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`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________________________
`
`
`
`
`
`Samsung Electronics America, Inc., and
`ASUS Computer International, Inc.
`Petitioner
`
`v.
`
`James B. Goodman,
`Patent Owner.
`
`
`________________________
`
`IPR2017-020211
`Patent No. 6,243,315
`________________________
`
`
`PETITIONER’S REPLY
`
`
`1 Case IPR2018-00047, filed by ASUS Computer International, Inc., has been
`joined with this proceeding.
`
`
`
`

`

`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
`
`
`B.
`
`C.
`
`TABLE OF CONTENTS
`Introduction ..................................................................................................... 1
`I.
`II. GROUND 1: DELL ANTICIPATES CLAIMS 1 AND 5 ............................. 2
`A. Dell discloses the claimed “control device,” which selectively
`electrically isolates memory from “said respective address lines
`and respective control lines.” ............................................................... 2
`The Board correctly found that the ’315 Patent does not require
`electrical isolation of all of the claimed memory at the same
`time ....................................................................................................... 6
`The Board correctly found that the ’315 Patent does not require
`electrical isolation of the claimed memory from all the address
`lines and all the control lines ................................................................ 7
`The ’315 Patent does not preclude CKE signals from reaching
`the memory during a self-refresh mode ............................................... 8
`III. GROUND 2: DELL AND ABE RENDER OBVIOUS CLAIMS 10
`AND 16 ......................................................................................................... 10
`A.
`There is ample motivation for combining Dell and Abe, and
`Goodman has not shown otherwise .................................................... 10
`groundS 3 AND 4: DELL, JESD21-C, AND ABE RENDER
`OBVIOUS CLAIMS 2-4, 6-9, 11-15, AND 17-20 ...................................... 12
`V. GROUND 5: OOISHI AND PALANISWAMI RENDER OBVIOUS
`CLAIMS 1 AND 5 ........................................................................................ 13
`A. Ooishi discloses memory capable of being placed in a self
`refresh mode and with address and control lines ............................... 13
`B. Ooishi, in combination with Palaniswami, renders obvious the
`claimed “control device” .................................................................... 13
`C. Ooishi, in combination with Palaniswami, renders obvious the
`claimed “memory access enable control device” ............................... 17
`D. One skilled in the art would have been motivated to combine
`Ooishi and Palaniswami ..................................................................... 17
`VI. GROUND 6: OOISHI, PALANISWAMI, AND ABE RENDER
`OBVIOUS CLAIMS 10 AND 16 ................................................................. 19
`VII. Conclusion .................................................................................................... 19
`Certification of Word Count ................................................................................... 20
`
`IV.
`
`D.
`
`i
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`

`

`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
`
`
`TABLE OF AUTHORITIES
`
`Cases
`Arctic Cat Inc. v. Bombardier Recreational Prod.s, Inc.,
`876 F.3d 1350 (Fed. Cir. 2017) ............................................................................ 11
`Connell v. Sears Roebuck & Co.,
`722 F.2d 1542 (Fed. Cir. 1983) ............................................................................ 19
`Gemtron Corp. v. Saint-Gobain Corp.,
`572 F.3d 1371 (Fed. Cir. 2009) ............................................................................ 16
`In re Fracalossi,
`681 F.2d 792 (CCPA 1982) ................................................................................. 19
`In re McDaniel,
`293 F3d. 1379 (Fed. Cir. 2002) ............................................................................ 19
`In re Natures Remedies, Ltd.,
`315 Fed. App’x. 300 (Fed. Cir. 2009) .................................................................. 15
`Laitram Corp. v. Cambridge Wire Cloth Co.,
`919 F.2d 1579 (Fed. Cir. 1990) ............................................................................ 17
`Outdry Techs. Corp. v. Geox S.p.A.,
`859 F.3d 1364 (Fed. Cir. 2017) ............................................................................ 11
`Perfect Web Techs., Inc. v. InfoUSA, Inc.,
`587 F.3d 1324 (Fed. Cir. 2009) ............................................................................ 16
`Phillips v. AWH Corp.,
`415 F.3d 1303 (Fed. Cir. 2003) .............................................................................. 5
`Sundance, Inc. v. Demonte Fabricating, Ltd.,
`550 F.3d 1356 (Fed. Cir. 2008) ............................................................................ 16
`Statutes
`35 U.S.C. § 102 ........................................................................................................ 19
