throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`In Re:
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`U.S. Patent 7,834,605
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`:
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`Attorney Docket No. 082963.0108
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`Inventor: Balu Balakirshnan et al. :
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`Filed:
`
`Issued:
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`October 16, 2009
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`November 16, 2010
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`:
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`:
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`IPR No. Unassigned
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`Assignee: Power Integrations Inc.
`
`Title:
`
`Method and Apparatus for Maintaining a Constant Load Current With
`Lin Voltage in a Switch Mode Power Supply
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`Submitted Electronically via the Patent Review Processing System
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`DECLARATION OF DOUGLAS HOLBERG, Ph.D.
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`Table of Contents
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`Background and Qualifications .................................................................... 1
`I.
`Legal Understanding ..................................................................................... 2
`II.
`III. Overview of the ’605 Patent .......................................................................... 2
`A. Background of the Technology ..................................................................... 2
`B.
`Subject Matter of the ’605 Patent .................................................................. 7
`C. The History of the ’605 Patent ....................................................................12
`IV. Summary of the Prior Art ...........................................................................15
`A.
`de Sartre .......................................................................................................15
`V. Claim Construction .....................................................................................20
`VI. Level of Ordinary Skill in the Art ..............................................................20
`VII. Summary of the Ground .............................................................................21
`VIII. Ground 1: de Sartre Anticipates Claims 1, 2, 5, and 9 ............................22
`A. Claim 1 ........................................................................................................22
`B. Claim 2 ........................................................................................................32
`C. Claim 5 ........................................................................................................34
`D. Claim 9 ........................................................................................................36
`IX. Conclusion ....................................................................................................37
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`Declaration of Doug Holberg
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`I, Doug Holberg, declare as follows:
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`1.
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`I make this declaration based upon my own personal knowledge and,
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`if called upon to testify, would testify competently to the matters contained herein.
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`2.
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`I have been asked to provide technical assistance in the inter partes
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`review of U.S. Patent No. 7,834,605 (“the ’605 Patent”).
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`3.
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`This declaration is a statement of my opinions on issues related to the
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`unpatentability of claims 1, 2, 5, and 9 of the ’605 Patent.
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`I.
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`Background and Qualifications
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`4.
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`In formulating my opinions, I have relied upon my knowledge,
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`training, and experience in the relevant art. A complete listing of my qualifications
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`including a list of my patents is stated more fully in my curriculum vitae.
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`Ex. 1004. Here I provide a brief summary of my qualifications
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`5.
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`I have over 30 years of experience in the electronics field. During that
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`time, I have worked for several different electronics companies including: Mostek,
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`Crystal Semiconductor, Cygnal Integrated Products, and Silicon Laboratories,
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`when it acquired Cygnal, which I co-founded in 1999. I am a named inventor on
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`39 U.S. patents. I have held a variety of engineering positions over that time from
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`circuit designer to Director of Engineering and V.P. of Technology. In addition to
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`my engineering experience, I also have served as an adjunct faculty member at the
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`University of Texas, where I earned my M.S.E. and Ph.D. degrees. Further, I have
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`published numerous IEEE papers, and co-authored three editions of a text book
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`titled CMOS Analog Circuit Design.
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`II. Legal Understanding
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`6. My opinions are also informed by my understanding of the relevant
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`law. I understand that the patentability analysis is conducted on a claim-by-claim
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`and element-by-element basis, and that there are several possible reasons that a
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`patent claim may be found to be unpatentable.
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`7.
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`I understand that a single prior art reference, article, patent or
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`publication “anticipates” a claim if each and every element of the claim is
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`disclosed in that prior art reference. I further understand that, where a claim
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`element is not explicitly disclosed in a prior art reference, the reference may
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`nonetheless anticipate a claim if the missing claim element is necessarily present in
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`the apparatus or a natural result of the method disclosed—i.e. the missing element
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`is “inherent.”
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`III. Overview of the ’605 Patent
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`A. Background of the Technology
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`8.
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`I have reviewed the ’605 Patent, which is entitled “Method and
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`Apparatus for Maintaining a Constant Load Current With Line Voltage in a Switch
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`Mode Power Supply.” Ex. 1001. I understand that this patent was filed on
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`October 16, 2009, and issued on November 16, 2010. Id. I have also reviewed
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`U.S. Patent No. 7,110,270 (“the ’270 Patent”), a patent from which the ’605 Patent
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`depends. Ex. 1002.
