Apple Inc.
`v.
`Qualcomm Incorporated
`IPR2018-01315
`IPR2018-01316
`U.S. Patent No. 8,063,674
`
`Patent Owner’s Demonstrative Exhibits
`
`
`v.
`Qualcomm Incorporated
`IPR2018-01315
`IPR2018-01316
`U.S. Patent No. 8,063,674
`
`Patent Owner’s Demonstrative Exhibits
`
`
`
`U.S. Patent No. 8,063,674
`
`U.S. Patent No. 8,063,674
`
`40)
`
`>
`
`301
`
`Vss
`
`Power U/D
`Detector
`306
`
`|
`|
`|
`'
`
`Signal
`Processor
`308
`
`FIG, 4
`
`|
`
`|
`'
`
`Output
`Butter
`309
`2
`
`Ex. 1001, Fig. 4
`
`t
`|
`M5 L---~-------4--
`|
`|
`
`1
`3107
`
`
`
`i
`V core
`
`
`
`‘674 Patent – Claim 1
`
`1. A multiple supply voltage device comprising:
`a core network operative at a first supply voltage; and
`a control network coupled to said core network wherein said control
`network is configured to transmit a control signal, said control network
`comprising: an up/down (up/down) detector configured to detect a power
`state of said core network; processing circuitry coupled to said up/down
`detector and configured to generate said control signal based on said power
`state;
`one or more feedback circuits coupled to said up/down detector, said one or
`more feedback circuits configured to provide feedback signals to adjust a
`current capacity of said up/down detector;
`at least one first transistor coupled to a second supply voltage, the at least
`one first transistor being configured to switch on when said first supply
`voltage is powered down and to switch off when said first supply voltage is
`powered on;
`at least one second transistor coupled in series with the at least one first
`transistor and coupled to said first supply voltage, the at least one second
`transistor being configured to switch on when said first supply voltage is
`powered on and to switch off when said first supply voltage is powered
`down;
`at least one third transistor coupled in series between the at least one first
`transistor and the at least one second transistor.
`
`3
`
`Ex. 1001, pp. 13-14, Fig. 4
`
`
`
`Contested Grounds
`
`I. AAPA/MAJCHERCZAK GROUNDS
`•
`IPR2018-01315, Ground 2a: Claims 1, 2, 5 and 6 as obvious over AAPA and Majcherczak
`•
`IPR2018-01315, Ground 2b: Claim 7 as obvious over AAPA, Majcherczak, and Matthews
`
`•
`
`•
`
`IPR2018-01316, Ground 2a: Claims 8, 9, 12, 13 and 17-21 as obvious over AAPA and
`Majcherczak
`
`IPR2018-01316, Ground 2b: Claims 16 and 22 as obvious over AAPA, Majcherczak, and
`Matthews
`
`II. STEINACKER/DOYLE/PARK GROUNDS
`•
`IPR2018-01315, Ground 1: Claims 1, 2 and 5-7 as obvious over Steinacker, Doyle, and Park
`•
`IPR2018-01316, Ground 1: Claims 8, 9, 12, 13, and 16-22 as obvious over Steinacker, Doyle,
`and Park
`
`4
`
`IPR2018-01315, Paper 7, pp. 40-41
`IPR2018-01316, Paper 7, pp. 40, 41
`
`
`
`Patentability
`
`I. AAPA/MAJCHERCZAK GROUNDS
`•
`Inter Partes Review Cannot be Based on AAPA
`•
`The POSA Would Not Combine the Alleged AAPA with Majcherczak
`
`II. STEINACKER/DOYLE/PARK GROUNDS
`•
`The Petition Does Not Articulate a Sufficient Motivation to Combine
`•
`The POSA Would Not Combine Steinacker, Doyle, and Park
`•
`The Combination of Steinacker, Doyle, and Park Does Not Teach All of the
`Limitations of Dependent Claim 5
`
`5
`
`IPR2018-01315, Papers 12 and 19
`IPR2018-01316, Papers 12 and 19
`
`
`
`Patentability
`
`I. AAPA/MAJCHERCZAK GROUNDS
`•
`Inter Partes Review Cannot be Based on AAPA
`•
`The POSA Would Not Combine the Alleged AAPA with Majcherczak
`
`II. STEINACKER/DOYLE/PARK GROUNDS
`•
`The Petition Does Not Articulate a Sufficient Motivation to Combine
