UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SEMICONDUCTOR COMPONENTS INDUSTRIES, LLC
`d/b/a ON SEMICONDUCTOR,
`Petitioner
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`v.
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`POWER INTEGRATIONS, INC.,
`Patent Owner
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`Case IPR2016-01600
`Patent No. 7,834,605
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`PATENT OWNER POWER INTEGRATIONS, INC.’S REPLY TO
`PETITIONER’S OPPOSITION TO PATENT OWNER’S
`MOTION TO AMEND
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SEMICONDUCTOR COMPONENTS INDUSTRIES, LLC
`d/b/a ON SEMICONDUCTOR,
`Petitioner
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`v.
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`POWER INTEGRATIONS, INC.,
`Patent Owner
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`Case IPR2016-01600
`Patent No. 7,834,605
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`PATENT OWNER POWER INTEGRATIONS, INC.’S REPLY TO
`PETITIONER’S OPPOSITION TO PATENT OWNER’S
`MOTION TO AMEND
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`I.
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`II.
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`Docket: 10256-0021IPC
`Case IPR2016-01600
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`TABLE OF CONTENTS
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`INTRODUCTION ........................................................................................... 1
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`35 U.S.C. § 316(d) ENTITLES PATENT OWNER TO CANCEL “ANY”
`CHALLENGED CLAIM AND THE BOARD ALREADY HELD THAT
`CLAIMS 1 AND 2 ARE “CHALLENGED CLAIMS AT ISSUE IN THIS
`PROCEEDING” .............................................................................................. 1
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`III. THE ONLY EVIDENCE IN THE RECORD SHOWS THAT NO
`ADDITIONAL CLAIM CONSTRUCTION WAS REQUIRED AND
`THERE WAS NO BASIS FOR PATENT OWNER TO REASONABLY
`ANTICIPATE ANY DISPUTES AS TO CLAIM SCOPE ............................ 4
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`IV. THE AMENDMENTS DO NOT INTRODUCE NEW SUBJECT MATTER
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`V. THE AMENDMENTS DO NOT ENLARGE THE SCOPE OF THE
`CLAIMS ........................................................................................................ 11
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`VI. CONCLUSION .............................................................................................. 12
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`i
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`Docket: 10256-0021IPC
`Case IPR2016-01600
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`PI 2002
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`PI 2003
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`PI 2004
`PI 2005
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`PI 2006
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`UPDATED EXHIBIT LIST
`Exhibit No. Description
`PI 2001
`Copy of Agreement and Plan of Merger as between Fairchild and
`ON Semiconductor filed with the SEC
`Press release related to merger between Fairchild and ON
`Semiconductor
`Power Integrations, Inc., v. Fairchild Semiconductor International,
`Inc. et al., Case No. 08-309-LPS (D. Del.), Dkt. No. 401
`RESERVED
`Article about completion of merger between ON Semiconductor
`and Fairchild
`Power Integrations, Inc., v. Fairchild Semiconductor International,
`Inc. et al., Case No. 08-309-LPS (D. Del.), Dkt. No. 731
`Confidentiality Agreement, dated September 14, 2015
`“XYZs of Oscilloscopes,” Tektronix, Inc., © 2000
`“Oscilloscope Fundamentals,” Tektronix, Inc., © 2009
`Declaration of Arthur W. Kelley
`U.S. Provisional Patent Application No. 60/325,642
`File History for U.S. Patent No. 7,834,605
`U.S. Patent No. 5,028,861 (“Pace”)
`U.S. Patent No. 5,680,034 (“Redl”)
`Reserved
`Resume of Arthur W. Kelley, Ph.D.