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`9.
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`The ’605 Patent relates to switch mode power supply circuits.
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`Ex. 1001, Abstract, 1:24-26. A switch mode power supply may transfer electrical
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`energy from a power source input (e.g., a wall socket) to the output of the switch
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`mode power supply through an inductive element, such as a transformer, coupled
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`to a switch. Id., 5:9-13, 2:4-8, Fig. 4. The duty cycle of the switch (i.e., the ratio
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`of the on-time of the switch to the overall switching period) may be controlled
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`during each switching cycle in order to regulate the amount of energy transferred
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`from the input to the output of the switch mode power supply. Id., 5:37-39, 5:11-
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`13, 3:19-21.
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`10. An example of a switch mode power supply is illustrated in Figure 4
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`of the ’605 Patent. Id., 5:31-34, Fig. 4. As shown in Figure 4, the power supply
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`receives power from an external power source at input 355 on the primary side of
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`the power supply. Id., Fig. 4. A regulation circuit 350 drives a winding of energy
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`transfer element 320 to supply power at output 300 on the secondary side of the
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`power supply. Id., Fig. 4; see also id., 5:31-49.
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`input 355
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`Id., Fig. 4.
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`primary side
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`secondary side
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`output 300
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`energy transfer element 320
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`regulation circuit 350
`(including switch)
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`
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`11. The regulation circuit of the power supply may control the current
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`and/or the voltage at output 300. Id., 5:37-49. For example, regulation circuit 350
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`includes an internal switch (i.e., a power MOSFET) that is coupled to the primary
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`winding of energy transfer element 320. Id., 5:40-43, Fig. 4. Regulation circuit
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`350 modulates the duty cycle of the switch (i.e., the ratio of the on-time of the
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`switch to the overall period of each switching cycle) to control the output voltage.
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`Id., 5:37-39. Similarly, regulation circuit 350 may adjust the current limit of the
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`switch to control the output current. Id., 5:40-43.
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`12.
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`In operation, the regulation circuit may maintain a constant voltage or
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`a constant current at the output of the power supply. Id., 5:53-56, Fig. 5. As
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`shown in Figure 5, the power supply may exhibit a constant output voltage region
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`and a constant output current region. Id., 5:53-56, Fig. 5.
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`constant output voltage region
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`output voltage
`threshold
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`constant output
`current region
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`
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`Id., Fig. 5. In the constant output voltage region, the output voltage remains
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`constant irrespective of the output current. Id., 5:56-58. However, when the
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`output current reaches an output current threshold, the power supply maintains a
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`constant output current, but at a reduced output voltage. Id., 5:58-63.
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`13. As stated in the background of the ’605 Patent, techniques were
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`known in the art for regulating the output current of a power supply. Id., 1:39-42.
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`For example, some switch mode power supplies monitor the current at the output
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`of the power supply (i.e., at the secondary side) and provide feedback to the
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`regulator circuit (i.e., at the primary side) to control the energy transfer to the
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`output. Id., 3:5-8. Other switch mode power supplies, including those disclosed in
`
`the ’605 Patent, monitor the current through the switch in the regulation circuit at
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`the primary side as a proxy for the output current at the secondary side. See id.,
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`1:44, 3:8-14.
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`14. To control the output current in the constant current region, the
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`regulation circuit of the power supply may set an intrinsic current limit threshold.
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`Id., 3:18-19. That is, the regulation circuit may monitor the current through the
`
`switch, and turn the switch off when the intrinsic current limit threshold is reached.
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`Id., 3:19-21, 4:42-44. The intrinsic current limit threshold may be a constant value
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`set to control the power supply switch in order to maintain a constant current at the
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`output of the power supply. Id., 3:18-20. Thus, the intrinsic current limit threshold
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`is used to maintain a constant output current at the output of the power supply
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`without monitoring the output current at the secondary side. See id., 1:51-2:18.