`•
`The POSA Would Not Combine Steinacker, Doyle, and Park
`•
`The Combination of Steinacker, Doyle, and Park Does Not Teach All of the
`Limitations of Dependent Claim 5
`
`6
`
`IPR2018-01315, Papers 12 and 19
`IPR2018-01316, Papers 12 and 19
`
`
`
`Inter Partes Review Cannot be Based on AAPA
`
`“A petitioner in an inter partes review may request to cancel as
`unpatentable 1 or more claims of a patent only on a ground that could be
`raised under section 102 or 103 and only on the basis of prior art consisting
`of patents or printed publications.” 35 U.S.C. § 311(b) (emphasis added)
`
`“The petition [for inter partes review] must specify where each element of
`the claim is found in the prior art patents or printed publications relied
`upon.” 37 C.F.R. § 42.104(b)(4) (emphasis added)
`
`7
`
`IPR2018-01315, Paper 12, pp. 17-20
`IPR2018-01316, Paper 12, pp. 18-20
`
`
`
`Patentability
`
`I. AAPA/MAJCHERCZAK GROUNDS
`•
`Inter Partes Review Cannot be Based on AAPA
`•
`The POSA Would Not Combine the Alleged AAPA with Majcherczak
`
`II. STEINACKER/DOYLE/PARK GROUNDS
`•
`The Petition Does Not Articulate a Sufficient Motivation to Combine
`•
`The POSA Would Not Combine Steinacker, Doyle, and Park
`•
`The Combination of Steinacker, Doyle, and Park Does Not Teach All of the
`Limitations of Dependent Claim 5
`
`8
`
`IPR2018-01315, Papers 12 and 19
`IPR2018-01316, Papers 12 and 19
`
`
`
`The POSA Would Not Combine AAPA with Majcherczak
`
`9
`
`IPR2018-01315, Paper 12, pp. 20-21
`IPR2018-01316, Paper 12, p. 21
`
`
`
`The POSA Would Not Seek To Add
`Hysteresis to the AAPA
`
`IPR2018-01315, Paper 16 (Pet. Reply), pp. 2-3
`IPR2018-01316, Paper 16, pp. 2-3
`
`IPR2018-01315, Paper 19, pp. 2-6
`IPR2018-01316, Paper 19, pp. 2-6
`
`10
`
`
`
`The POSA Would Not Seek To Add
`Hysteresis to the AAPA
`
`11
`
`Ex. 1001, pp. 10-11, Fig. 1 (emphasis added)
`
`
`
`There is No Reason for the POSA to
`Combine AAPA with Majcherczak
`
`Ex. 1001, Fig. 1
`
`Ex. 1008, Fig. 2
`
`12
`
`
`
`Patentability
`
`•
`
`The POSA Would Not Combine the Alleged AAPA with Majcherczak
`
` The Proposed Combination Results in Increased Leakage Current
`Compared to the AAPA Alone
`
` The Proposed Combination Results in Increased Leakage Current
`Compared To Majcherczak Alone
`
` The Proposed Combination Results in a DC Fighting Condition and
`Increased Glitch Current
`
`13
`
`IPR2018-01315, Paper 12, pp. 20-27
`IPR2018-01316, Paper 12, pp. 21-31
`
`
`
`Patentability
`
`•
`
`The POSA Would Not Combine the Alleged AAPA with Majcherczak
`
` The Proposed Combination Results in Increased Leakage Current
`Compared to the AAPA Alone
`
` The Proposed Combination Results in Increased Leakage Current
`Compared To Majcherczak Alone
`
` The Proposed Combination Results in a DC Fighting Condition and
`Increased Glitch Current
`
`14
`
`IPR2018-01315, Paper 12, pp. 20-27
`IPR2018-01316, Paper 12, pp. 21-31
`
`
`
`The Alleged AAPA
`
`15
`
`Ex 1001, pp. 10-11 and Fig.1
`
`
`
`The Proposed Combination Results in Increased
`Leakage Current Compared to the AAPA Alone
`
`16
`
`IPR2018-01315, Paper 12, pp. 21-25
`IPR2018-01316, Paper 12, pp. 22-26
`
`
`
`The Proposed Combination Results in Increased
`Leakage Current Compared to the AAPA Alone
`
`IPR2018-01316, Ex 2002, Declaration of Dr. Pedram p. 33
`
`17
`
`
`
`Patentability
`
`•
`
`The POSA Would Not Combine the Alleged AAPA with Majcherczak
`
` The Proposed Combination Results in Increased Leakage Current
`Compared to the AAPA Alone
`
` The Proposed Combination Results in Increased Leakage Current