`35 U.S.C. § 103 ................................................................................................... 1, 20
`Regulations
`37 C.F.R § 42.105 ...................................................................................................... 1
`
`ii
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`37 C.F.R. § 42.24(d) ................................................................................................ 21
`37 C.F.R. § 42.6(e) ..................................................................................................... 1
`
`
`iii
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`LIST OF EXHIBITS
`
`
`Exhibit No. Description
`1001
`U.S. Patent No. 6,243,315
`1002
`Declaration of Dr. Andrew Wolfe
`1003
`Curriculum Vitae of Dr. Andrew Wolfe
`1004
`U.S. Patent No. 6,327,664 to Dell, issued December 4, 2001
`1005
`U.S. Patent No. 5,590,082 to Abe, issued December 31, 1996
`1006
`JESD21-C: JEDEC Configurations for Solid State Memories,
`Release 7, Published January 1997
`Declaration of John R. Kelly Regarding Records of JEDEC
`U.S. Patent No. 6,172,928 to Ooishi, issued August January 9, 2001
`U.S. Patent No. 6,144,219 to Palaniswami, issued November 7,
`2000
`Micron MT48LC4M4R1(S) Functional Specification, 1994
`Micron MT48LC4M4A1/A2 S Datasheet, 1998
`U.S. Patent No. 4,005,395 to Fosler, Jr. et al. issued January 25,
`1977
`
`1007
`1008
`1009
`
`1010
`1011
`1012
`
`
`
`
`iv
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`

`

`
`I.
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`INTRODUCTION
`The Board instituted review of the ’315 Patent on all six grounds advanced
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`by Petitioner Samsung Electronics America, Inc. (“Samsung”). In response to the
`
`institution, Goodman makes several arguments that have already been raised and
`
`rejected by the Board, relies on mischaracterizations of the prior art, or attacks the
`
`conclusions reached by Samsung’s expert without providing any opposing expert
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`testimony.
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`Goodman’s chief and most frequent mischaracterization of the ’315 Patent
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`claims continues to be that they require memory to be electrically isolated from all
`
`address signals and all control signals. The ’315 claims, however, do not require
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`total isolation of the memory from every signal, and the ’315 Patent specification
`
`does not disclose total isolation of the memory from every signal. Claim 1 only
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`requires “selectively electrically isolating said memory devices from said
`
`respective address lines and respective control lines.” Goodman’s arguments
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`repeatedly ignore both the plain language of the claims and the ’315 specification.
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`Goodman also argues against Samsung’s combinations under 35 U.S.C.
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`§ 103, often asserting—without further explanation or argument—that the
`
`motivations to combine set forth by Samsung are “speculative” or “illogical.”
`
`Goodman, however, offers no expert testimony to rebut the conclusions of
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`Samsung’s expert, Dr. Andrew Wolfe. Nor does Goodman dispute that Dr. Wolfe
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`1
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`is one skilled in the art. Therefore, the only evidence in the record of how one
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`skilled in the art would understand the challenged claims in the context of the ’315
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`Patent is the unrebutted testimony of Dr. Wolfe. Ultimately, Goodman’s
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`conclusory and repetitive arguments are without merit.
`
`II. GROUND 1: DELL ANTICIPATES CLAIMS 1 AND 5
`A. Dell discloses the claimed “control device,” which selectively
`electrically isolates memory from “said respective address lines
`and respective control lines.”
`Goodman disputes that Dell discloses the “control device” element of
`
`Claim 1 of the ’315 Patent. See, e.g.:
`
`a control device for selectively electrically isolating said
`memory devices from respective address lines and
`respective control lines so that when said memory
`devices are electrically isolated, any signals received on
`said respective address lines and respective control lines
`do not reach said memory devices;
`
`Ex. 1001 at Claim 1, element [b]. First, Goodman argues that Dell does not
`
`disclose this element because “opening FET switch 52 only isolate[s] address and
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`control lines from the system memory controller, not the DSP” and that the flow
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`diagram of Fig. 2 in Dell “show[s] that DSP can deactivate the FET switches.”
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`Paper 10 at 11.
