IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`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
`
`Filing Date:
`October 7, 2003
`
`Title:
`Method And Apparatus for Internally Trimming Output
`Drivers and Terminations in Semiconductor Devices
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`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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`

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`
`Case IPR2017-01819
`Attorney Docket No: 24069-0004IP2
`
`TABLE OF CONTENTS
`
`
`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
`
`Exhibit No.
`
`Description
`
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`U.S. Patent No. 7,124,325 (“the ’325 patent”)
`
`Declaration of Nick Tredennick, Ph.D.
`
`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”)
`
`U.S. Patent No. 6,356,105 (“Volk 105”)
`
`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”)
`
`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
`
`iii
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`I.
`
`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
`
`Review (“IPR”) of claims 14 and 16-18, and 20 (“the Challenged Claims”) of
`
`Patent No. 7,124,325 (“the ’325 patent”).
`
`II. REQUIREMENTS FOR IPR
`
`
`
`Standing
`
`Petitioner certifies that the ’325 patent is available for IPR. This petition is
`
`being filed within one year of service of a complaint against Petitioner on July 25,
`
`2016. See Ex. 1003, 6. Petitioner is not barred or estopped.
`
` Challenge and Relief Requested
`
`Petitioner requests IPR of the Challenged Claims on the grounds below, as
`
`explained in this petition and in Ex. 1002.
`
`Ground
`Ground 1
`
`Ground 2
`
`Ground 3
`
`Ground 4
`
`
`
` 
`
`’325 Claims
`14, 16-18
`
`14, 16-17
`
`14, 16–18, 20
`
`14, 16–18, 20
`
`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
`
`1
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`

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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
`Attorney Docket No: 24069-0004IP2
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` 
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`priority to October 7, 2002. Each reference pre-dates this and qualifies as prior art,
`
`e.g., as follows:
`
`Reference
`
`Date
`
`Volk 450
`
`September 29, 2000 (filed)
`
`Section
`
`102(e)
`
`Volk 105
`
`March 12, 2002 (issued)
`
`102(b), (e), and (a)
`
`Hiraki
`
`March 13, 2001 (issued)
`
`102(b), (e), and (a)
`
`
`
`2
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`III. BACKGROUND
`
` Overview of the ’325 Patent
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`Case IPR2017-01819
`Attorney Docket No: 24069-0004IP2
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`The ’325 patent describes a method for adjusting the impedance of the
`
`interface devices on an integrated circuit. See ’325 patent, 1:63-2:5; see also Ex.
`
`1002 ¶ 16. The adjustment, which the ’325 patent calls “trimming” is done by
`
`varying the impedance of the interface devices to improve the data transmission
`
`rates. Id., 1:42-54 (“[T]he impedance of the output drivers…[,] which a
`
`semiconductor device uses to effect a write access to the data bus,” is an interface
`
`parameter that, if trimmed correctly, can allow for a higher data transmission
`
`rate.”)
`
`As the ’325 patent acknowledges though, trimming interface devices
`
`predates the ’325 patent. Id. at 2:31-50. Even the ’325 inventors conceded that
`
`prior art methods of trimming existed to trim the interface devices “before or
`
`during the initial startup…or repeatedly during [] operation.” Id. 2:6-17. Indeed,
`
`the ’325 patent observes that interface devices have settable “control elements…in
`
`the form of switchable impedances whose respective value can be programmed”
`
`based on a value saved in a “trimming register.” Id.; see also Ex. 1002 ¶¶ 17–19.
`
`The ’325 patent purports to improve the prior art by providing a “trimming
`
`unit ... within the semiconductor device” rather than within an external device.
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` 
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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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`Case IPR2017-01819
`Attorney Docket No: 24069-0004IP2
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`semiconductor device:
`
`trimming unit
`in the device
`
`
`As shown in Figure 3 above, trimming unit 5 is connected to the interface
`
`devices 10a-10d, and to trimming registers 14. Id., Fig. 3, 8:4-11. Trimming
`
`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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`Case IPR2017-01819
`Attorney Docket No: 24069-0004IP2
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`unit compares the voltage measured from the interface device (UM) with a nominal
`
`voltage, US, and if the measured voltage is smaller, the trimming unit increases the
`
`value of trimming registers 14. Id., 8:12-22; see also Ex. 1002 ¶ 20–21.