`Declaration of Howard G. Pollack in Support of Admission Pro
`Hac Vice
`AN-5841 Application Note
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`
`PI 2007
`PI 2008
`PI 2009
`PI 2010
`PI 2011
`PI 2012
`PI 2013
`PI 2014
`PI 2015
`PI 2016
`PI 2017
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`PI 2018
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`ii
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`Docket: 10256-0021IPC
`Case IPR2016-01600
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`I. INTRODUCTION
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`Most notable about Petitioner’s opposition is that which is absent. First,
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`Petitioner does not dispute that the proposed amendments distinguish all prior art
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`of record. Second, Petitioner has provided no evidence to support any of its
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`arguments regarding the claims or the claim scope as understood by a person of
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`ordinary skill in the art. Petitioner offers no rebuttal testimony that contradicts
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`anything Patent Owner’s expert, Dr. Arthur Kelley, has testified to in this
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`proceeding. Moreover, Petitioner chose not to cross-examine Dr. Kelley regarding
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`his testimony. Thus, Dr. Kelley’s testimony regarding the understanding of a
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`person of ordinary skill in the art and the amended claim scope stands unrebutted.
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`Absent actual evidence – the unsupported attorney argument Petitioner offers is not
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`evidence – there is no basis to dispute Dr. Kelley’s opinions.
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`As shown below, Petitioner’s attorney argument also has no legal merit,
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`makes little logical sense, and is not supported by admissible evidence. Patent
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`Owner thus respectfully requests that its motion to amend be granted.
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`II.
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`35 U.S.C. § 316(d) ENTITLES PATENT OWNER TO CANCEL
`“ANY” CHALLENGED CLAIM AND THE BOARD ALREADY
`HELD THAT CLAIMS 1 AND 2 ARE “CHALLENGED CLAIMS AT
`ISSUE IN THIS PROCEEDING”
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`There is no legal basis for Petitioner’s suggestion that claims 1 and 2 of the
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`’605 patent “no longer exist and are no longer subject to this proceeding.” Paper 18
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`at 1. In fact, Petitioner’s argument is directly contradicted by the Board’s finding
`1
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`Docket: 10256-0021IPC
`Case IPR2016-01600
`on March 31, 2017 that claims 1 and 2 are “challenged claims at issue in this
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`proceeding.” Paper 14 at 3. The procedural posture is the same now as on March
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`31st when the Board’s ruling issued given that the Federal Circuit’s opinion
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`became final on March 12, 2017 after Patent Owner’s time to seek certiorari
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`expired. See Paper 18 at 4. Thus, Petitioner’s arguments alleging Patent Owner
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`cannot cancel claims 1 and 2 have no legal merit and, absent that argument, there is
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`no reason that the substitution of claims 13 and 14 is unreasonable.
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`Under 35 U.S.C. § 316(d), Patent Owner is statutorily entitled to cancel “any
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`challenged patent claim,” including claims 1 and 2:
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`(1) In general.—During an inter partes review instituted under this
`chapter, the patent owner may file 1 motion to amend the patent in 1
`or more of the following ways:
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`(A) Cancel any challenged patent claim.
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`(B) For each challenged claim, propose a reasonable number of
`substitute claims.
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`35 U.S.C. § 316(d). The statutory language of § 316(d)(1)(A) affirmatively allows
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`for cancelation of “any challenged patent claim,” and nothing in the statutory
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`language suggests that claims that were found invalid by a court are per se
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`unavailable for amendment.
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`The Board’s Order, Paper 14, confirms that claims 1 and 2 are presently
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`challenged and are still at issue in this proceeding. That is, after the Board
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`2
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`Case IPR2016-01600
`instituted IPR in consideration of the Federal Circuit’s ruling invalidating claims 1
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`and 2 (Paper 11 at 2), the Board again confirmed that claims 1 and 2 were
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`“challenged claims at issue in this proceeding.” Paper 14 at 3 (“the challenged
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`claims at issue in this proceeding (claims 1, 2, 5, and 9).”). Because there can be
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`no reasonable dispute that claims 1 and 2 are “challenged claims,” and because 35
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`U.S.C. § 316(d) allows for cancellation of “any challenged patent claim,” Patent
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`Owner is necessarily entitled to cancel claims 1 and 2.
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`The Federal Circuit has never suggested that a court’s invalidity ruling
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`actually or effectively “cancels” claims or that such a ruling removes the Patent
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`Office’s statutory jurisdiction. Contrary to Petitioner’s arguments, a court does not
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`“cancel” claims, much less make them “no longer exist,” but instead claims are
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`only “cancelled” pursuant to specific grants of authority to the Director by statute.