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`Goodman’s argument that the DSP of Dell “can deactivate the FET
`
`switches” is incorrect, and the flow diagram Goodman relies on does not show
`
`otherwise. Figure 2 of Dell only shows that the FET switches are “deactivated,”
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`2
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`

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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`generally, in the event that the DSP desires to access the memory. See Ex. 1004 at
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`Fig. 2, below:
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`
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`Fig. 2 does not state that the DSP has control over any FET switches. If it did, then
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`Fig. 2 would be inconsistent with Fig. 1, which shows that FET switches 50 and 52
`
`are coupled to bus controller 34. See, e.g., id. at Fig. 1 (annotated below with
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`respect to FET 52):
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`3
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`

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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`As Fig. 1 illustrates, only the bus controller 34 has direct access to FET 52
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`(through the line highlighted in blue), and when FET 52 is open, the memory is
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`selectively electrically isolated from the address and control lines on bus 16. The
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`bus controller 34 and FET 52 therefore constitute the claimed “control device.”
`
`See Paper 2 at 15-19.
`
`
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`Second, Goodman argues that “the open FET does not, in fact, isolate all of
`
`the memory devices as urged by petitioner.” Resp. at 11. This argument relies on
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`a limitation not recited by the claims. Goodman appears to contend that the
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`“control device” limitation is not disclosed because the DSP can access the
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`memory when the FET at 52 is in an open position. Even accepting this
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`characterization as true, Goodman is incorrect in continuing to argue that Claim 1
`
`4
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`of the ’315 Patent requires electric isolation of the memory from all address lines
`
`and all control lines. Claim 1 contains no such requirement. It instead recites only
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`that the “control device . . . selectively electrically isolate[s] said memory devices
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`from respective address lines and respective control lines.” Ex. 1001 at Claim 1;
`
`see also Phillips v. AWH Corp., 415 F.3d 1303, 1312 (Fed. Cir. 2003) (“[T]he
`
`Supreme Court made clear that the claims are ‘of primary importance, in the effort
`
`to ascertain precisely what it is that is patented.”). Moreover, as noted by the
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`Board (Paper 9 at 12-13), the preferred embodiments of the ’315 Patent do not
`
`isolate the memory devices from all address and control lines.” The ’315 preferred
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`embodiment instead discloses that the memory devices are electrically isolated
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`“from the control lines 122 and address lines 117.” Ex. 1001 at 9:44-48. It is
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`axiomatic that claims “must be read in view of the specification, of which they are
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`a part,” and Goodman’s interpretation is inconsistent with the ’315 specification.
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`Phillips, 415 F.3d at 1315 (internal quotations omitted).
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`Dell discloses the “control device” as claimed in the ’315 Patent and
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`consistent with its specification. The claimed “address lines and control lines” are
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`disclosed by Dell’s address and control bus 16, and the bus controller 34 uses FET
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`52 to selectively electrically isolate the memory from the address and control bus.
`
`See Paper 2 at 15-19. Samsung has already acknowledged that Dell also discloses
`
`that memory banks can be reached through a CKE signal in low-power and/or self-
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`5
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`

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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`refresh mode. See Paper 2 at 17 and Ex. 1004 at 4:11-22 (specifying that, in self-
`
`refresh mode, “only the clock enable signal is active, with all other receivers being
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`turned off”). Dell’s disclosure mirrors the ’315 Patent, which, as the Board found,
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`does not isolate the memory devices from at least the RAS (row address select) and
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`WE (write enable) control lines. The preferred embodiment of the ’315 Patent
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`instead only isolates the memory from control lines 122 and address lines 117; just
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`as Dell isolates the memory from address and control bus 16. Dell discloses the
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`“control device” element, which requires “selectively electrically isolating said
`
`memory devices from respective address lines and respective control lines,” and
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`therefore anticipates Claim 1.
`
`B.
`
`The Board correctly found that the ’315 Patent does not require
`electrical isolation of all of the claimed memory at the same time
`Goodman disputes the Board’s finding that the ’315 Patent does not require
`
`all of the memory banks to be placed into a reduced power state at the same time.
`
`Goodman argues that because the “memory devices” claimed in the ’315 Patent are
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`identified as a “plurality of volatile solid state memory devices,” that every
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`reference to “memory devices” in Claim 1 must therefore refer to all of the
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`memory devices and can never refer to only a portion thereof. Paper 10 at 13.