`
`Figure 4 (below) shows additional details of the trimming unit. In particular,
`
`comparator unit 56 compares the measured voltage UM with nominal voltage US.
`
`Id., 8:39-59. Based on that comparison, logic unit 57 either writes a new value to
`
`trimming registers 14, or else it writes the existing trimming value to nonvolatile
`
`memory unit 59. Id.; see also Ex. 1002 ¶ 22.
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`5
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`Case IPR2017-01819
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`comparator compares
`the measurement
`voltage UM with
`nominal voltage US
`
`
`
`IV. CLAIM CONSTRUCTION
`
`
`
`A claim subject to IPR is given its “broadest reasonable construction in light
`
`of the specification of the patent in which it appears.” 37 C.F.R. § 42.100(b).
`
`In an earlier proceeding involving the ’325 patent, the Board construed the
`
`term “interface device,” recited in independent claim 14, as a device “associated
`
`with an interface” and “‘between the semiconductor device’ and ‘another device
`
`external to the semiconductor device.’” See Ex. 1006, 10. As the Board explained,
`6
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`such a construction was mandated by the specification’s “consistent usage of the
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`Case IPR2017-01819
`Attorney Docket No: 24069-0004IP2
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`term ‘interface device’” to describe a device associated with an interface between
`
`the semiconductor device and something external to the semiconductor device.
`
`See id. at 8–9. As will be demonstrated below, the prior art cited herein meets the
`
`Board’s previous construction of interface device.
`
`At this time, Petitioner contends that no additional terms require
`
`construction for the purposes of this IPR. However, Petitioner notes that Patent
`
`Owner previously asked the Board to construe certain other terms that are relevant
`
`to the current IPR. For example, the Patent Owner argued that “trimming” means
`
`“adjusting.” Ex. 1007, 20. Although Petitioner believes an explicit construction of
`
`the term “trimming” is not necessary for the purposes of this IPR, Petitioner
`
`believes that the grounds of the present petition disclose trimming under Patent
`
`Owner’s previous proposed construction of this term.
`
`Patent Owner also previously proposed that “settable control element”
`
`should mean “a circuit element, the impedance of which can be programmed,
`
`adjusted, or set.” Id. at 23. Patent Owner previously argued that this “settable
`
`control element” must be “part of an ‘interface device.’” Id. at 21. Petitioner
`
`believes this term does not require construction for purposes of this IPR. However,
`
`again, even under Patent Owner’s previously proposed construction, the settable
`
`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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`Attorney Docket No: 24069-0004IP2
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`are not relevant to the claims challenged in this IPR.
`
`Petitioner reserves the right to assert claim construction positions in district
`
`court proceedings that apply a different claim construction standard.1
`
`
`
`
`
`V. APPLICATION OF PRIOR ART TO CHALLENGED CLAIMS
`
`As detailed above (incorporated herein) and below, this request shows a
`
`reasonable likelihood that Petitioner will prevail on the Challenged Claims.
`
` GROUND 1: Claims 14 and 16-18 are anticipated by Volk 450
`
`under 35 U.S.C. § 102
`
`
`
`                                                            
`
` 1
`
` The claim construction standard for district court (“ordinary and customary
`
`meaning”) is different than the broadest reasonable interpretation standard applied
`
`in IPR. Due to the different standards, disclosure of the references identified by
`
`Petitioner as teaching a claim term of the ’325 patent is not an admission that the
`
`claim term is met by any disclosure for infringement purposes, or that the claim
`
`term is enabled or meets the requirements for written description.
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`Volk 450
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`Case IPR2017-01819
`Attorney Docket No: 24069-0004IP2
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`As set forth below, like the ’325 patent, Volk 450 describes a semiconductor
`
`device that includes an on-chip trimming unit for adjusting the impedance of an
`
`interface device. See Ex. 1002, ¶ 26. This semiconductor device can be seen in
`
`Figure 3:
`
`
`As shown in Figure 3, the semiconductor device of Volk 450 includes 3
`
`major components: (1) a driver 52 which drives data off the device to a receiver,
`
`(2) a tuner 72 that senses the voltage signal and adjusts the impedance of the driver
`9
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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
`
`driver system 50 configured to transmit data on bus line 58 to a receiver with pull-
`
`up impedance, such as receiver 18 shown in FIG. 1a.”); id., 3:31-34 (“Tuner 72
`
`includes a comparator 90, which receives the feedback voltage 60 as one input and
`
`the regulated VSWING voltage 84 as another input.”); id., 3:16-17 (“RCOMP
`
`controller 64 initially sets pull-down driving element 82 impedance”); see also Ex.
