`
`
`Udo Hartmann, Sascha Nerger
`In re Patent of:
`7,124,325 Attorney Docket No.: 24069-0004IP2
`U.S. Patent No.:
`October 17, 2006
`
`Issue Date:
`Appl. Serial No.: 10/680,782
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`Filing Date:
`October 7, 2003
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`Title:
`Method And Apparatus for Internally Trimming Output
`Drivers and Terminations in Semiconductor Devices
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`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`
`
`PETITION FOR INTER PARTES REVIEW OF UNITED STATES PATENT
`NO. 7,124,325 PURSUANT TO 35 U.S.C. §§ 311–319, 37 C.F.R. § 42
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`Case IPR2017-01819
`Attorney Docket No: 24069-0004IP2
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`TABLE OF CONTENTS
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`Introduction .......................................................................................................... 1
`I.
`II. Requirements for IPR .......................................................................................... 1
` Standing ............................................................................................................ 1
` Challenge and Relief Requested ....................................................................... 1
`III. Background ....................................................................................................... 3
` Overview of the ’325 Patent ............................................................................. 3
`IV. CLAIM CONSTRUCTION ............................................................................. 6
`V. Application of prior art to challenged claims ...................................................... 8
` GROUND 1: Claims 14 and 16-18 are anticipated by Volk 450 under 35
`U.S.C. § 102 ............................................................................................................ 8
` GROUND 2: Claims 14 and 16-17 are anticipated by Volk 105 under 35
`U.S.C. § 102 .......................................................................................................... 38
` GROUNDS 3 & 4: Volk 105 or Volk 450 in view of Hiraki ........................ 59
`VI. THE GROUNDS PRESENTED IN THIS PETITION ARE NOT
`REDUNDANT AND THEIR CONSIDERATION IS WARRANTED ................. 70
`VII. CONCLUSION .............................................................................................. 72
`VIII. MANDATORY NOTICES UNDER 37 C.F.R § 42.8(a)(1) ......................... 74
` Real Party-In-Interest Under 37 C.F.R. § 42.8(b)(1) ..................................... 74
` Related Matters Under 37 C.F.R. § 42.8(b)(2) ............................................... 74
` Lead And Back-Up Counsel Under 37 C.F.R. § 42.8(b)(3) .......................... 74
` Service Information ........................................................................................ 75
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`Case IPR2017-01819
`Attorney Docket No: 24069-0004IP2
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`EXHIBIT LIST
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`Exhibit No.
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`Description
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`1001
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`1002
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`1003
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`1004
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`1005
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`1006
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`1007
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`1008
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`1009
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`1010
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`1011
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`U.S. Patent No. 7,124,325 (“the ’325 patent”)
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`Declaration of Nick Tredennick, Ph.D.
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`Return of Service for Complaint in Polaris Innovations Ltd. v.
`Dell Inc., and NVIDIA Corp., No. 5:16-CV-451-XR (W.D.
`Tex. 2016)
`U.S. Patent No. 6,693,450 (“Volk 450”)
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`U.S. Patent No. 6,356,105 (“Volk 105”)
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`Decision Denying Institution of Inter Partes Review dated June
`23, 2017 for Case No. IPR2017-00382.
`Patent Owner’s Preliminary Response to Petition for Inter
`Partes Review of Patent No. 7,124,325 (Case No. IPR2017-
`00382)
`U.S. Patent No. 6,201,733 (“Hiraki”)
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`Excerpts from Microsoft Computer Dictionary, Fifth Edition,
`2002
`Excerpts from Barron’s Dictionary of Computer and Internet
`Terms, Eighth Edition, 2003
`Excerpts from McGraw-Hill, Dictionary of Computing and
`Communications
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`I.
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`INTRODUCTION
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`Case IPR2017-01819
`Attorney Docket No: 24069-0004IP2
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`NVIDIA Corporation (“Petitioner” or “NVIDIA”) petitions for Inter Partes
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`Review (“IPR”) of claims 14 and 16-18, and 20 (“the Challenged Claims”) of
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`Patent No. 7,124,325 (“the ’325 patent”).
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`II. REQUIREMENTS FOR IPR
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`
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`Standing
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`Petitioner certifies that the ’325 patent is available for IPR. This petition is
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`being filed within one year of service of a complaint against Petitioner on July 25,
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`2016. See Ex. 1003, 6. Petitioner is not barred or estopped.