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`E.g., 35 U.S.C. § 316(d)(1)(A); 35 U.S.C. § 307; 35 U.S.C. 316 (Pre-AIA); 35
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`U.S.C. § 318. Petitioner’s cited Fresenius case is inapposite and deals only with
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`the effect of an Office decision on a “pending litigation,” and does not suggest that
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`a court’s finding of invalidity “cancels” the claims (actually or effectively) or
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`removes the Office’s statutory jurisdiction over the invalidated claims. See
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`Fresenius USA, Inc. v. Baxter Int’l Inc., 721F.3d 1330, 1347 (Fed. Cir. 2013).
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`Moreover, it is only the Patent Office’s own rules that dictate that under certain
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`circumstances cancelled claims are not subject to further proceedings, not an
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`3
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`Docket: 10256-0021IPC
`Case IPR2016-01600
`inherent lack of statutory jurisdiction over invalidated claims (or that they “no
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`longer exist” as alleged by Petitioner). See, e.g., 37 C.F.R. 1.570 (d); 37 C.F.R.
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`1.997(d).
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`Petitioner’s other cited cases speak only to the issue of collateral estoppel as
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`a matter of common law, and do not negate the statutory mandate found in 35
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`U.S.C. § 316. There is necessarily a difference between the collateral estoppel
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`effects of a court’s finding of invalidity and the question of whether the Board has
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`lost its statutory jurisdiction under 35 U.S.C. § 316 over the claims of a patent for
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`purposes of inter partes review. Patent Owner does not deny that the common law
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`doctrine of collateral estoppel applies, and thus the Board could not properly issue
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`contrary findings of fact (e.g., MPEP § 2286), but that does not mean that it has
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`lost its statutory jurisdiction over the claims. None of Petitioner’s cited cases, or
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`the Patent Office’s rules, state that the statutory authority granted by 35 U.S.C. §
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`316 over challenged claims is exhausted by a court’s finding of invalidity.
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`Accordingly, Patent Owner should be allowed to cancel claims 1 and 2, and
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`new claims 13 and 14 should be allowed as reasonable substitutes.
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`III. THE ONLY EVIDENCE IN THE RECORD SHOWS THAT NO
`ADDITIONAL CLAIM CONSTRUCTION WAS REQUIRED AND
`THERE WAS NO BASIS FOR PATENT OWNER TO REASONABLY
`ANTICIPATE ANY DISPUTES AS TO CLAIM SCOPE
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`As stated by the Board, Patent Owner need only suggest claim constructions
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`for new terms used in a substitute claim “where the patent owner reasonably
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`4
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`Case IPR2016-01600
`anticipates a dispute as to the meaning of such term.” Paper 14 at 3 (emphasis
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`added). Patent Owner provided evidence, in the form of a declaration from Dr.
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`Kelley, explaining why there should be no reasonable dispute over the meaning of
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`the new claim elements. Exhibit 2010 at ¶ 49. Petitioner, on the other hand, has
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`provided no evidence and no contrary expert declaration, but only attorney
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`argument, to suggest that the new terms “introduce ambiguities and/or conflict
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`with terms in the original language of claim 1.” Paper 18 at 9-10. Petitioner also
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`opted not to cross-examine Dr. Kelley as to his testimony. Thus, the only evidence
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`in the record regarding how a person of ordinary skill in the art would understand
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`the claims is Dr. Kelley’s unrebutted testimony. Petitioner’s unsupported attorney
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`argument does not undermine Patent Owner’s reasonable reliance on the sworn
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`testimony of its expert that no dispute could be reasonably anticipated. Petitioner’s
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`arguments should be rejected.
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`“A first state and a second state”: The only evidence in the record, Dr.
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`Kelley’s unrebutted testimony, establishes that a person of ordinary skill in the art
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`would readily understand what is meant by a “first state and a second state.” Ex.