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`15. However, a delay may occur from the time that the switch reaches the
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`intrinsic current limit threshold and when the control circuitry fully disables the
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`switch. Id., 3:21-23. During this delay, current through the switch continues to
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`ramp up beyond the intrinsic current limit threshold. Id., 3:24-33. This excess
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`current through the switch causes an actual current limit that is greater than the
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`intrinsic current limit threshold. Id., 3:31-33. Moreover, the amount of excess
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`current will vary based on the input voltage of the power supply. Id., 3:24-27. As
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`a result, the actual current limit (i.e., the sum of the intrinsic current limit and the
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`excess current) varies as a function of the input voltage. Id., 3:33-35. Such
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`variations in the actual current limit may cause undesirable variations in the output
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`current when the power supply is operating in its constant current region. Id.,
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`3:31-35.
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`B. Subject Matter of the ’605 Patent
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`16. The ’605 Patent purports to overcome the problem of variations in the
`
`actual current limit caused by different input voltages. Ex. 1001, 3:14-17. For
`
`example, the power supply regulation circuit of the ’605 Patent creates a variable
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`current limit threshold (i.e., a variable intrinsic current limit) that increases during
`
`the on-time of the power switch. Id., Abstract. Because the ramp up rate of the
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`excess current in the switch varies with respect to the input voltage to the power
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`supply, the variable current limit threshold of the ’605 Patent may compensate for
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`changes in the input voltage that might otherwise cause variations in the actual
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`current limit, and thus variations in the output current. Id., 3:45-55. The ’605
`
`Patent’s implementation of this variable intrinsic current limit threshold is
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`explained directly below, followed by an explanation of how this variable intrinsic
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`current limit threshold compensates for input voltage variations to provide a stable
`
`actual current limit.
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`17. Figure 1 of the ’605 Patent illustrates a regulation circuit for
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`implementing a variable current limit threshold in a power supply.
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`regulation circuit
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`switch
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`Ex. 1001, Fig. 1. Oscillator 5 controls the timing of MOSFET 2 (i.e., the power
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`supply switch). Id., 4:16-17, 1:11-14. The rising edge of clock signal 10 triggers
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`the beginning of the power switch cycle. Id., 4:19-20. Clock signal 10 sets latch
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`90 such that the control signal output from the latch turns the switch on (i.e.,
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`MOSFET 2 is enabled to begin conducting). Id., 4:20-24.
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`18. As shown in Figure 1, OR gate 85 has three inputs and is coupled to
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`the reset of latch 90. Id., Fig. 1. Thus, any one of three occurrences may reset
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`latch 90 to turn the switch off. In the constant voltage region, PWM comparator 32
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`may reset latch 90 based on a voltage feedback from the output of the power
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`supply. Id., Fig. 1, 4:50-53. In the constant current region, comparator 70 may
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`reset latch 90 if the switch current exceeds the current limit threshold. Id., 4:47-49.
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`Finally, if latch 90 is not reset before the end of the switch cycle, then maximum
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`duty cycle signal DMAX 15 may reset the latch at the end of the switch cycle (i.e.,
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`falling edge of DMAX 15). Ex. 1001, 4:25-26. When reset, latch 90 creates an
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`output control signal that turns the switch off. Id., 4:26-28.
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`19. As discussed above, the regulation circuit of the ’605 Patent may
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`generate a variable current limit threshold to control the regulation circuit switch.
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`Id., 4:29-33. For example, oscillator 5 generates a sawtooth signal 20 that
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`increases during the on-time of the regulation circuit switch. Id., 4:56-61.
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`Sawtooth signal 20 is applied to the base of NPN transistor 30 such that the current
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`in resistor 25 linearly increases with the on-time of the switch. Id., 4:34-37. The
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`current through resistor 25 is mirrored by current mirror 40 and combined with
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`constant current source 50. Id., 4:37-39. The combined current is applied to
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`resistor 17 to create a variable intrinsic current limit threshold at node 22. Id.,
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`4:39-42. Thus, the current limit threshold at node 22 comprises both a constant
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`component and variable component that linearly increases during the duty cycle of
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`the power switch. Id., 4:34-42.
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`20. Figure 2 of the ’605 Patent illustrates the variable intrinsic current
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`limit threshold created by the regulation circuit.
