KINGSTON TECHNOLOGY COMPANY, INC. (Petitioner)
`v.
`POLARIS INNOVATIONS LTD. (Patent Owner)
`Oral Argument Demonstratives
`
`Case IPR2016‐01621
`Patent 6,438,057 B1
`
`Before Hon. S. C. MEDLEY, J. R. HOMERE, and M. R. CLEMENTS,
`Administrative Patent Judges
`
`1
`
`KiINGSTON 1019
`Kingston v. Polaris
`IPR2016-01621
`
`
`v.
`POLARIS INNOVATIONS LTD. (Patent Owner)
`Oral Argument Demonstratives
`
`Case IPR2016‐01621
`Patent 6,438,057 B1
`
`Before Hon. S. C. MEDLEY, J. R. HOMERE, and M. R. CLEMENTS,
`Administrative Patent Judges
`
`1
`
`KiINGSTON 1019
`Kingston v. Polaris
`IPR2016-01621
`
`
`
`Overview
`
`• Introduction to the Claimed Technology
`• Ample Reasons to Combine Atkinson and
`Broadwater
`• Obvious to Use a Diode with Atkinson
`• Atkinson Teaches “Refresh Unit” and “Refresh
`Timing Unit”
`• PO’s Expert’s Opinions Are Based on Faulty
`Understanding of POSITA
`
`2
`
`
`
`INTRODUCTION TO THE CLAIMED
`TECHNOLOGY
`
`INTRODUCTION TO THE CLAIMED
`
`TECHNOLOGY
`
`3
`
`
`
`The ’057 Patent is About Adjusting the DRAM Refresh Rate
`Using the Temperature of the DRAM Array
`
`‘057 Patent, Ex. 1001, 1:5‐10.
`
`4
`
`
`
`Adjusting the DRAM Refresh Rate Using the Temperature of
`the DRAM Array
`
`‘057 Patent, Ex. 1001, 4:30‐37.
`
`Id. at Fig. 3.
`
`Id. at Fig. 2.
`
`5
`
`
`
`Adjusting the DRAM Refresh Rate Using the Temperature of
`the DRAM Array
`
`Id. at 4:49‐53.
`
`‘057 Patent, Ex. 1001, Fig. 3.
`
`Id. at Fig. 5
`PO Resp. at 52
`
`Id. at 4:49‐53.
`
`6
`
`
`
`Independent Claim 1 Is Illustrative of the Claimed Subject Matter
`
`1. An apparatus, comprising:
`a semiconductor package including at least one connection pin;
`at least one dynamic random access memory (DRAM) array disposed within
`the package; and
`at least one temperature sensor in thermal communication with the DRAM
`array, operable to produce a signal indicative of a temperature of the DRAM array,
`and coupled to the at least one connection pin such that the signal may be
`provided to external circuitry,
`wherein the DRAM array is refreshed at a rate that decreases as the
`temperature of the DRAM array decreases and that increases as the temperature
`of the DRAM array increases.
`
`7
`
`
`
`All Claims of ’057 Patent Are Obvious
`
`References
`Atkinson and Broadwater
`Atkinson, Broadwater, and Miller
`
`Independent Claims: 1, 13, and 16
`
`Claims Obvious
`in Light of References
`1, 3, 5–9, 12, 13, and 16
`2, 4, 10, 11, 14, 15, and 17
`
`Claim 13: Similar to Claim 1, except it includes a DRAM chipset
`comprising a “DRAM chip including a DRAM array and at least a
`temperature sensor” and a “refresh chip operable to refresh the
`DRAM array.” ’057 Patent, Ex. 1001, at 6:59–7:6.
`Claim 16: Similar to Claim 1, but a method claim for refreshing
`contents of a DRAM array at a rate that varies proportionally in
`response to temperature increases/decreases of the DRAM array. Id. at
`8:1–9.
`
`PO Resp. at 3
`
`8
`
`
`
`AMPLE REASON AND MOTIVATION TO
`COMBINE ATKINSON AND BROADWATER
`
`AMPLE REASON AND MOTIVATION TO
`
`COMBINE ATKINSON AND BROADWATER
`
`9
`
`
`
`Atkinson and Broadwater Are Directed to the Same Field
`
`Deposition of PO Expert, Ex. 1018, 38:3‐5.
`
`• Undisputed that Atkinson
`and Broadwater are in the
`same field.
`• PO concedes that “Atkinson
`and Broadwater both teach
`reducing circuit activity.”
`POR at 40.
`• Both references are
`concerned with reliability,
`temperature, and power
`consumption issues.