`
`Goodman’s argument imports a limitation into Claim 1 that does not exist.
`
`Claim 1 only recites that the memory devices can be “selectively electrically
`
`isolated” from “respective address lines and respective control lines.” Claim 1
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`6
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`does not recite that the memory devices must be “selectively electrically isolated”
`
`in unison. However, even if Claim 1 did recite that all the memory devices must
`
`be “selectively electrically isolated” at the same time, Dell would still anticipate.
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`Dell broadly discloses that all of the memory devices can be placed in any of the
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`power-down modes, and does not foreclose the possibility of all memory banks
`
`being placed into power-down mode simultaneously. See Ex. 1004 at 4:19-22.
`
`C. The Board correctly found that the ’315 Patent does not require
`electrical isolation of the claimed memory from all the address
`lines and all the control lines
`Goodman repeatedly argues that the claimed memory must be electrically
`
`isolated from all address lines and all control lines, and in so doing asserts that the
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`’315 Patent “makes it clear that the claimed invention is to protect the data in the
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`memory devices during self refresh from errant signals which might reach the
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`memory devices.” Paper 10 at 14.
`
`Goodman’s argument mischaracterizes the stated purpose of the ’315 Patent,
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`which is to isolate the memory from only specifically identified address lines and
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`control lines—not every single conceivable signal. See Ex. 1001 at 5:63-67
`
`(emphasis added):
`
`By isolating the memory devices from control buss 22
`and address buss 17 the control device 15 prevents errant
`signals from erroneously changing or affecting the data
`being retained by the memory devices 5.
`
`See also id. at 9:44-48 (stating that electrical isolation of the memory “from the
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`7
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`

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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`control lines 122 and address lines 117 . . . is necessary to prevent errant signals.”)
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`The ’315 Patent does not state any goal of isolating the memory from clock enable
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`signals, such as the RAS (26) and WE (28) control lines, nor the data buss (8), nor
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`any voltage lines (e.g., Fig. 4 at 143). Indeed, consistent with the language of
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`Claim 1, the ’315 Patent does not disclose that the memory devices are electrically
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`isolated from anything other than specific, respective address lines and control
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`lines.
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`D. The ’315 Patent does not preclude CKE signals from reaching the
`memory during a self-refresh mode
`Goodman argues that Dell “allows the CKE (clock enable)2 lines to remain
`
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`2 Goodman also argues that the CKE line disclosed in Dell is a “control signal”
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`under the stipulated claim construction in the Goodman v. Hewlett-Packard, Inc.
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`litigation in the Southern District of Texas (to which Samsung is not a party). This
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`argument is irrelevant, given that Claim 1 of the ’315 Patent does not requires
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`electrical isolation from all address and control lines. Moreover, it is waived, as
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`Goodman never asserted prior to institution that the term “control signal” should
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`be given any specific construction. See IPR2013-00473, Paper 14 at 3 (rejecting
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`post institution claim construction proposal and noting that “[w]e continue to be
`
`persuaded that [Petitioner] should not benefit from providing a specific claim
`
`construction only after the institution decision has been made.”).
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`8
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`connected to a memory bank even when the memory bank is in a power down
`
`state” and that because the ’315 Patent “requires all address and control lines to be
`
`electrically isolated from the memory devices,” Dell does not anticipate. Paper 10
`
`at 14-15.
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`This argument should be rejected for the reasons already explained by the
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`Board and reiterated above—i.e., that the ’315 Patent does not preclude clock
`
`enable signals from reaching the memory during self-refresh mode, and only
`
`recites that the memory is “selectively electrically isolate[d] . . . from respective
`
`address lines and respective control lines.” Dell, like the ’315 Patent, discloses
`
`selective electrical isolation from respective address and respective control lines.
`
`To the extent Goodman suggests that there are two clock enable lines
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`disclosed in Dell, this is both incorrect and irrelevant. See Paper 10 at 15-16. The
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`“second” CKE signal identified by Goodman—“clock enable line 14”—appears to
`
`be a mistake in the Dell patent. Element 14 in Dell is first identified in the
`
`specification as the “memory data bus” (Ex. 1004 at 2:44-56), and Figure 1 also
`
`identifies element 14 as the “memory data bus.” The only clock enable line
`
`referred to consistently in the specification or in the Figures is CKE 24.
