nor are these memory products staples in commerce. Smart
`Modular tests the memory products for compliance with the JEDEC Specifications, and to collect
`data for marketing the memory products. Hence, Smart Modular “adds” the components for
`direct infringement.
`
`The respective designation of the memory products as “DDR2", “DDR3", and “DDR4"
`means that the respective products comply with the JEDEC STANDARDS: See DDR2 SDRAM
`SPECIFICATION (JESD79-2F), under the heading, “NOTICES” stating “No claims to be in
`conformance with this standard may be made unless all requirements stated in the standard are
`met”. See DDR3 SDRAM STANDARD (JESD79-3F) and DDR3 SDRAM STANDARD
`(JESD79-3F) for the same statement under “NOTICES”.
`
`Thus, any additional company designations in addition to DDR2, DDR3, and DDR4 does
`not alter the obligation of Smart Modular to comply with the JEDEC standards.
`
`Copies of the above identified JEDEC Specifications have already been supplied on a
`disk served on Smart Modular.
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`Page 1 of 5
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`SMART EXHIBIT 1003 - PAGE - 1
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`The Federal Circuit has recently stated:
`
`We hold that a district court may rely on an industry standard in
`analyzing infringement. If a district court construes the claims and
`finds that the reach of the claims includes any device that practices
`a standard, then this can be sufficient for a finding of infringement.
`We agree that claims should be compared to the accused product to
`determine infringement. However, if an accused product operates
`in accordance with a standard, then comparing the claims to the
`standard is the same as comparing the claims to the accused
`product. Fujitsu Limited et al. v. Netgear Inc., 620 F. 3d 1312
`(Fed. Cir. 20110)
`
`Hence, it is only necessary to compare the DDR2, DDR3, and DDR4 memory products
`with the added equipment used by Smart Modular to the respective JEDEC Standards to show
`direct infringement.
`
`CLAIM CHART AND ASSOCIATED CONSTRUCTION
`U.S. Patent No. 6,243,315
`SMART MODULAR PRODUCTS
`Claim 1. A memory system for use in a
`SMART MODULAR manufactures DDR2,
`computer system, said memory system
`DDR3, and DDR4 memory products for use
`comprising:
`in memory systems such as computers, and
`similar devices. Incorporating one of the
`memory products into a computer and similar
`devices adds the claim components to the
`memory products to create the memory
`system according to claim 1.
`
`Smart Modular sometimes adds words or
`codes to the designation of its memory
`products; however, the use of the respective
`designations of DDR2, DDR3, and DDR4
`requires the memory products to comply with
`the respective JEDEC Specifications.
`
`This chart is for the memory system created
`when Smart Modular tests the respective
`memory products.
`
`Page 2 of 5
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`SMART EXHIBIT 1003 - PAGE - 2
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`a plurality of volatile solid state memory
`devices that retain information when an
`electrical power source is applied to said
`memory devices within a predetermined
`voltage range and
`
`For DDR2, see JEDEC, No. 79-2F, Section
`2.4, Table 3 showing four banks of memory
`which under the doctrine of equivalents is a
`plurality of memory devices, and Section 6
`for the predetermined voltage range.
`
`For DDR3, see JEDEC, No 79-3F, Section
`2.11, Tables showing eight banks of memory
`which under the doctrine of equivalents is a
`plurality of memory devices, and Section 8
`for the predetermined voltage range.
`
`For DDR4, see JEDEC, No. 79-4, Section
`3.2, showing sixteen banks of memory which
`under the doctrine of equivalents is a plurality
`of memory devices, and Section 7 for the
`predetermined voltage range.
`
`capable of being placed in a self refresh
`mode;
`
`For DDR2, see JEDEC, No. 79-2F, Sections
`3.10 and 3.11.
`
`For DDR3, see JEDEC, No 79-3F, Section
`4.15.
`
`For DDR4, see JEDEC, No. 79-4, Sections
`4.27.
`
`said memory devices having address lines and
`control lines;
`
`For DDR2, see JEDEC, No. 79-2F, Section
`2.3.
`
`For DDR3, see JEDEC, No 79-3F, Section
`2.10.
`
`For DDR4, see JEDEC, No. 79-4, Sections
`2.6.
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`Page 3 of 5
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`SMART EXHIBIT 1003 - PAGE - 3
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`a control device for selectively electrically
`isolating said memory devices from
`respective address lines and respective control
`lines so that when said memory devices are
`electrically isolated, any signals received on
`said respective address lines and respective
`control lines do not reach said memory
`devices; and
`
`For DDR2, see JEDEC, No. 79-2F, Sections
`2.3, 3.10, 3.11, and 4.2, particularly to the
`“Don’t Care” function which is equivalent to
`electrically isolating. The “control device” is
`supplied by Smart Modular during its testing
`of the DDR2 to confirm compliance with the
`JEDEC Specification, and to use test results
`for marketing to other companies.
`
`For DDR3, see JEDEC, No 79-3F, Section
`4.1, 4.7, 4.15, 4.16, and 4.17.1 , particularly
`to the “Don’t Care” function which is
`equivalent to electrically isolating. The
`“control device” is supplied by Smart
`Modular during its testing of the DDR2 to
`confirm compliance with the JEDEC
`Specification, and to use test results for
`marketing to other companies.
`
`For DDR4, see JEDEC, No. 79-4, Sections
`4.1, 4.26, 4.27, and 4.28, .particularly to the
`“Don’t Care” function which is equivalent to
`electrically isolating. The “control device” is
`supplied by Smart Modular during its testing
`of the DDR2 to confirm compliance with the
`JEDEC Specification, and to use test results
`for marketing to other companies.
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`Page 4 of 5
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`SMART EXHIBIT 1003 - PAGE - 4
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`a memory access enable control device
`coupled to said control device and to said
`control lines for determining when said
`memory system is not being accessed and for
`initiating a low power mode for said memory
`system wherein said control device
`electrically isolates said memory devices and
`places said memory devices in said self
`refresh mode, thereby reducing the amount of
`electrical energy being drawn from an
`electrical power supply for said computer
`system.
`
`For DDR2, see JEDEC, No. 79-2F, Section
`3.11 describes entering Power-Down when
`there is no read or write operations.
`
`For DDR3, see JEDEC, No 79-3F, Section
`4.17 describes entering Power-Down when
`there is no read or write operations.
`
`For DDR4, see JEDEC, No. 79-4, Sections
`4.28 describes entering Power-Down when
`there is no read or write operations.
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`Page 5 of 5
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`SMART EXHIBIT 1003 - PAGE - 5
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