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`variable current
`limit threshold
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`Id., Fig. 2. As illustrated, sawtooth signal 20 linearly increases during the
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`switching cycle. Id., 4:34-37, Fig. 2. The regulation circuit of the power supply
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`uses sawtooth signal 20 to create the variable intrinsic current limit threshold 22.
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`Id., 4:54-5:4, Fig. 2. During each switching cycle, the variable intrinsic current
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`limit threshold begins at constant value K1 and increases proportionally to the time
`
`elapsed (e.g., K2*telapsed). Id., 5:1-4.
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`21. Comparator 70 may monitor the current through the power switch,
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`and disable the switch when the current reaches the variable intrinsic current limit
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`threshold. Id., 4:47-49. For example, node 37, one input to comparator 70, is
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`proportional to the drain current (IDRAIN 7) across the power supply switch. Id.,
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`4:42-45. The other input to comparator 70 is the variable current limit threshold at
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`node 22. Id., 4:48, Fig. 1. When the voltage at node 37 (e.g., representing the
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`current through the switch) exceeds the voltage at node 22 (e.g., representing the
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`variable intrinsic current limit threshold), comparator 70 resets latch 90, thereby
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`disabling the switch. Id., 4:45-49.
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`22. The variable intrinsic current limit threshold of the ’605 Patent may
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`reduce variations in the actual current limit caused by different input voltages. Id.,
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`3:37-44. For example, when the input voltage is high, the current through the
`
`primary winding of the energy transfer element may increase faster, and thus reach
`
`the intrinsic current limit earlier in the switching cycle when the variable intrinsic
`
`current limit is lower. Id., 3:31-33, 3:40-41, 3:47-51, 4:66-5:4. At the same time,
`
`the higher input voltage may cause a higher amount of excess current during the
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`delay time (i.e., the delay between when the intrinsic current limit threshold is
`
`reached and when the control circuitry fully disables the switch). Id., 3:31-33. As
`
`a result, the lower intrinsic current limit compensates for the higher excess current
`
`during the delay time. See id., 3:36-44.
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`23. Conversely, when the input voltage is low, the current through the
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`primary winding of the energy transfer element may increase slowly, and thus
`
`reach the intrinsic current limit later in the switching cycle when the variable
`
`intrinsic current limit is higher. Id., 3:52-53. The lower input voltage, however,
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`may cause a lower amount of excess current in the delay time. Id., 3:28-31. As a
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`result, the higher intrinsic current limit compensates for the lower excess current
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`during the delay time. See id., 3:36-44. Accordingly, the actual current limit (i.e.,
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`the sum of the current limit and the excess current) may become constant across
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`different input voltages as a result of the variable intrinsic current limit threshold.
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`Id., 3:14-18, Abstract.
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`24.
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`In sum, the ’605 Patent discloses a variable intrinsic current threshold
`
`to achieve a constant actual current limit. Id., 3:28-33. The constant actual current
`
`limit may reduce variation in the output current caused by changes to the input
`
`voltage in order to create an approximately constant output current below an output
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`threshold voltage. Id., 3:14-18, 3:39-40. However, as explained in the next
`
`section, the claims of the ’605 Patent were broadened such that they do not require
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`a constant actual current limit or a constant output current.
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`C. The History of the ’605 Patent
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`25. The ’605 Patent is a continuation of U.S. App. No. 11/784,560, filed
`
`on April 6, 2007, now U.S. Patent No. 7,646,184, which is a continuation of
`
`application U.S. App. No. 11/397,524, filed on April 3, 2006, now U.S. Patent No.
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`7,215,105, which is a continuation of U.S. App. No. 10/892,300, filed on July 15,
`
`2004, now the ’270 Patent. See Ex. 1001.
`
`26. Patent Owner asserted claims 6-9 the ’270 Patent in the D. Del.
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`Litigation. Ex. 1006. Independent claim 6 of the ’270 Patent recites a power
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`supply regulator comprising:
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`a comparator having first and second inputs and an
`output, the first input of the comparator to sense a voltage
`developed by a switch, during an on time of the switch,
`the second input of the comparator coupled to receive a
`current limit threshold signal to increase during the on
`time of the switch; and
`a control circuit to generate a control signal in
`response to the output of the comparator, the control
`signal to be coupled to a control terminal of the switch to
`control switching of the switch to provide a power supply
`to have an output
`characteristic having an
`approximately constant output current below an output
`threshold voltage, the variable current limit threshold
`signal to vary between a first level and a second level
`during a time when the switch is to be on in response to
`the control signal.