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` Challenge and Relief Requested
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`Petitioner requests IPR of the Challenged Claims on the grounds below, as
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`explained in this petition and in Ex. 1002.
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`Ground
`Ground 1
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`Ground 2
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`Ground 3
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`Ground 4
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`’325 Claims
`14, 16-18
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`14, 16-17
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`14, 16–18, 20
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`14, 16–18, 20
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`Basis
`Anticipated by Volk
`450
`Anticipated by Volk
`105
`Obvious over Volk 450
`in view of Hiraki
`Obvious over Volk 105
`in view of Hiraki
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`1
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`The filing date of the ’325 patent is October 7, 2003. It claims foreign
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`Case IPR2017-01819
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`priority to October 7, 2002. Each reference pre-dates this and qualifies as prior art,
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`e.g., as follows:
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`Reference
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`Date
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`Volk 450
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`September 29, 2000 (filed)
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`Section
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`102(e)
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`Volk 105
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`March 12, 2002 (issued)
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`102(b), (e), and (a)
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`Hiraki
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`March 13, 2001 (issued)
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`102(b), (e), and (a)
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`III. BACKGROUND
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` Overview of the ’325 Patent
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`The ’325 patent describes a method for adjusting the impedance of the
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`interface devices on an integrated circuit. See ’325 patent, 1:63-2:5; see also Ex.
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`1002 ¶ 16. The adjustment, which the ’325 patent calls “trimming” is done by
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`varying the impedance of the interface devices to improve the data transmission
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`rates. Id., 1:42-54 (“[T]he impedance of the output drivers…[,] which a
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`semiconductor device uses to effect a write access to the data bus,” is an interface
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`parameter that, if trimmed correctly, can allow for a higher data transmission
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`rate.”)
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`As the ’325 patent acknowledges though, trimming interface devices
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`predates the ’325 patent. Id. at 2:31-50. Even the ’325 inventors conceded that
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`prior art methods of trimming existed to trim the interface devices “before or
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`during the initial startup…or repeatedly during [] operation.” Id. 2:6-17. Indeed,
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`the ’325 patent observes that interface devices have settable “control elements…in
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`the form of switchable impedances whose respective value can be programmed”
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`based on a value saved in a “trimming register.” Id.; see also Ex. 1002 ¶¶ 17–19.
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`The ’325 patent purports to improve the prior art by providing a “trimming
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`unit ... within the semiconductor device” rather than within an external device.
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`3
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`Figure 3 shows the proposed integration of the “trimming unit” into the
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`semiconductor device:
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`trimming unit
`in the device
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`As shown in Figure 3 above, trimming unit 5 is connected to the interface
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`devices 10a-10d, and to trimming registers 14. Id., Fig. 3, 8:4-11. Trimming
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`registers 14 are connected to the settable control elements of the interface devices,
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`4
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`which have settable impedances. Id. To trim the interface devices, the trimming
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`unit compares the voltage measured from the interface device (UM) with a nominal
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`voltage, US, and if the measured voltage is smaller, the trimming unit increases the
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`value of trimming registers 14. Id., 8:12-22; see also Ex. 1002 ¶ 20–21.
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`Figure 4 (below) shows additional details of the trimming unit. In particular,
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`comparator unit 56 compares the measured voltage UM with nominal voltage US.
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`Id., 8:39-59. Based on that comparison, logic unit 57 either writes a new value to
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`trimming registers 14, or else it writes the existing trimming value to nonvolatile
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`memory unit 59. Id.; see also Ex. 1002 ¶ 22.
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`5
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`comparator compares
`the measurement
`voltage UM with
`nominal voltage US
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`IV. CLAIM CONSTRUCTION
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`A claim subject to IPR is given its “broadest reasonable construction in light
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`of the specification of the patent in which it appears.” 37 C.F.R. § 42.100(b).
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`In an earlier proceeding involving the ’325 patent, the Board construed the
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`term “interface device,” recited in independent claim 14, as a device “associated
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`with an interface” and “‘between the semiconductor device’ and ‘another device
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`external to the semiconductor device.’” See Ex. 1006, 10. As the Board explained,
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`such a construction was mandated by the specification’s “consistent usage of the
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`term ‘interface device’” to describe a device associated with an interface between
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`the semiconductor device and something external to the semiconductor device.