`Compared To Majcherczak Alone
`
` The Proposed Combination Results in a DC Fighting Condition and
`Increased Glitch Current
`
`18
`
`IPR2018-01315, Paper 12, pp. 20-27
`IPR2018-01316, Paper 12, pp. 21-31
`
`
`
`Majcherczak
`
`IPR2018-01316, Ex 2002, Declaration of Dr. Pedram p. 36
`
`19
`
`Ex 1008, Fig 2 and p. 9
`
`
`
`Majcherczak
`
`Ex 2003, Deposition of Dr. Horst, p. 65
`
`Ex 1008, Fig 2
`
`20
`
`
`
`The Proposed Combination Results in Increased
`Leakage Current Compared to Majcherczak Alone
`
`21
`
`IPR2018-01315, Paper 12, pp. 25-27
`IPR2018-01316, Paper 12, pp. 26-28
`
`
`
`The Proposed Combination Results in Increased
`Leakage Current Compared to Majcherczak Alone
`
`IPR2018-01316, Ex 2002, Declaration of Dr. Pedram p. 37
`22
`
`
`
`Patentability
`
`•
`
`The POSA Would Not Combine the Alleged AAPA with Majcherczak
`
` The Proposed Combination Results in Increased Leakage Current
`Compared to the AAPA Alone
`
` The Proposed Combination Results in Increased Leakage Current
`Compared To Majcherczak Alone
`
` The Proposed Combination Results in a DC Fighting Condition and
`Increased Glitch Current
`
`23
`
`IPR2018-01315, Paper 12, pp. 20-27
`IPR2018-01316, Paper 12, pp. 21-31
`
`
`
`The Alleged AAPA
`
`24
`
`Ex 1001, p. 10 and Fig. 1
`
`
`
`The Proposed Combination Results in a DC Fighting
`Condition and Increased Glitch Current
`
`25
`
`IPR2018-01315, Paper 12, pp. 27-31
`IPR2018-01316, Paper 12, pp. 28-31
`
`
`
`DC Fighting Condition
`
`IPR2018-01316, Ex 2002, Declaration of Dr. Pedram p. 38-39
`26
`
`
`
`Increased Glitch Current
`
`IPR2018-01316, Ex 2002, Declaration of Dr. Pedram p. 39-40
`
`27
`
`
`
`Patentability
`
`I. AAPA/MAJCHERCZAK GROUNDS
`•
`Inter Partes Review Cannot be Based on AAPA
`•
`The POSA Would Not Combine the Alleged AAPA with Majcherczak
`
`II. STEINACKER/DOYLE/PARK GROUNDS
`•
`The Petition Does Not Articulate a Sufficient Motivation to Combine
`•
`The POSA Would Not Combine Steinacker, Doyle, and Park
`•
`The Combination of Steinacker, Doyle, and Park Does Not Teach All of the
`Limitations of Dependent Claim 5
`
`28
`
`IPR2018-01315, Papers 12 and 19
`IPR2018-01316, Papers 12 and 19
`
`
`
`Patentability
`
`•
`
`The Petition Does Not Articulate a Sufficient Motivation to Combine
`
` The Proposed Combination of Steinacker, Doyle, and Park is Based on
`Impermissible Hindsight Reconstruction
`
` The Petitioner’s Reasons for Combining Steinacker, Doyle, and Park are
`Generic Statements Divorced from the Prior Art Elements
`
` The POSA Would Not Have Selected the Forced Stack Technique Over
`the Sleepy Stack Technique Described in Park
`
`29
`
`IPR2018-01315, Paper 12, pp. 32-45
`IPR2018-01316, Paper 12, pp. 33-46
`
`
`
`Patentability
`
`•
`
`The Petition Does Not Articulate a Sufficient Motivation to Combine
`
` The Proposed Combination of Steinacker, Doyle, and Park is Based on
`Impermissible Hindsight Reconstruction
`
` The Petitioner’s Reasons for Combining Steinacker, Doyle, and Park are
`Generic Statements Divorced from the Prior Art Elements
`
` The POSA Would Not Have Selected the Forced Stack Technique Over
`the Sleepy Stack Technique Described in Park
`
`30
`
`IPR2018-01315, Paper 12, pp. 32-41
`IPR2018-01316, Paper 12, pp. 33-42
`
`
`
`Steinacker
`
`31
`
`Ex. 1005, p. 6 and Fig. 1 (emphasis added)
`
`
`
`Doyle
`
`32
`
`Ex. 1006, p. 5 and Fig. 2 (emphasis added)
`
`
`
`Park
`
`Park
`
`Reduction
`
`Leakage
`Mooney II, Senior Member, IEEE
`
`Sleepy
`
`Stack
`
`Jun Cheol Park and Vincent J.