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`Regardless, as stated above, Samsung has already acknowledged that the CKE line
`
`in Dell can access the memory devices during low power/self-refresh mode, but
`
`this is irrelevant to the claim, which only requires isolation from “respective
`
`9
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`address lines and respective control lines”—not all address lines and all control
`
`lines.
`
`III. GROUND 2: DELL AND ABE RENDER OBVIOUS CLAIMS 10 AND
`16
`A. There is ample motivation for combining Dell and Abe, and
`Goodman has not shown otherwise
`In disputing that Dell and Abe render Claims 10 and 16 obvious, Goodman
`
`mainly repeats his arguments as to why Dell does not disclose the claimed “control
`
`device.” These arguments have already been addressed above at § II, supra.
`
`Goodman also appears to reference the language of Claim 10—“a control device
`
`for monitoring said first voltage”—in arguing that “Dell has no reason to monitor
`
`the voltage so it is logical that such language does not appear in Dell.” Paper 10 at
`
`18.
`
`To the extent Goodman argues that because Dell “has no reason to monitor
`
`the voltage,” it cannot be combined with Abe under § 103, Goodman is both
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`factually and legally incorrect. First, Dell is directed principally to reducing power
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`requirements and allowing memories to take proper advantage of self-refresh
`
`mode. See Paper 2 at 12-13, Ex. 1002 at 16-17. One skilled in the art, therefore,
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`would be motivated to apply Abe’s power supply control circuitry (i.e., “power
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`supply monitors” 3 and 5) to Dell’s memory system. See Ex. 1002 at ¶ 62.
`
`Second, the fact that Dell does not literally disclose “monitoring said first voltage”
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`10
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`is irrelevant, because Samsung is relying on obviousness (in view of Abe), not
`
`anticipation, and has explained in detail its basis for doing so.
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`Goodman’s suggestion that the motivation to combine references must be
`
`contained in the references themselves is also inconsistent with the law. See
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`Outdry Techs. Corp. v. Geox S.p.A., 859 F.3d 1364, 1370-71 (Fed. Cir. 2017)
`
`(“Any motivation to combine references, whether articulated in the references
`
`themselves or supported by evidence of the knowledge of a skilled artisan, is
`
`sufficient to combine those references to arrive at the claims process.”). The
`
`proper analysis should consider “a range of real-world facts” to determine whether
`
`there was an apparent reason to combine, including market forces, design
`
`incentives, interrelated teachings of multiple patents, a need or problem known in
`
`the field, and background knowledge and common sense of the person of ordinary
`
`skill. Arctic Cat Inc. v. Bombardier Recreational Prods., Inc., 876 F.3d 1350,
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`1359 (Fed. Cir. 2017).
`
`Goodman also argues that “there is [no] technical basis for combining the
`
`technical aspects of Dell and Abe other than the Expert’s statement that it would
`
`have been obvious” and that “the Expert left this issue open without any proposed
`
`technical explanation for actually combining the teachings of Dell and Abe.”
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`Paper 10 at 18. This argument ignores the detailed explanation provided by Dr.
`
`Wolfe in his Declaration as to why one skilled in the art would be motivated to
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`11
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`combine Dell and Abe. See Ex. 1002 at ¶¶ 60-63 (explaining, for example, that
`
`both Dell and Abe are directed to the same field of technology, that each reference
`
`discloses that its respective teachings are merely exemplary modules that a person
`
`of ordinary skill may apply without departing from the scope of their
`
`corresponding functions, providing explicit illustrations of one skilled in the art
`
`might combined Dell and Abe, and describing the requisite skill that would be
`
`required to substitute the known elements in the manner shown). Samsung and Dr.
`
`Wolfe, therefore, provided more than sufficient “technical basis” and “technical
`
`explanation” for combining Dell and Abe under § 103, and Goodman has offered
`
`no expert testimony, let alone any cognizable argument, to the contrary.