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`See id. at 8–9. As will be demonstrated below, the prior art cited herein meets the
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`Board’s previous construction of interface device.
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`At this time, Petitioner contends that no additional terms require
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`construction for the purposes of this IPR. However, Petitioner notes that Patent
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`Owner previously asked the Board to construe certain other terms that are relevant
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`to the current IPR. For example, the Patent Owner argued that “trimming” means
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`“adjusting.” Ex. 1007, 20. Although Petitioner believes an explicit construction of
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`the term “trimming” is not necessary for the purposes of this IPR, Petitioner
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`believes that the grounds of the present petition disclose trimming under Patent
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`Owner’s previous proposed construction of this term.
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`Patent Owner also previously proposed that “settable control element”
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`should mean “a circuit element, the impedance of which can be programmed,
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`adjusted, or set.” Id. at 23. Patent Owner previously argued that this “settable
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`control element” must be “part of an ‘interface device.’” Id. at 21. Petitioner
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`believes this term does not require construction for purposes of this IPR. However,
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`again, even under Patent Owner’s previously proposed construction, the settable
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`control element limitation is met by each ground of the present Petition. The
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`Patent Owner also previously argued for the construction of additional terms that
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`are not relevant to the claims challenged in this IPR.
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`Petitioner reserves the right to assert claim construction positions in district
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`court proceedings that apply a different claim construction standard.1
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`V. APPLICATION OF PRIOR ART TO CHALLENGED CLAIMS
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`As detailed above (incorporated herein) and below, this request shows a
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`reasonable likelihood that Petitioner will prevail on the Challenged Claims.
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` GROUND 1: Claims 14 and 16-18 are anticipated by Volk 450
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`under 35 U.S.C. § 102
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` The claim construction standard for district court (“ordinary and customary
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`meaning”) is different than the broadest reasonable interpretation standard applied
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`in IPR. Due to the different standards, disclosure of the references identified by
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`Petitioner as teaching a claim term of the ’325 patent is not an admission that the
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`claim term is met by any disclosure for infringement purposes, or that the claim
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`term is enabled or meets the requirements for written description.
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`Volk 450
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`As set forth below, like the ’325 patent, Volk 450 describes a semiconductor
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`device that includes an on-chip trimming unit for adjusting the impedance of an
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`interface device. See Ex. 1002, ¶ 26. This semiconductor device can be seen in
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`Figure 3:
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`As shown in Figure 3, the semiconductor device of Volk 450 includes 3
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`major components: (1) a driver 52 which drives data off the device to a receiver,
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`(2) a tuner 72 that senses the voltage signal and adjusts the impedance of the driver
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`52, and (3) an RCOMP controller 64 that programs the initial impedance of the
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`drivers and provides a reference voltage. See Ex. 1004, 2:22-25 (“FIG. 3 shows a
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`driver system 50 configured to transmit data on bus line 58 to a receiver with pull-
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`up impedance, such as receiver 18 shown in FIG. 1a.”); id., 3:31-34 (“Tuner 72
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`includes a comparator 90, which receives the feedback voltage 60 as one input and
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`the regulated VSWING voltage 84 as another input.”); id., 3:16-17 (“RCOMP
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`controller 64 initially sets pull-down driving element 82 impedance”); see also Ex.
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`1002 ¶ 27.
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`In operation, a transmitting semiconductor device from Volk 450 transmits
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`data over a data line or “bus” to a receiving semiconductor device, as shown
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`below:
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`10
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`See also Ex. 1004, 1:47-50 (“FIG. la and lb are diagrams showing typical parallel
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`interfaces. In parallel interface 10 shown in FIG. la, a driver 12 in a sending circuit
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`14 transmits data along a bus line 16 to a receiver 18 in a receiving circuit 20.”);
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`Ex. 1002 ¶ 28.
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`Importantly, the Volk 450’s driver 52 and tuner 72 are designed such that
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`the “impedance of the driver element is dynamically adjustable.” Id., Abstract. To
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`adjust the impedance, the voltage on the data line is fed back to tuner 72. Id., 3:30-
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`31. Tuner 72 has a comparator that compares the voltage on the data line (“voltage
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`60”) with a reference voltage (“VSWING”) provided by the “RCOMP Controller.”