`Ex. 1002, Claim 6. (emphasis added). As shown, claim 6 recites a “variable
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`current limit threshold” as well as the “constant output current” that results from
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`the variable current limit threshold. Claim 6 of the ’270 Patent is thus directed to a
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`variable current limit threshold used for the specific purpose disclosed in the
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`specification and described above (i.e., to maintain an output characteristic having
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`an approximately constant output current below an output threshold voltage). See
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`supra Section III.B.
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`27. Over a year into the D. Del. Litigation, the Patent Owner filed the
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`continuation application that is now the ’605 Patent. See Ex. 1002. Claim 1 of the
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`’605 Patent is the only independent claim. As shown below, claim 1 recites the
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`“variable current limit threshold,” but does not include the “constant output
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`current” limitation:
`
`A power supply regulator, comprising:
`a comparator having a first input coupled to sense
`a voltage representative of a current flowing through a
`switch during an on time of the switch, the comparator
`having a second input coupled to receive a variable
`current limit threshold that increases during the on
`time of the switch;
`a feedback circuit coupled to receive a feedback
`signal representative of an output voltage at an output of
`a power supply; and
`a control circuit coupled to generate a control
`signal in response to an output of the comparator and in
`response to an output of the feedback circuit, the control
`signal to be coupled to a control terminal of the switch to
`control switching of the switch.
`Ex. 1001, Claim 1. (emphasis added). A comparison of the claims in the ’270
`
`Patent and the ’605 Patent illustrate how the claims of the ’605 Patent were
`
`broadened beyond the scope of the purported invention described in the common
`
`specifications of the patents.
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`28. With broadened claim 1 of the ’605 Patent, Patent Owner seeks to
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`cover any power supply regulator with a variable current limit threshold, regardless
`
`of whether the variable current limit threshold is used for the purpose described in
`
`the shared specification of the ’270 and ’605 Patents. However, this expansion of
`
`claim scope is an overreach that encompasses prior art switch mode power supplies
`
`that utilized variable current limit thresholds for other purposes. As described
`
`below, the prior art de Sartre patent discloses one such switch mode power supply,
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`which utilizes a current limit threshold that varies while the switch is on, albeit for
`
`a different purpose than described by the shared specification of the ’270 and ’605
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`Patents.
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`IV. Summary of the Prior Art
`
`A. de Sartre
`
`29. United States Patent No. 4,692,853 by de Sartre et al. (“de Sartre”)
`
`issued on September 9, 1987 (see Ex. 1005), and thus qualifies as § 102(b) prior
`
`art. de Sartre was not considered during the original prosecution of the ’605 Patent
`
`or during the D. Del. Litigation. See Ex. 1001, Ex. 1010.
`
`30.
`
`de Sartre discloses a switch mode power supply that includes two
`
`integrated circuits: “regulation circuit CI1” and “regulation circuit CI2.”
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`power source 10
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`primary side
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`secondary side
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`switch
`sense resistor
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`output Vs
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`Regulation circuit CI1
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`Regulation circuit CI2
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`
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`Ex. 1005, Fig. 1. Regulation circuit CI1, located on the primary side of the power
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`supply, may control the base of power transistor TP (e.g., a switch). Id., 1:30-31.
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`Transistor TP controls the flow of current from electric mains line 10 (i.e., the
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`power source) into the primary winding of the transformer. Id., 1:28-45, Fig. 1.
`
`On the secondary side of the power supply, regulation circuit CI2 monitors the
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`output voltage Vs and sends regulation signals back to regulation circuit CI1
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`through transformer TX. Id., 1:36-41, Fig. 1.
`
`31. During normal operation of the power supply, regulation circuit CI2
`
`sends regulation signals to regulation circuit CI1 to cause transistor TP to turn on
`
`and off. Id., 10:45-50. The regulation signals from regulation circuit CI2 are
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`received at terminal 40 of regulation circuit CI1. Ex. 1005, Fig. 2, 9:56-57.