`
`IV. GROUNDS 3 AND 4: DELL, JESD21-C, AND ABE RENDER
`OBVIOUS CLAIMS 2-4, 6-9, 11-15, AND 17-20
`Goodman provides no substantive arguments as to why dependent Claims 2-
`
`4, 6-9, 11-15 and 17-20 are not rendered obvious by a combination of Dell,
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`JESD21-C, and Abe, other than to refer to his previous arguments. Goodman does
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`not dispute the prior art status of JESD21-C nor offer any explanation as to why it
`
`does not disclose the particular limitations of the dependent claims. For the
`
`reasons explained above, Dell and/or Dell combined with Abe anticipate or render
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`obvious claims 1, 5, 10, and 16, and Goodman has not otherwise shown that the
`
`dependent claims are not also invalidated when incorporating the disclosures of
`
`JESD21-C.
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`12
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`V. GROUND 5: OOISHI AND PALANISWAMI RENDER OBVIOUS
`CLAIMS 1 AND 5
`A. Ooishi discloses memory capable of being placed in a self refresh
`mode and with address and control lines
`Goodman disputes that the combination of Ooishi and Palaniswami renders
`
`claims 1 and 5 obvious, arguing that “the word ‘volatile,’ ‘address lines’,[] and
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`‘control lines’ do not appear in Ooishi at all.” Paper 10 at 20. Samsung, however,
`
`does not argue that these words are literally present in Ooishi, nor is it required to.
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`Samsung instead relies on § 103 and has provided unrebutted evidence that one
`
`skilled in the art would understand that Ooishi renders this limitation obvious
`
`because it describes a DRAM unit with a plurality of memory cell arrays (Ex. 1008
`
`at 3:18-26); a self-refresh control circuit that generates refresh signals in a power
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`down mode (id. at 1:44-50; 1:56-58; and 5:38-41); and specifically identified
`
`control signals and address signals (id. at 5:3-15 and Fig. 1). See also Ex. 1002 at
`
`¶¶ 95-99. Samsung, therefore, is not “assuming speculation is the same as facts,”
`
`but has provided ample explanation and unrebutted testimony regarding how one
`
`skilled in the art, i.e. Dr. Wolfe, would find the required disclosures in Ooishi.
`
`B. Ooishi, in combination with Palaniswami, renders obvious the
`claimed “control device”
`Goodman argues that the “control device” limitation is not met by the
`
`combination of Ooishi and Palaniswami through several arguments that again
`
`mischaracterize the grounds and Samsung’s evidence.
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`First, Goodman argues that “[i]t is being assumed by [Samsung] that the
`
`address and control lines are for supplying electrical power to the memory devices,
`
`and this is completely wrong.” Paper 10 at 20. Samsung, however, has never
`
`argued that the address lines and control lines supply power to the memory
`
`devices. Samsung’s position is that Ooishi discloses that the address and control
`
`signals are electrically isolated from the DRAM when they are not supplied with
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`power. Paper 2 at 56-57 (citing Ex. 1008 at 6:38-42 (“in power down mode . . .
`
`[p]ower supply is not supplied to circuitry 400 that is not required for a self refresh
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`operation”)). As Samsung’s unrebutted testimony shows, one skilled in the art
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`would understand that when the components that connect the address and control
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`signals to the DRAM are not supplied with power, they are electrically isolated
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`from the DRAM during self-refresh mode. Id. at 57 (citing Ex. 1002 at ¶¶ 101-
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`102).
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`Second, Goodman argues that Samsung has “not address[ed]” how the
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`“control device” responds to the “memory access enable control device.” Paper 10
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`at 21. It is unclear exactly how Goodman contends, through this argument, that
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`Samsung’s obviousness ground fails. Regardless, Samsung has thoroughly
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`explained why both the “control device” and “memory access enable control
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`device” limitations are rendered obvious by the combination of Ooishi and
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`Palaniswami. For example, Samsung has explained, with respect to element [c] of
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`Claim 1, why one skilled in the art would have been motivated to combine the
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`isolation mechanism of Palaniswami with the mode decoder within the DRAM of
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`Ooishi to determine when the memory is not being accessed and to selectively
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`electrically isolate the memory from respective address lines and respective control
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`lines. Paper 2 at 63-65; Ex. 1002 at ¶¶ 114-118.