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`Id., 3:31-34; see also Ex. 1002 ¶ 29. The comparator and these connections are
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`shown in Figure 3 below:
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`Based on these inputs, the comparator determines which of the data line and
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`reference voltage “is higher, and produces an error signal 92.” Id., 3:35-44. The
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`signal is sent to the tuner controller, which uses the signal to determine whether the
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`12
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`adder should be updated. Id., 3:45-52. Adjusting the value in the adder results in
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`an adjustment to the impedance of the interface device. See id. This in turn
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`adjusts the voltage on the data line, and the process repeats until the tuner adjusts
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`the data line voltage to match the reference voltage as close as possible. Ex. 1004,
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`3:56-59; see also Ex. 1002 ¶ 30.
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`Application of Prior Art to Challenged Claims
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`[14.0]: A semiconductor device comprising:
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`Volk 450 discloses a semiconductor device in Figure 3, which shows “a
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`block diagram of a driver system.” Ex. 1004, 1:31-32. The driver system of Volk
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`450 is clearly a semiconductor device as it is described as including “a pull-up
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`driver element 80 and a pull-down driver element 82.” An example driver element
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`82 is shown in Figure 4. Id., 4:8-11 (“FIG. 4 is a diagram of an exemplary
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`programmable pull-down driver element 82.”). Figure 4 is described as including
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`a “set of n-channel metal oxide semiconductor field effect transistors
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`(MOSFETs) 106 are arrayed in parallel between terminals 102 and 104.” Id., 4:9-
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`12; see also Ex. 1002 ¶ 31–32. The MOSFET semiconductors of Volk 450 are
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`shown below:
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`Additionally, the driver system of Volk 450 includes Predriver and Logic 54,
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`tuner 72 (including Tuner Controller 100 with memory 96), and RCOMP
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`Controller 64 (which receives a clock signal 94) – all of which are semiconductors
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`and further confirm that the driver system 50 of Volk 450 is a “semiconductor
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`device.” See Ex. 1002 ¶ 33. These elements are each shown below in Figure 3:
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` [14.1]: at least one interface device having a settable control element;
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`The driver 56 of Volk 450 is an interface device that has a settable control
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`element. First, as described below, driver elements 56 meet the PTAB’s prior
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`construction of “interface device” which requires that the device be associated with
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`an interface” that is “‘between the semiconductor device’ and ‘another device
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`external to the semiconductor device.’” Ex. 1006, 10. Next, as also described
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`below, “the impedance of driver elements 56 is programmable and dynamically
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`adjustable,” i.e., its control elements are settable as claimed.
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`First, the driver 56 of Volk 450 is associated with an interface. In particular,
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`the drivers in Volk 450 are associated with a “typical parallel interface,” such as
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`parallel interface 10 shown in Figure 1A (reproduced below).
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`As shown above, the parallel interface 10 includes a driver 12 in a sending
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`circuit 14 which “transmits data along a bus line 16 to a receiver 18.” Ex. 1004,
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`1:46-50. As such, the interface in Volk 450 comprises a driver and a bus line that
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`connects to a receiver.” Volk 450 explains that driver system 50 (including drivers
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`56) can be used with a parallel interface like that shown in Figure 1a, explaining
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`that “FIG. 3 shows a driver system 50 configured to transmit data on bus line 58 to
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`a receiver with pull-up impedance, such as receiver 18 shown in FIG. 1a.” Id.,
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`2:22-25; Ex. 1002 ¶ 35. The bus line 58 and its connection to driver 56 can be
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`seen in Figure 3:
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`Accordingly, the drivers 56 are associated with the interface as the Board’s
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`construction requires. See Ex. 1002 ¶¶ 36.
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`Next, the driver 56 (the interface device) is associated with an interface that
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`is between the semiconductor device housing the interface device and another
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`device external to the semiconductor device, as required by the Board’s
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`construction. In particular, Volk 450 discloses a “device comprising a driver
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`configured to transmit a signal on a bus line” to another device that is the receiver
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`of the data. Id., Abstract; 1:47-50 (“FIG. la and lb are diagrams showing typical
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`parallel interfaces. In parallel interface 10 shown in FIG. la, a driver 12 in a
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`sending circuit 14 transmits data along a bus line 16 to a receiver 18 in a receiving
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`circuit 20.”); claims 1, 5, and 9; Figs. 1A and 1B:
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`transmitting
`devices with
`a “Driver”
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`“Receiver”
`devices with
`a termination
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`See also Ex. 1002 ¶ 37.