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`Positive control signals at terminal 40 cause transistor TP to turn on, and negative
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`control signals cause transistor TP to turn off during the switching cycle. Id.,
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`10:45-50.
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`32. To protect transistor TP, the power supply may utilize a safety mode
`
`during start up or when a dangerous overcurrent condition is detected. Id., 2:48-
`
`53. Regulation circuit CI1 may detect start up or overcurrent through terminal 40
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`(i.e., absence of regulation signals from regulation circuit CI2) and terminal 44
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`(i.e., current measuring input from transistor TP). Id., 8:46-51, 11:49-53.
`
`from regulation circuit CI2
`
`regulation circuit CI1
`
`signal to switch
`
`current measuring input from sense resistor
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`
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`Id., Fig. 2.
`
`33.
`
`In safety mode, the regulation circuit slowly ramps up the current
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`through transistor TP to prevent destruction of the transistor. Id., 2:9-18. Bursts of
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`triggering pulses may be sent to transistor TP during short enablement windows in
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`which the current limit threshold is gradually increased. Ex. 1005, Abstract,
`
`11:39-44. Oscillator 82 generates a low frequency (e.g., 1Hz) sawtooth waveform
`
`82 that comparator 88 in turn uses to generate a short (10% duty cycle) periodic
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`square waveform (i.e., as enablement window). Id., 7:8-28, 8:55-64.
`
`enablement windows
`
`current limit
`increasing during
`on-time of switch
`
`variable current
`limit threshold
`
`
`
`Id., Fig. 4. To protect transistor TP, the current limit from circuit 90 (i.e., the
`
`current limit threshold at which transistor TP is turned off by comparator 92) is set
`
`to a low value (Vs2) and then gradually increased to the current limit threshold
`
`used during normal operation of the power supply (Vs1). Id., 9:19-25, Fig. 2,
`
`Fig. 4.
`
`34. Each burst of triggering pulses to transistor TP during an enablement
`
`window is subject to a “current limitation threshold [that] passes progressively
`
`from its second relatively low value to its normal higher value.” Id., 9:39-42.
`
`18
`
`ON SEMICONDUCTOR EXHIBIT 1003
`Page 20 of 40
`
`

`
`
`
`Each triggering pulse may enable, or turn on transistor TP. Id., 8:55-65, 10:45-46.
`
`As illustrated below, the variable current limit threshold increases during each
`
`triggering pulse to transistor TP (i.e., during the on-time of the switch).
`
`on-time of the switch
`(e.g., transistor TP)
`
`variable current limit threshold increasing
`during the on-time of the switch
`
`
`
`Id., Fig. 4 (excerpt and annotation). This annotated figure illustrates that the
`
`current limit threshold increases over numerous triggering pulses (i.e., representing
`
`the on-time of the switch). And despite the high frequency of the triggering pulses,
`
`the current limit threshold will increase some amount during each pulse to
`
`transistor TP, as illustrated in the figure above.
`
`35.
`
`In sum, de Sartre discloses a power supply that operates in safety
`
`mode during start up and overcurrent conditions. Ex. 1005, 2:48-53, Abstract. In
`
`safety mode, transistor TP may be turned on as the current limit threshold is
`
`increased. Id., 9:19-25, Fig. 2, Fig. 4. Thus, de Sartre discloses a current limit
`
`threshold that increases during the on-time of the switch. The purpose of the
`
`variable current limit threshold in de Sartre (i.e., to protect transistor TP during
`
`19
`
`ON SEMICONDUCTOR EXHIBIT 1003
`Page 21 of 40
`
`

`
`
`
`start up and overcurrent conditions) may be different than that described in the
`
`specification of the ’605 Patent (i.e., reduce variations in the actual current limit
`
`caused by different input voltages). However, as explained in Section III.C, the
`
`claims of the ’605 Patent were broadened to encompass prior art switch mode
`
`power supplies that utilized variable current limit thresholds for other purposes.
`
`V. Claim Construction
`
`36.