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`Third, Goodman argues that Samsung is incorrect to argue that the address
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`and control lines are electrically isolated when power is not supplied to them
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`during self-refresh mode, in part because “the line would remain connected and the
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`line would be ‘floating,’ thereby creating a path for erratic signals.” Paper 10 at
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`21. Goodman does not explain what “floating” is, nor does he provide any
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`citations to the ’315 Patent, prior art, or expert testimony to explain his argument
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`or support his position. Goodman’s attorney argument reflect only a lay
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`interpretation of the claims are not evidence of how one skilled in the art would
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`have understood the claim in the context of the patent. See, e.g., In re Natures
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`Remedies, Ltd., 315 Fed. App’x. 300, 305 (Fed. Cir. 2009) (“Attorney argument …
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`cannot take the place of record evidence.”).
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`Moreover, Goodman’s attorney cannot stand in the stead of one skilled in
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`the art. Sundance, Inc. v. Demonte Fabricating, Ltd., 550 F.3d 1356, 1363 (Fed.
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`Cir. 2008). The validity of a patent must be assessed from the perspective of one
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`of ordinary skill in the art. Id. Goodman’s arguments must therefore be supported
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`in the admissible opinions of a qualified expert. Id. Here, Goodman fails to
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`proffer any such evidence, and his arguments must be disregarded. See Perfect
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`Web Techs., Inc. v. InfoUSA, Inc., 587 F.3d 1324, 1332 (Fed. Cir. 2009) (citing
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`Gemtron Corp. v. Saint-Gobain Corp., 572 F.3d 1371, 1380 (Fed. Cir. 2009)); see
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`also Laitram Corp. v. Cambridge Wire Cloth Co., 919 F.2d 1579, 1583 (Fed. Cir.
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`1990) (criticizing parties’ “reliance on attorney argument and counsel’s unsworn
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`fact statements as ‘evidence.’”).
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`To the extent, however, that “floating” is understood to mean a state wherein
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`the lines are not connected to a driving signal, the ’315 claims do not prohibit this.
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`Claim 1 recites “electrically isolating,” not “physically isolating,” and Samsung’s
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`unrebutted expert testimony shows that one skilled the art would understand that
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`when power is not supplied to the address and control lines, they are “electrically
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`isolated” from the memory. Paper 2 at 56-57.
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`Finally, Goodman argues that Palaniswami’s isolation mechanism does not
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`render the “control device” limitation obvious because “the ‘control device’ . . .
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`must communicate with the ‘memory access enable control device’ and a ‘memory
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`access enable control device’ has not been identified.” Paper 10 at 21. As
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`explained above, Samsung clearly identified Ooishi’s mode decoder as the
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`“memory access enable control device.” Paper 2 at 63-65; Ex. 1002 at ¶¶ 114-118.
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`C. Ooishi, in combination with Palaniswami, renders obvious the
`claimed “memory access enable control device”
`Goodman disputes that the “memory access enable control device”
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`limitation is rendered obvious, arguing that “there is no explicit support” for
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`Samsung’s arguments and that “the cited portions do not the urged [sic] operation
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`of the mode decoder.” Paper 10 at 22-23. Samsung interprets Goodman’s
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`argument as disputing that the “mode decoder” renders obvious the “memory
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`access enable control device.” Samsung has clearly explained, however, that one
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`skilled in the art would understand that Ooishi’s mode decoder is coupled to the
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`control lines and the self-refresh control circuit, determines when the memory
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`system is not being accessed, and then outputs a self-refresh set signal to initiate
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`self-refresh mode. Paper 2 at 63-64 (citing Ex. 1008 at 5:16-19; 6:38-44; 6:51-55;
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`and 7:34-45); Ex. 1002 at ¶ 114-116. Goodman has not rebutted Samsung’s expert
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`testimony or otherwise explained how the stated combination of Ooishi and
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`Palaniswami does not render obvious the “memory access enable control device.”
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`D. One skilled in the art would have been motivated to combine
`Ooishi and Palaniswami
`Goodman also argues that “the reasoning for combining Ooishi and
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`Palaniswami is illogical [] and irrelevant” because Samsung “removed the
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`motivation to combine these patents” by asserting that Ooishi includes a “control
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`device.” Paper 10 at 21-22. Again, Samsung has clearly and thoroughly provided
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`Petitioner’s Reply Brief in IPR2017-02021 (U.S. Patent No. 6,243,315)
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`the motivation to combine Ooishi and Palaniswami through unrebutted expert
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`testimony.