`
`a new circuit structure named
`In this paper, we
`“sleepy stack” as a
`remedy for static power consumption.(The)
`
`provide
`
`Low-VTH
`
` a
`
`33
`
`Ex. 1007, pp. 1-2 (emphasis added)
`
`of each transistor and active mode
`(a) Sleepy stack inverter with
`Fig. 2.
`17/£
`S, S" assertion. (b) Sleep mode S, S$’ assertion.
`
`approaches,
`However, unlike the
`forced
`transistor
`the
`stack
`retains the
`technique
`sleep
`technique,
`sleepy
`original state; furthermore, unlike the forced stack technique,
`can utilize
`to achieve up
`the sleepy stack technique
`high-V,,
`to two orders of magnitude leakage power reduction compared
`to the forced stack.
`the
`stack
`Unfortunately,
`sleepy
`technique
`comes with
`and area overheads. Therefore, the
`new Pareto
`to
`stack
`
`delay
`
`sleepy
`
`points [3]
`designers
`technique provides
`and are
`ultra-low
`leakage power consumption
`somearea and
`cost.
`delay
`
`require
`to pay
`
`who
`
`willing
`
`
`
`The Proposed Combination of Steinacker, Doyle, and
`Park is Based on Impermissible Hindsight Reconstruction
`
`34
`
`IPR2018-01315, Petition, p. 20
`IPR2018-01316, Petition, p. 19
`IPR2018-01315, Paper 12, p. 34
`IPR2018-01316, Paper 12, p. 35
`
`
`
`Patentability
`
`•
`
`The Petition Does Not Articulate a Sufficient Motivation to Combine
`
` The Proposed Combination of Steinacker, Doyle, and Park is Based on
`Impermissible Hindsight Reconstruction
`
` The Petitioner’s Reasons for Combining Steinacker, Doyle, and Park are
`Generic Statements Divorced from the Prior Art Elements
`
` The POSA Would Not Have Selected the Forced Stack Technique Over
`the Sleepy Stack Technique Described in Park
`
`35
`
`IPR2018-01315, Paper 12, pp. 41-44
`IPR2018-01316, Paper 12, pp. 42-45
`
`
`
`The Petitioner’s Reasons for Combining
`Steinacker, Doyle, and Park are Generic
`Statements Divorced from the Prior Art Elements
`
`36
`
`IPR2018-01316, Paper 2, p. 21 (emphasis added)
`
`
`
`The Petitioner’s Reasons for Combining
`Steinacker, Doyle, and Park are Generic
`Statements Divorced from the Prior Art Elements
`
`37
`
`IPR2018-01316, Paper 2, p. 20-11 (emphasis added)
`
`
`
`Patentability
`
`•
`
`The Petition Does Not Articulate a Sufficient Motivation to Combine
`
` The Proposed Combination of Steinacker, Doyle, and Park is Based on
`Impermissible Hindsight Reconstruction
`
` The Petitioner’s Reasons for Combining Steinacker, Doyle, and Park are
`Generic Statements Divorced from the Prior Art Elements
`
` The POSA Would Not Have Selected the Forced Stack Technique Over
`the Sleepy Stack Technique Described in Park
`
`38
`
`IPR2018-01315, Paper 12, pp. 44-45
`IPR2018-01316, Paper 12, pp. 45-46
`
`
`
`The POSA Would Not Have Selected the Forced
`Stack Technique Over the Sleepy Stack
`Technique Described in Park
`
`39
`
`Ex. 1007, pp. 1-2 (emphasis added)
`
`
`
`Patentability
`
`I. AAPA/MAJCHERCZAK GROUNDS
`•
`Inter Partes Review Cannot be Based on AAPA
`•
`The POSA Would Not Combine the Alleged AAPA with Majcherczak
`
`II. STEINACKER/DOYLE/PARK GROUNDS
`•
`The Petition Does Not Articulate a Sufficient Motivation to Combine
`•
`The POSA Would Not Combine Steinacker, Doyle, and Park
`•
`The Combination of Steinacker, Doyle, and Park Does Not Teach All of the
`Limitations of Dependent Claim 5
`
`40
`