`
`I understand that claim terms considered by the United States Patent
`
`and Trademark Office for patentability are to be given their “broadest reasonable
`
`construction.” I further understand that claim terms are generally given their
`
`ordinary and customary meaning, which is the meaning that the term would have
`
`to a person of ordinary skill in the art in question at the time of the invention this
`
`construction is to be made, consistent with the broadest reasonable construction. I
`
`also understand that the construction of claims in patent litigation in a United
`
`States District Court could be under a different standard than the “broadest
`
`reasonable construction” used before the Patent and Trademark Office. I do not
`
`believe that construction of any claims is required for, or material to, the resolution
`
`of this IPR.
`
`VI. Level of Ordinary Skill in the Art
`
`37.
`
`I understand that the person having ordinary skill in the art (POSITA)
`
`is a hypothetical person who is presumed to know the relevant prior art. I
`
`20
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`
`

`
`
`
`understand that the actual inventor’s skill is not determinative of the level of
`
`ordinary skill. I further understand that factors that may be considered in
`
`determining level of skill include: type of problems encountered in art; prior art
`
`solutions to those problems; rapidity with which innovations are made;
`
`sophistication of the technology; and educational level of active workers in the
`
`field. I understand that not all such factors may be present in every case, and one
`
`or more of them may predominate. In a given case, every factor may not be
`
`present, and one or more factors may predominate.
`
`38.
`
`In my opinion, a person of ordinary skill in the art for the ’605 Patent
`
`in the year 2001 would be a person having a B.S. in Electrical Engineering or a
`
`related field with at least two years of experience in designing power electronics,
`
`or having an M.S. in Electrical Engineering or a related field. At the time of
`
`invention, I was familiar with this level of skill because at the time of the ’605
`
`Patent, I taught engineering students at The University of Texas at Austin with this
`
`level of skill, and I managed a team of engineers, including those with this level of
`
`skill, at Crystal Semiconductor Corp.
`
`VII. Summary of the Ground
`
`Ground
`
`Description
`
`1
`
`Claims 1, 2, 5, and 9 are anticipated by de Sartre
`
`21
`
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`
`

`
`
`
`VIII. Ground 1: de Sartre Anticipates Claims 1, 2, 5, and 9
`
`A. Claim 1
`
`(i) Claim 1[pre]: “A power supply regulator, comprising:”
`
`39.
`
`de Sartre discloses a “chopped power supply control circuit.”
`
`Ex. 1005, Abstract. The power supply includes various circuit elements, including
`
`regulation circuit CI1 and regulation circuit CI2, which regulate the output of the
`
`power supply. Ex. 1005, 1:28-45, Fig. 1.
`
`Regulation circuit CI1
`
`Regulation circuit CI2
`
`
`
`Id., Fig. 1. Accordingly, de Sartre discloses a “power supply regulator,” as recited
`
`by the preamble of claim 1.
`
`1[pre]. A
`power
`supply
`regulator,
`
`de Sartre:
`Ex. 1005, Abstract: “A chopped power supply control circuit is
`provided intended to receive regulation control signals and to
`produce square waves for enabling a switch.”
`
`22
`
`ON SEMICONDUCTOR EXHIBIT 1003
`Page 24 of 40
`
`

`
`
`
`comprising:
`
`
`Ex. 1005, 1:28-45: “In chopped power supply architecture
`proposed by the applicant and shown in FIG. 1, two integrated
`circuits are used. One of the circuits CI1, serves for controlling the
`base of a power transistor TP for applying thereto periodic enabling
`and disabling control signals. The base control circuit CI1 is placed
`on the primary winding side (EP) of the transformer (TA) for
`reasons which will be better understood in the rest of the
`description. The other integrated circuit, regulation circuit CI2, is
`on the contrary placed on the secondary side (winding ES1) and it
`serves for examining the output voltage Vs of the power supply for
`forming regulation signals which it transmits to the first integrated
`circuit through a small transformer TX. The first integrated circuit
`CI1 uses these regulation signals for modifying the cyclic
`conduction ratio of the switching transistor TP and thus regulating
`the output voltage Vs of the power supply.”
`See also, e.g., Ex. 1005, 1:1-15, 1:53-62, 2:32-3:11, 4:25-9:64,
`Figs. 1, 2.
`
`(ii) Claim 1[a]: “a comparator having a first input coupled to sense a
`voltage representative of a current flowing through a switch during an
`on time of the switch, the comparator having a second input coupled
`to receiv

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