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`As noted above, Volk 450 specifically states that the driver system 50 is
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`“configured to transmit data on bus line 58 to a receiver … such as receiver 18 as
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`shown in FIG. 1a.” Ex. 1004, 2:22-25. As can be clearly seen, the receiver 18 is
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`external from the driver 12 shown in Figure 1a and connected via the bus line 16.
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`When, as Volk 450 explicitly describes, driver system 50 (and thus driver 56) is
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`used to transmit data over bus line 58 to receiver 18, it is undeniably sending data
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`over the interface to a receiver that is external to the driver system 50. See Ex.
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`1002 ¶ 38.
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`Moreover, Volk 450 provides additional detail regarding the operation of
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`drivers that further show that the drivers 56 transmit to a device external to the
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`driving system 50. In particular, Volk 450 explains that “[a] driver is a digital
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`electronic circuit for holding a binary value, and communicating it to other circuits
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`to which it is connected. The binary value is represented by a voltage level. It is
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`common to connect a driver to a data bus for communicating the binary value to a
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`receiving circuit by ‘driving’ the bus to a desired voltage level.” Id., 1:7-12; Ex.
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`1002 ¶ 39.
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`Next, the interface device of Volk 450 has a “settable control element,” as
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`this limitation requires. In particular, according to Volk 450, “[d]river elements 56
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`comprise a pull-up driver element 80 and a pull-down driver element 82.” Id.,
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`2:29-40. The pull down driver element 82 is annotated in the version of Figure 3
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`shown below:
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`See also Ex. 1002 ¶ 40. Volk 450 explains that “[t]he impedance of pull-up driver
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`element 80 and the impedance of pull-down driver element 82 are
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`programmable… To facilitate the dynamic adjustment of the output impedance of
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`driver system 50, the impedance of pull-up driver element 80 and the impedance of
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`pull-down driver element 82 are electronically adjustable.” Id., 2:29-40 (emphasis
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`added); see also Fig. 5. This “adjustable” and “programmable” impedance is the
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`“settable control element” recited in the ’325 patent. See Ex. 1002 ¶ 41.
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`In even more detail, the “Pull-Down Driver Element” (illustrated in Figure
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`3, reproduced above) includes “[a] set of n-channel metal oxide semiconductor
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`field-effect transistors (MOSFETs) 106 [that] are arrayed in parallel between
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`terminals 102 and 104. Terminal 102 is connected to output bus line 58, and
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`terminal 104 is connected to circuit ground 32.” Id., 4:9-13; Fig. 4:
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`driver element
`with MOSFETS
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`By selectively enabling the MOSFETs, the impedance of the output driver
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`can be made “adjustable” and “programmable.” Id., 4:9-16 (“The number and
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`values of MOSFETs 106 that are turned on when pull-down driver element 100 is
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`enabled determines the impedance between terminals 102 and 104.”) (emphasis
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`added); see also Ex. 1002 ¶ 43. Volk 450 discloses additional details about how
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`the driver is adjusted or trimmed, which are discussed in Ground 1:[14.3].
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`Volk 450’s driver elements with “adjustable,” “programmable” output
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`impedances meet even Polaris’ previously asserted construction of “settable
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`control element.” In its Patent Owner Preliminary Response, Polaris argued that
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`“settable control element” should be construed as “a circuit element, the
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`impedance of which can be programmed, adjusted, or set.” Ex. 1007, 23.2
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`Petitioner does not believe that construction of “settable control element” is
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`necessary, but even under Polaris’ construction, Volk 450 is clear that the driver
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`element’s impedance may be programmed and adjusted. See Ex. 1004, 2:30-40
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`(“The impedance of pull-up driver element 80 and the impedance of pull-down
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`driver element 82 are programmable… To facilitate the dynamic adjustment of
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`the output impedance of driver system 50, the impedance of pull-up driver
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`element 80 and the impedance of pull-down driver element 82 are electronically
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` The PTAB declined to construe “settable control element.” Ex. 1006, 10.