`
`Responsive to Reply at 9
`
`Id. at 40:5‐18.
`
`10
`
`
`
`Clear Reasons Why a POSITA Would Want to Add the
`Broadwater Functionality to Atkinson
`
`A POSITA would want to add Broadwater’s
`overheating protection to increase reliability in Atkinson.
`
`Broadwater, Ex. 1006, 1:25‐26.
`
`Safety and reliability are strong motivators to detect
`thermal stress and avoid damage to the memory in Atkinson.
`
`11
`
`
`
`Clear Reasons Why a POSITA Would Want to Add the
`Broadwater Functionality to Atkinson
`
`The invention in Broadwater is as important
`in the sleep state as it is in the active state.
`
`Deposition of PO Expert, Ex. 1018, 178:2‐13.
`
`12
`
`
`
`Clear Reasons Why a POSITA Would Want to Add the
`Broadwater Functionality to Atkinson
`
`1.
`
`An apparatus, comprising:
`a semiconductor package including at least one connection pin;
`at least one dynamic random access memory (DRAM) array
`disposed within the package; and
`at least one temperature sensor in thermal communication
`with the DRAM array, operable to produce a signal indicative of a
`temperature of the DRAM array, and coupled to the at least one
`connection pin such that the signal may be provided to external
`circuitry,
`wherein the DRAM array is refreshed at a rate that decreases as
`the temperature of the DRAM array decreases and that increases as
`the temperature of the DRAM array increases.
`
`Nothing in the
`claims requires that
`the external pin be
`used as part of the
`refresh process as
`long as it outputs a
`signal indicative of
`the temperature.
`
`Deposition of PO Expert, Ex. 1018, 156:5‐9.
`
`13
`
`
`
`A POSITA Could Add Another Pin to the Array
`
`Deposition of PO Expert, 1018, 176:19‐177:2.
`
`14
`
`
`
`Broadwater and Atkinson Teach Interoperability
`
`PO’s Expert Discussing Aircraft:
`
`Broadwater, Ex. 1006, 1:25‐29.
`
`Deposition of PO’s Expert, Ex. 1018, 166:8‐13.
`
`Atkinson, Ex. 1010, 24:35‐39.
`
`15
`
`
`
`A POSITA Could Replace Atkinson’s Thermistor
`
`Atkinson, Ex. 1010, 22:21‐26.
`
`Additionally, whether it is a diode, a thermocouple,
`or a thermistor, all of these temperature sensors
`require power to measure the temperature.
`
`16
`
`
`
`IT IS OBVIOUS TO USE A DIODE WITH ATKINSON
`
`IT IS OBVIOUS TO USE A DIODE WITH ATKINSON
`
`17
`
`
`
`Grounds for Invalidity Include Miller
`
`• Ground 2 in the Petition adds the teaching from Broadwater to the teaching of
`Atkinson.
`
`Petition, p. 30.
`
`• When discussing Atkinson
`and Broadwater, the
`Petition notes that a
`POSITA would know to use
`the diode in Miller
`
`Id., pp. 20, 40.
`
`18
`
`
`
`Grounds for Invalidity Include Miller
`
`• Institution Grounds included “Asserted Obviousness Over
`Atkinson, Broadwater, and Miller”
`Inst. Dec., pp. 18.
`
`• PO understood Atkinson, Broadwater, and Miller combination
`included all of the Petitioner’s arguments from Atkinson and
`Broadwater, both of which include Miller.
`See POR, pp. 31‐34 .
`
`19
`
`
`
`A POSITA Would Use a Diode in Atkinson
`
`Deposition of PO’s Expert, Ex. 1018, 180:6‐10.
`
`Atkinson, Ex. 1010, 22:21‐26.
`
`Broadwater, Ex. 1006, 3:55‐58.
`
`20
`
`
`
`A POSITA Would Know of the Diode in Miller
`
`Deposition of Petitioner’s Expert, Ex. 2009, 209:12‐17.
`
`Deposition of PO’s Expert, Ex. 1018, 189:11‐14.
`
`21
`
`
`
`Diode or Thermistor: Refresh Generator Remains the Same
`
`’057 Patent, Ex. 1001, 2:36‐45.