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`2010 at ¶ 49. As explained by Dr. Kelley, “‘first state’ and ‘second state’ would
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`have been generally known to a person having ordinary skill in the art at the time
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`of the invention and refer to a signal having various well-known states, such as
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`‘on’/‘off’ or ‘high’/‘low,’ for example.” Id. Petitioner has not provided any
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`5
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`Docket: 10256-0021IPC
`Case IPR2016-01600
`contrary evidence to rebut Dr. Kelley. Accordingly, the evidence establishes that
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`the claims have an understood plain and ordinary meaning.
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`Petitioner’s argument that “PO does not make clear whether or not they
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`intend ‘first state’ to have the same scope as the existing claim term ‘on time of the
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`switch’” (Paper 18 at 11) is meritless. As explained by Dr. Kelley, the term “first
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`state” is entitled to its broadest reasonable interpretation and would be readily
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`understood by persons of ordinary skill in the art. See Ex. 2010 at ¶ 49. Petitioner
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`has not proposed a contrary construction; nor has it alleged that the claims ensnare
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`the prior art when properly construed. Petitioner’s attorney argument regarding
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`Patent Owner’s intent is irrelevant and nothing more than baseless speculation.
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`There is nothing to suggest that there is any reasonable dispute as to the meaning
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`of the claims or that Patent Owner could have reasonably anticipated a dispute.
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`“The variable current limit threshold increases during at least a portion of
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`the first state”: Petitioner’s argument as to this claim term, once again, fails to cite
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`any evidence in the record to contradict Dr. Kelley’s testimony or to support
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`Petitioner’s contention that the claim language would be unclear to a person of
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`skill in the art. Petitioner argues that “Petitioner and the Board must determine
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`whether PO intends any difference between the requirement that the variable
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`current limit threshold increase (1) ‘during the on time of the switch’ as recited in
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`claim 1 and the first clause of proposed substitute claim 13 and (2) ‘during at least
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`6
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`Docket: 10256-0021IPC
`Case IPR2016-01600
`a portion of the first state’ as recited in the last clause of proposed substitute claim
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`13.” Paper 18 at 12. But this makes little sense – the claim is what it is and means
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`what it says. It adds a requirement that is in addition to what was present in the
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`original claim. Likewise, Petitioner’s argument that “[i]f PO intends ‘during at
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`least a portion of the first state’ to have the same meaning as ‘during the on time of
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`the switch,’ the new term is ‘largely redundant’”, is also baseless. See Paper 18 at
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`12. The terms are not the same (or similar) and thus as a matter of law do not
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`necessarily have the same scope – here, again, the claims are what they are and are
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`entitled to their broadest reasonable interpretation.
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`If Petitioner believed the claims were so broad as to ensnare the prior art
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`under the broadest reasonable interpretation, then it could have said so. Instead,
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`Petitioner offers only unsupported attorney argument contending a skilled artisan
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`would be unable to understand the claims. Here again, the claim language is clear
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`to a person of skill in the art – as Dr. Kelley’s unrebutted testimony establishes –
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`and Petitioner’s attorney argument, which is not evidence, does not undermine that
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`testimony. There is no basis to suggest there is a reasonable dispute as to the
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`claim’s meaning or that Patent Owner could have reasonably anticipated a dispute.
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`IV. THE AMENDMENTS DO NOT INTRODUCE NEW SUBJECT
`MATTER
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`
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`Patent Owner has provided the sworn testimony of Dr. Kelley along with his
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`detailed element-by-element analysis demonstrating that the original disclosure
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`7
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`Docket: 10256-0021IPC
`Case IPR2016-01600
`supports the substitute claims. Ex. 2010 at ¶¶ 55-70. Dr. Kelley’s testimony
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`stands unrebutted. Petitioner’s decision not to cross-examine Dr. Kelley speaks
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`volumes about the strength of its position. But, more importantly, it also
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`demonstrates that Petitioner has nothing more than attorney argument – and no
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`actual evidence – to support its contention that a person of ordinary skill in the art
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`would find that new matter has been introduced.
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`“A plurality of consecutive control signal cycles”: As explained by Dr.