`
`1002 ¶ 27.
`
`In operation, a transmitting semiconductor device from Volk 450 transmits
`
`data over a data line or “bus” to a receiving semiconductor device, as shown
`
`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
`
`interfaces. In parallel interface 10 shown in FIG. la, a driver 12 in a sending circuit
`
`14 transmits data along a bus line 16 to a receiver 18 in a receiving circuit 20.”);
`
`Ex. 1002 ¶ 28.
`
`Importantly, the Volk 450’s driver 52 and tuner 72 are designed such that
`
`the “impedance of the driver element is dynamically adjustable.” Id., Abstract. To
`
`adjust the impedance, the voltage on the data line is fed back to tuner 72. Id., 3:30-
`
`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
`
`shown in Figure 3 below:
`
`
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`
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`Based on these inputs, the comparator determines which of the data line and
`
`reference voltage “is higher, and produces an error signal 92.” Id., 3:35-44. The
`
`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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`Case IPR2017-01819
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`an adjustment to the impedance of the interface device. See id. This in turn
`
`adjusts the voltage on the data line, and the process repeats until the tuner adjusts
`
`the data line voltage to match the reference voltage as close as possible. Ex. 1004,
`
`3:56-59; see also Ex. 1002 ¶ 30.
`
`Application of Prior Art to Challenged Claims
`
`[14.0]: A semiconductor device comprising:
`
`Volk 450 discloses a semiconductor device in Figure 3, which shows “a
`
`block diagram of a driver system.” Ex. 1004, 1:31-32. The driver system of Volk
`
`450 is clearly a semiconductor device as it is described as including “a pull-up
`
`driver element 80 and a pull-down driver element 82.” An example driver element
`
`82 is shown in Figure 4. Id., 4:8-11 (“FIG. 4 is a diagram of an exemplary
`
`programmable pull-down driver element 82.”). Figure 4 is described as including
`
`a “set of n-channel metal oxide semiconductor field effect transistors
`
`(MOSFETs) 106 are arrayed in parallel between terminals 102 and 104.” Id., 4:9-
`
`12; see also Ex. 1002 ¶ 31–32. The MOSFET semiconductors of Volk 450 are
`
`shown below:
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`13
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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
`
`Controller 64 (which receives a clock signal 94) – all of which are semiconductors
`
`and further confirm that the driver system 50 of Volk 450 is a “semiconductor
`
`device.” See Ex. 1002 ¶ 33. These elements are each shown below in Figure 3:
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`14
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`Case IPR2017-01819
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` [14.1]: at least one interface device having a settable control element;
`
`The driver 56 of Volk 450 is an interface device that has a settable control
`
`element. First, as described below, driver elements 56 meet the PTAB’s prior
`
`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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`Case IPR2017-01819
`Attorney Docket No: 24069-0004IP2
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`external to the semiconductor device.’” Ex. 1006, 10. Next, as also described
`
`below, “the impedance of driver elements 56 is programmable and dynamically
`
`adjustable,” i.e., its control elements are settable as claimed.
`
`First, the driver 56 of Volk 450 is associated with an interface. In particular,
`
`the drivers in Volk 450 are associated with a “typical parallel interface,” such as
`
`parallel interface 10 shown in Figure 1A (reproduced below).
`
`
`As shown above, the parallel interface 10 includes a driver 12 in a sending
`
`circuit 14 which “transmits data along a bus line 16 to a receiver 18.” Ex. 1004,
`
`1:46-50. As such, the interface in Volk 450 comprises a driver and a bus line that
`
`connects to a receiver.” Volk 450 explains that driver system 50 (including drivers
`
`56) can be used with a parallel interface like that shown in Figure 1a, explaining
`
`that “FIG. 3 shows a driver system 50 configured to transmit data on bus line 58 to
`16
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`a receiver with pull-up impedance, such as receiver 18 shown in FIG. 1a.” Id.,
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`Case IPR2017-01819
`Attorney Docket No: 24069-0004IP2
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`2:22-25; Ex. 1002 ¶ 35. The bus line 58 and its connection to driver 56 can be
`
`seen in Figure 3:
`
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`Accordingly, the drivers 56 are associated with the interface as the Board’s
`
`construction requires. See Ex. 1002 ¶¶ 36.