`IPR2018-01315, Paper 12, pp. 45-49
`IPR2018-01316, Paper 12, pp. 46-50
`
`
`
`The Proposed Combination Results in
`Leakage and Glitch Currents
`
`41
`
`IPR2018-01315, Paper 12, p. 47
`IPR2018-01316, Paper 12, p. 48
`
`
`
`The Proposed Combination Results in Leakage
`Current During Steady-State Operations
`
`IPR2018-01316, Ex 2002, Declaration of Dr. Pedram p. 61
`
`42
`
`
`
`The Proposed Combination Results in
`Significant Glitch Current During Turn-On
`
`IPR2018-01316, Ex 2002, Declaration of Dr. Pedram pp. 61-62
`
`43
`
`
`
`Patentability
`
`I. AAPA/MAJCHERCZAK GROUNDS
`•
`Inter Partes Review Cannot be Based on AAPA
`•
`The POSA Would Not Combine the Alleged AAPA with Majcherczak
`
`II. STEINACKER/DOYLE/PARK GROUNDS
`•
`The Petition Does Not Articulate a Sufficient Motivation to Combine
`•
`The POSA Would Not Combine Steinacker, Doyle, and Park
`•
`The Combination of Steinacker, Doyle, and Park Does Not Teach All of the
`Limitations of Dependent Claim 5
`
`44
`
`IPR2018-01315, Paper 12, pp. 49-52
`
`
`
`The Combination of Steinacker, Doyle, and Park Do
`Not Teach All of the Limitations of Dependent Claim 5
`
`5. The multiple supply voltage
`device of claim 1 further comprising:
`an input/output (I/O) network
`operative at a second supply voltage,
`wherein said I/O network is coupled
`to said core network and said control
`network, and wherein said I/O
`network is configured to receive said
`control signal.
`
`Ex. 1001, p. 14 (emphasis added)
`
`IPR2018-01315, Paper 2, p. 23
`
`45
`
`
`
`Petitioner’s New Reasons for Combining Steinacker,
`Doyle, and Park are Untimely and Deficient
`
`•
`•
`
`•
`
`•
`
`•
`
`Steinacker includes no mention of hysteresis or feedback.
`Steinacker does not need to be “optimized… for power supplies with slow
`turn-on profiles” based on Doyle.
`
`Steinacker does not suggests that leakage current is a problem, and the
`POSA would have no reason to look to Park.
`
`Petitioner has not explained why the POSA would allegedly apply Park’s
`forced stacking technique to some transistors in Steinacker, but not others.
`
`The POSA would not be motivated to choose Park’s forced stack technique
`over its sleepy stack technique.
`
`46
`
`IPR2018-01315, Paper 19, pp. 21-24
`IPR2018-01316, Paper 19, pp. 21-24
`
`
`
`Petitioner’s Unrealistic Simulations
`Should Be Disregarded
`
`47
`
`IPR2018-01315, Paper 19, pp. 11-19
`IPR2018-01316, Paper 19, pp. 11-19
`
`
`
`Petitioner’s Unrealistic Simulations
`Should Be Disregarded
`
`Ex. 2006 (Deposition of Dr. Horst), pp. 93-94
`
`48
`
`
`
`IPR2018-01315
`IPR2018-01316
`U.S. Patent No. 8,063,674
`CERTIFICATE OF SERVICE
`
`
`The undersigned hereby certifies that a copy of Patent Owner’s Demonstrative
`
`Exhibits was served on October 8, 2019 by email, as follows:
`
`W. Karl Renner
`IPR39521-0053IP1@fr.com
`IPR39521-0053IP2@fr.com
`axf-ptab@fr.com
`
`Thomas A. Rozylowicz
`PTABInbound@fr.com
`rozylowicz@fr.com
`tar@fr.com
`
`Timothy W. Riffe
`PTABInbound@fr.com
`riffe@fr.com
`
`Kenneth J. Hoover
`hoover@fr.com
`
`Whitney A. Reichel
`wreichel@fr.com
`
`Date: October 8, 2019
`
`
`
`
`/ Joseph M. Sauer /
`Joseph M. Sauer, Reg. No. 47,919
`JONES DAY
`901 Lakeside Avenue
`Cleveland, OH, 44114
`
`Counsel for Patent Owner
`
`
`
`
`
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