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`Kelley, in the embodiment shown in FIG. 1, the “control signal” is the output of
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`the latch 90. Ex. 2010 at ¶ 60 (“control signal (FIG. 1 ‘D’ output of ‘latch 90’)”).
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`In that embodiment, the “D” output is coupled to the control terminal of MOSFET
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`2 and controls the switching cycles, i.e., turning the switch on and off. Ex. 2010 at
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`¶ 61. Thus, the “control signal” necessarily has multiple cycles as the switch is
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`turned on and off multiple times. Ex. 2010 at ¶¶ 62-65. This can be seen, for
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`example, from FIG. 2, which shows multiple cycles of various signals which,
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`coupled as shown in the circuit in FIG. 1, necessarily result in the switch turning
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`on and off multiple times. The proof of the fact that multiple switching cycles will
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`necessarily be present in the embodiments of FIGs. 1 and 2 is provided by Dr.
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`Kelley’s explanation of the DMAX 15 signal. That signal defines when each
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`switching cycle will necessarily begin (i.e., FIG. 1 shows the “Clock” signal
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`coupled to the “S” or Set input to the latch 90 is aligned with the DMAX 15 rising
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`8
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`Docket: 10256-0021IPC
`Case IPR2016-01600
`edge) and the maximum time for which each cycle may persist (i.e., the falling
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`edge of the DMAX 15 signal coupled to the “R” or Reset input of latch will
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`necessarily stop a switching cycle). Ex. 2010 at ¶ 65. Given that the DMAX 15
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`signal is shown in FIG. 2 as having multiple cycles, and given that the switch must
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`turn on when DMAX goes high, and must turn off no later than when DMAX goes
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`low, Dr. Kelley’s testimony establishes that the multiple cycles of the control
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`signal are necessarily present; if not expressly disclosed, by FIGs. 1 and 2. See id.
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`“Control signal cycles each having a first state and a second state”: As
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`stated above, in the embodiments shown in FIGs. 1 and 2 the control signal output
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`by latch 90 will necessarily have a first state and a second state. Ex. 2010 at ¶ 63.
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`The “first state” will begin when the “Clock” signal shown in FIG. 1 goes high,
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`which is aligned with the rising edge of the DMAX 15 signal; the “second state”
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`will occur when the latch 90 is reset via the “R” input of the latch, which will
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`necessarily happen no later than the falling edge of the DMAX 15 Signal.
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`Accordingly, as confirmed by Dr. Kelley – and as is unrebutted by any evidence
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`from Petitioner – this element is fully disclosed.
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`“The variable current limit threshold increases during at least a portion of
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`the first state”: Petitioner’s argument on this claim term makes little sense.
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`Petitioner appears to allege that disclosing an embodiment where the variable
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`current limit threshold increases during the entire first state fails to disclose that the
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`9
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`Docket: 10256-0021IPC
`Case IPR2016-01600
`“the variable current limit threshold increases during at least a portion of the first
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`state.” Of course, a variable current limit threshold that increases during at least a
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`portion of the first state is necessarily shown by a variable current limit threshold
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`that increases during the entire first state. And, a variable threshold that increases
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`during the entire first state necessarily meets the limitation that it increase “during
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`at least a portion of the first state.”
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`More to the point, the original disclosure is not as restricted at Petitioner
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`contends. As stated in the original disclosure, “[t]he regulation circuit current limit
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`threshold is varied from a first level to a second level during the time when the
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`semiconductor switch is on.” Ex. 2011 at 8. There is no reason that “during the
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`time when the semiconductor switch is on” must necessarily mean during the
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`entire time when the semiconductor switch is on. If the Patentee intended to limit
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`the disclosure to the entire time when the switch is on – i.e., narrow it from what
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`the ordinary meaning of the terms would imply – and disallow thresholds that only
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`increase during part of the on time, then the patentee would have needed to make
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`such a limitation express and unmistakable. Absent an express limitation in the
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`specification, there is no reason that the language should not be given its plain
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`meaning. Moreover, the original disclosure expressly states that it is to be
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`interpreted as illustrative and not restrictive. Ex. 2011 at 18. Petitioner’s argument
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`is factually and legally meritless and should be rejected.