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`adjustable.”) (emphasis added); see also Ex. 1002 ¶ 44. As a result, Volk 450
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`discloses at least one interface device having a settable control element.
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`Moreover, the driver elements 56 disclosed by Volk 450 are the same type
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`of “output driver” recited by the ’325 patent as one of two exemplary “interface
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`devices.” Ex. 1001, 3:18-20 (“a method for trimming interface devices such as
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`output drivers and terminations in semiconductor devices”). The “output
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`impedance” of the driver discussed above for Volk 450 is the same parameter
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`disclosed by the ’325 patent as the “settable control element” of the interface
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`device: “[a] first such interface parameter is the impedance of the output drivers
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`(OCD-off chip driver), which a semiconductor device uses to effect a write access
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`to the data bus, or to output data signals to the data bus.” Id., 1:42-45; see also Ex.
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`1002 ¶ 45.
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`[14.2]: a trimming register connected to said control element; and
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`Volk 450 discloses a trimming register connected to the control element. A
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`register is a circuit “with memory elements that can store from a few to millions of
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`bits of coded information…” Ex. 1011; see also Ex. 1002, ¶ 47. As the ’325
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`patent explains, the “value in the trimming register 14 is taken as a basis for
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`altering the control elements 12, 17, for example, by increasing an impedance in
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`stages.” Ex. 1001, 7:34-37. No structure for the trimming register 14 is provided
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`in the ’325 patent other than its ability to store the value that will be used to trim
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`the impedance.
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`Just like the ’325 patent, Volk 450 describes a trimming register (Adder 98)
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`that is connected to the “Pull-Down Driver Element” (control element). Id., Figure
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`3. In particular, Adder 98 (shown below) is described as being configured to
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`“digitally increase or decrease digital pull-down control signal 70, thereby
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`increasing or decreasing the impedance of pull-down driver element 82.” Id., 3:48-
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`52. “Tuner controller 100 can make adjustments in large or small increments with
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`adder 98.” Id.; see also Ex. 1002 ¶ 48.
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`The adder provides a “digital pull-down control signal 70” (depicted above),
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`and Adder 98’s value is set based on information from the trimming unit portion of
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`“tuner controller 100.” Id., 3:48-52; Ex. 1002, ¶ 49. As such, the adder 98 either
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`is or includes a register that stores a value that is used to trim or adjust the
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`impedance of the driver element. Id. The value stored in the adder is based on the
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`input received from the trimming unit, described in additional detail below in
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`Ground 1: [14.3]; see also Ex. 1002 ¶ 49. Accordingly, Volk 450 discloses a
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`trimming register connected to the control element.
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`[14.3]: a trimming unit for writing to said trimming register based on a
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`measured variable detected on said interface device;
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`Volk 450 also discloses a tuner 72 in the semiconductor device for writing to
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`the trimming register based on a measured variable detected on the interface
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`device. First, as noted above in Ground 1: [14.2], the tuner controller 100 within
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`the tuner 72 is configured to program (i.e., write to) the adder 98 when it
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`determines a need to adjust the impedance of the driver 56. Ex. 1004, 3:47-62
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`(noting that the “tuner controller 100 includes an adder 98 to digitally increase or
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`decrease the impedance of pull-down driver element 82.”); see also Ex. 1002 ¶ 50.
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`The remaining portion of the tuner 72 is described as making the
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`adjustments to the impedance (via the adder 98) based on a measured variable
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`detected on the interface device. In particular, Volk 450 “presents a method of
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`electronically adjusting the impedance of the driver element to regulate the swing
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`voltage on the bus line.” Id., Abstract (emphasis added); see also id., 1:5-6 (“This
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`invention relates to dynamic output impedance adjustment.”); 2:7-9 (“If signal
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`reflections are minimized, the swing voltage can be safely regulated by
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`dynamically adjusting the output impedance of the driver.”). Volk 450 describes
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`that this “adjusting” or trimming is needed “[t]o compensate for shifts in the swing
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`voltage” that occur when the “terminating impedance” (the impedance of the
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`receiving device) is “different from the expected value,” or due to impedance
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`changes from “loading at the receiver, heating or other factors.” Id., 3:21-29; see
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`also Ex. 1002 ¶ 51.