`
`Next, the driver 56 (the interface device) is associated with an interface that
`
`is between the semiconductor device housing the interface device and another
`
`device external to the semiconductor device, as required by the Board’s
`17
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`construction. In particular, Volk 450 discloses a “device comprising a driver
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`Case IPR2017-01819
`Attorney Docket No: 24069-0004IP2
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`configured to transmit a signal on a bus line” to another device that is the receiver
`
`of the data. Id., Abstract; 1:47-50 (“FIG. la and lb are diagrams showing typical
`
`parallel interfaces. In parallel interface 10 shown in FIG. la, a driver 12 in a
`
`sending circuit 14 transmits data along a bus line 16 to a receiver 18 in a receiving
`
`circuit 20.”); claims 1, 5, and 9; Figs. 1A and 1B:
`
`transmitting
`devices with
`a “Driver”
`
`
`
`“Receiver”
`devices with
`a termination
`
`
`
`See also Ex. 1002 ¶ 37.
`
`As noted above, Volk 450 specifically states that the driver system 50 is
`
`“configured to transmit data on bus line 58 to a receiver … such as receiver 18 as
`18
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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.
`
`When, as Volk 450 explicitly describes, driver system 50 (and thus driver 56) is
`
`used to transmit data over bus line 58 to receiver 18, it is undeniably sending data
`
`over the interface to a receiver that is external to the driver system 50. See Ex.
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`1002 ¶ 38.
`
`Moreover, Volk 450 provides additional detail regarding the operation of
`
`drivers that further show that the drivers 56 transmit to a device external to the
`
`driving system 50. In particular, Volk 450 explains that “[a] driver is a digital
`
`electronic circuit for holding a binary value, and communicating it to other circuits
`
`to which it is connected. The binary value is represented by a voltage level. It is
`
`common to connect a driver to a data bus for communicating the binary value to a
`
`receiving circuit by ‘driving’ the bus to a desired voltage level.” Id., 1:7-12; Ex.
`
`1002 ¶ 39.
`
`Next, the interface device of Volk 450 has a “settable control element,” as
`
`this limitation requires. In particular, according to Volk 450, “[d]river elements 56
`
`comprise a pull-up driver element 80 and a pull-down driver element 82.” Id.,
`
`2:29-40. The pull down driver element 82 is annotated in the version of Figure 3
`
`shown below:
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`See also Ex. 1002 ¶ 40. Volk 450 explains that “[t]he impedance of pull-up driver
`
`element 80 and the impedance of pull-down driver element 82 are
`
`programmable… To facilitate the dynamic adjustment of the output impedance of
`
`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.
`
`In even more detail, the “Pull-Down Driver Element” (illustrated in Figure
`
`3, reproduced above) includes “[a] set of n-channel metal oxide semiconductor
`
`field-effect transistors (MOSFETs) 106 [that] are arrayed in parallel between
`
`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:
`
`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
`
`added); see also Ex. 1002 ¶ 43. Volk 450 discloses additional details about how
`
`the driver is adjusted or trimmed, which are discussed in Ground 1:[14.3].
`
`Volk 450’s driver elements with “adjustable,” “programmable” output
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`impedances meet even Polaris’ previously asserted construction of “settable
`
`control element.” In its Patent Owner Preliminary Response, Polaris argued that
`
`“settable control element” should be construed as “a circuit element, the
`
`impedance of which can be programmed, adjusted, or set.” Ex. 1007, 23.2
`
`Petitioner does not believe that construction of “settable control element” is
`
`necessary, but even under Polaris’ construction, Volk 450 is clear that the driver
`
`element’s impedance may be programmed and adjusted. See Ex. 1004, 2:30-40
`
`(“The impedance of pull-up driver element 80 and the impedance of pull-down
`
`driver element 82 are programmable… To facilitate the dynamic adjustment of
`
`the output impedance of driver system 50, the impedance of pull-up driver
`
`element 80 and the impedance of pull-down driver element 82 are electronically
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`                                                            
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` 2
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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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` 
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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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