`
`22
`
`
`
`ATKINSON TEACHES THE “REFRESH UNIT”
`AND THE “REFRESH GENERATING UNIT”
`
`ATKINSON TEACHES THE ”REFRESH UNIT”
`
`AND THE ”REFRESH GENERATING UNIT”
`
`23
`
`
`
`ATKINSON TEACHES THE “REFRESH UNIT”
`AND THE “REFRESH GENERATING UNIT”
`
`ATKINSON TEACHES THE "REFRESH UNIT”
`
`AND THE "REFRESH GENERATING UNIT”
`
`CLAIM 6
`
`CLAIM 6
`
`IE. The apparatus cf claim 1, futthcr ccmprising—
`.cpcrahlc tc Icficsh the DRAM strayr at a tab: that Vflt‘lfifi
`1'11 rcspcnsc tc thc signal.
`
`CLAIM 7
`
`CLAIM 7
`
`T- Thc apparatus cf claim 15, whcrcih thc Icftcsh L1I1it
`includcs—c11crahlc tc cstahlish thc rats
`at which the [1M array,F is rcfrcshcd 1'I1 rcspcasc tc thc
`signal.
`
`24
`
`
`
`Atkinson Teaches the “Refresh Unit” of Claim 6
`
`Atkinson, Ex. 1010, 24:1‐23 and Fig. 9.
`
`25
`
`
`
`Atkinson Teaches the “Refresh Timing Unit” of Claim 7
`
`The voltage controlled oscillator (VCO) is the “refresh timing unit” of Claim 7
`
`Atkinson, Ex. 1010, 23:5‐19.
`
`26
`
`
`
`Atkinson Teaches the “Refresh Timing Unit” of Claim 7
`
`The refresh generator 850, using its components, establishes the rate that DRAM refreshes
`itself in response to the temperature indicative signal.
`
`PO Resp. at 21‐22
`
`Atkinson, Ex. 1010, Claim 7 and Fig. 8.
`
`27
`
`
`
`PO’S EXPERT’S OPINIONS RELY ON FAULTY
`DEFINITION OF POSITA
`
`PO'S EXPERT'S OPINIONS RELY ON FAULTY
`
`DEFINITION OF POSITA
`
`28
`
`
`
`PO’s Expert’s Analysis Was Not Based on the Proper
`Definition of a POSITA
`
`• Dr. Bernstein did not presume that a POSITA read,
`understood, and remembered the teachings of Atkinson
`and Broadwater. Deposition Tr., Ex. 1018, at 69:14‐24.
`
`• He was not prepared to apply a standard where the POSITA
`was presumed to have read, understood, and remembered
`every existing reference from the prior art. Id. at 65:13‐22.
`
`29
`
`
`
`PETITIONER’S REPLY DOES NOT INCLUDE
`NEW MATTER
`
`PETITIONER'S REPLY DOES NOT INCLUDE
`
`NEW MATTER
`
`30
`
`
`
`Reply Refutes Arguments in PO’s Response Regarding
`Motivation to Combine Broadwater and Atkinson
`
`POR, pp. 40‐41.
`
`Reply, § II.a ‐ .b, pp. 2‐3.
`31
`
`
`
`Reply Refutes Arguments in PO’s Response Regarding
`Safety and Overheating Protection
`
`POR, pp. 42.
`
`Reply, p. 12.
`
`32
`
`Deposition of PO Expert, Ex. 1018, 40:5‐18.
`
`
`
`Petition Notes that It Would Be Obvious to a POSITA to
`Use a Diode
`
`Petition, pp. 20‐21.
`
`33
`
`
`
`Reply Refutes Arguments in PO’s Response Regarding
`“Refresh Unit” and “Rate of Refresh”
`
`POR, pp. 58, 59.
`
`Reply, p. 20‐21.
`
`34
`
`
`
`Reply Refutes Arguments in PO’s Response that Atkinson and
`Broadwater Do Not Teach Increasing Rate in Response to Signal
`
`POR, p. 2.
`
`Reply, p. 20‐21.
`
`35
`
`
`
`Reply Refutes Arguments in PO’s Response Regarding Atkinson’s
`Sleep Mode
`
`POR, p. 59.
`
`Reply, p. 10.
`
`36
`
`
`
`Reply Refutes Arguments in PO’s Response Regarding
`Broadwater in Sleep Mode
`
`Reply, p. 4.
`
`37
`
`
`
`Reply Refutes Arguments in PO’s Response that Atkinson Does
`Not Include a Temperature Signal
`
`Reply, p. 5.
`
`38
`
`
`
`Reply Refutes Arguments in PO’s Response that Atkinson Does
`Not Include a Temperature Signal
`
`Reply, p. 21.
`
`39
`
`
`
`Reply Addresses the Credibility of PO’s Expert, Especially
`Regarding His Definition of POSITA
`
`Reply, p. 22.
`
`40
`
`
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