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`To achieve the desired compensation, the Tuner 72 “dynamically adjust[s]”
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`“the impedance of pull-down driver element 82.” Id., 2:44-47. To perform this
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`adjustment, the voltage on the data line is fed back to tuner 72. Id., 3:30-31
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`(“Dynamic compensation is accomplished by feeding back the voltage 60
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`transmitted on bus line 58 to tuner 72.”); Fig. 3:
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`“voltage 60” is
`fed back to the
`comparator of the
`tuner controller
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`See Ex. 1002 ¶ 53. The tuner includes a comparator, which is part of the trimming
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`unit. The comparator compares the voltage on the data line (“voltage 60”) with a
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`reference voltage (“VSWING”) provided by the “RCOMP Controller.” Id., 3:31-
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`34 (“Tuner 72 includes a comparator 90, which receives the feedback voltage 60 as
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`one input and the regulated VSWING voltage 84 as another input.”). The “voltage
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`60” is the recited “measured variable detected on [the] interface device” of claim
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`14. The interface device includes driver elements 56, and the measured variable is
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`measured right from the data line that connects to the driver elements. See Ex.
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`1002 ¶ 54.
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`The comparator of the trimming unit compares its inputs to determine which
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`of the data line and reference voltage “is higher, and produces an error signal 92.”
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`Id., 3:35-44 (“Comparator 90 compares the two input voltages 60 and 84 and
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`determines which of the two is higher, and produces an error signal 92. The
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`polarity of comparator 90 shown in FIG. 3 is arbitrary, but for illustrative purposes
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`VSWING voltage 84 is applied to the noninverting input. Consequently, when the
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`voltage 60 transmitted on bus line 58 is the higher of the two voltages, comparator
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`90 generates a voltage LOW error signal, and when the regulated VSWING
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`voltage 84 is higher, comparator 90 generates a voltage HIGH error signal 92.”);
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`see also Ex. 1002 ¶ 55.
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`This error signal is sent to the tuner controller, which includes “adder 98.”
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`The tuner controller 100 writes to the adder 98 by incrementing or decrementing it
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`as appropriate based on the error signal. In other words, based on whether the data
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`line voltage is higher or lower than the reference voltage. Because adder 98 is
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`connected to the pull-down driver element, and because it controls the impedance
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`of that element, adjusting the adder results in an adjustment to the impedance of
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`the interface device. See id., 3:45-51. This in turn adjusts the voltage on the data
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`line, and the process repeats until the tuner adjusts the data line voltage to match
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`the reference voltage as close as possible. Ex. 1004, 3:56-59 (“By repeatedly
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`increasing or decreasing the impedance, tuner 72 ‘homes in’ on the impedance of
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`pull-down driver element 82 that produces a voltage LOW signal as close to
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`VSWING 84 as possible.”); see also Ex. 1002 ¶ 56.
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`Volk 450 provides further disclosure on the iterative nature of the trimming
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`performed by the tuner. The process is summarized in Figure 5, which begins by
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`setting the driver with a starting value. Ex. 1002 ¶ 57. In step 122 the voltage on
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`the data bus, which also connects to the driver (interface device) is measured. Id.,
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`Fig. 5 (reproduced below); see also claim 5. If the data bus voltage is too low,
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`then the tuner will calculate an impedance adjustment (if an adjustment is not
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`pending) and will then adjust the impedance. Id. The voltage on the data bus is
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`then measured again, and the process repeats, adjusting the impedance as needed if
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`the voltage is too high or too low based on the comparison with the reference
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`voltage. Id.; see also Ex. 1002 ¶ 58.
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`Accordingly, Volk 450 discloses a trimming unit (comparator and part of the
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`tuner controller) for writing to the trimming register (adder) based on a measured
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`variable (the voltage on the data bus that connects to the driver) detected on the
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`interface device (the driver element).
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`[14.4]: said trimming unit connected to said interface device and said trimming
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`register.
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`See Ground 1: [14.0]- [14.3]. The trimming unit of Volk 450 is connected to
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`the trimming register (adder 98) and the interface device (driver elements 56,
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`including pull-down driver element 82). This is illustrated below in Figure 3:
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`the trimming unit
`(red) is connected to
`the interface device
`(blue) and the
`trimming register
`(green)
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`See also Ex. 1002 ¶ 60.
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`[16]: The semiconductor device according to claim 14, wherein said trimming
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