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`10
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`Docket: 10256-0021IPC
`Case IPR2016-01600
`V. THE AMENDMENTS DO NOT ENLARGE THE SCOPE OF THE
`CLAIMS
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`It is axiomatic that adding a non-negative limitation to a claim necessarily
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`narrows the claim – Petitioner appears to misunderstand this basic tenant of patent
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`law. The unrebutted testimony of Dr. Kelley explains that “[t]he amendments
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`proposed by Patent Owner do not expand the scope of the original claims” and that
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`“each substitute claims adds a new claim limitation that narrows the scope of the
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`original claims.” Ex. 2010 at ¶ 51. Petitioner has provided no rebuttal testimony
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`or any other evidence to suggest that the claims have been expanded in scope.
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`“First state”: The fact that the claim’s original scope includes the term “on
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`time of the switch” does not mean that the addition of the term “first state of each
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`control signal cycle” broadens the claim. These are different elements, and each is
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`entitled to its broadest reasonable interpretation. This is true regardless of whether
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`the time periods defined by these limitations could, in certain embodiments, be
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`coextensive. Petitioner provides no evidence to support its attorney argument that
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`the claim terms would not have readily understood meanings in the art; nor does
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`Petitioner present any evidence to rebut Dr. Kelley’s testimony that adding the
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`proposed language narrows the claim scope.
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`“The variable current limit threshold increases during at least a portion of
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`the first state”: Patent Owner has never contended that original claim 1 requires
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`that the current limit threshold increase during the entire on time of the switch.
`11
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`Docket: 10256-0021IPC
`Case IPR2016-01600
`Indeed, the opposite is true. Petitioner’s products found infringing in litigation
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`have a variable current limit threshold that increases during only a portion of the
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`switch on time and then plateaus. See Ex. 2018 (AN-5841 Application Note) at 6
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`(showing the infringing implementation uses an increasing threshold that plateaus
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`before the end of the switch cycle). Nor did Petitioner (through its predecessor-in-
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`interest Fairchild) ever assert non-infringement during litigation based on the
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`interpretation its attorneys argue here. The broadest reasonable interpretation of
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`original claim 1 does not require that the current limit threshold increase during the
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`entire on time of the switch; Patent Owner has never contended otherwise, and no
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`tribunal has so found. Accordingly, substituted claim 13, by adding further
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`limitations on the invention, including that the variable current limit also decreases
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`during at least a portion of the second state of each control signal cycle, is
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`necessarily narrower than the original claim.
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`And, as noted above, Petitioner has not even attempted to argue that the
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`claims, as amended, are disclosed by or obvious in view of any prior art.
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`VI. CONCLUSION
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`For all of these additional reasons, Patent Owner requests that its motion to
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`amend be granted.
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`12
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`Docket: 10256-0021IPC
`Case IPR2016-01600
`Respectfully submitted,
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`/Neil A. Warren/
`Neil A. Warren, Reg. No. 63,582
`Counsel for Patent Owner
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`Date: 9/18/2017
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`Customer Number 26171
`Fish & Richardson P.C.
`Telephone: (612) 337-2508
`Facsimile: (612) 288-9696
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`Docket: 10256-0021IPC
`Case IPR2016-01600
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`
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR § 42.6(e)(4), the undersigned certifies that on September
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`18, 2017, a complete and entire copy of this Patent Owner Power Integrations, Inc.’s
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`Reply to Petitioner’s Opposition to Patent Owner’s Motion to Amend and Exhibit
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`2018 were provided via email, to the Petitioner by serving the email
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`correspondence addresses of record as follows:
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`Roger Fulghum
`Brett Thompsen
`Baker Botts L.L.P.
`One Shell Plaza, 910 Louisiana Street
`Houston, TX 77002-4995
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`Email: roger.fulghum@bakerbotts.com
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` brett.thompsen@bakerbotts.com
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`/Diana Bradley/
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`Diana Bradley
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`(858) 678-5667
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`14
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