Advanced Micro Devices, Inc.
`Petitioner
`v.
`Aquila Innovations, Inc.
`Patent Owner
`____________
`
`IPR2019-01525 (Patent No. 6,239,614)
`
`December 11, 2020
`
`1
`
`AMD EX1051
`AMD v. Aquila
`IPR2019-01525
`
`
`Petitioner
`v.
`Aquila Innovations, Inc.
`Patent Owner
`____________
`
`IPR2019-01525 (Patent No. 6,239,614)
`
`December 11, 2020
`
`1
`
`AMD EX1051
`AMD v. Aquila
`IPR2019-01525
`
`
`
`Instituted Grounds
`
`IPR2019-01525 (’614 Patent)
`
`Claims
`
`References
`
`Ground 1
`
`Ground 2
`
`Ground 3
`
`1-3
`
`1-3
`
`4-5
`
`Urano in view of Mutoh021
`
`Mutoh in view of Mutoh021
`
`Douseki in view of Ramus
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`2
`
`
`
`Overview
`
`• Petition Demonstrated that Claims 1-5 Are
`Unpatentable
`
`• Undisputed that Prior Art Discloses All Claim
`Elements
`
`• Disputes:
`• Whether a POSA Would Combine the Prior Art To
`Disclose Power Switch Cells “Disposed Around Said Unit
`Cell Array” (Grounds 1 and 2)
`
`POR, pp. 19-49.
`• Whether a POSA Would Combine the Prior Art To
`Disclose Capacitors “Constructed by Connecting MOS
`Transistors Placed Within Unit Cells in Array Form”
`(Ground 3)
`
`POR, p. 50.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`3
`
`
`
`’614 Patent: Claim 1
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`EX1001, 6:45-61.
`4
`
`
`
`Introduction to ’614 Patent
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`Petition, p. 12.
`
`5
`
`
`
`’614 Patent: Claim Construction
`
`“a power switch disposed around said unit cell array and
`comprised of a plurality of third MOS transistors”
`
`• Petitioner’s Construction: “a power switch comprising a
`plurality of third MOS transistors wherein a portion of the
`plurality of the third MOS transistors encircle said unit cell
`array”
`
`Petition, p. 21; EX1003, ¶98.
`
`• Patent Owner’s Construction: “disposed around” should be
`construed as “located on all sides of”
`
`POR, p. 14.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`6
`
`
`
`Ground 1: Undisputed That the Elements Were Known
`
`Reply, p. 3; EX1048, ¶9.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`7
`
`
`
`Ground 1: The Claimed “Power Switch” Was Obvious
`
`“a power switch disposed around said unit cell array and
`comprised of a plurality of third MOS transistors”
`
`• Urano discloses the “power switch . . . comprised of a
`plurality of third MOS transistors”
`Petition, pp. 49-52; EX1003, ¶¶141-143.
`
`• Mutoh021 discloses power MOSFETs “disposed around,” i.e.,
`encircling a unit cell array
`Petition, pp. 52-55; EX1003, ¶¶144-146.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`8
`
`
`
`Ground 1: The Claimed “Power Switch” Was Obvious
`
`Urano Discloses the “power switch . . . comprised
`of a plurality of third MOS transistors”
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`9
`
`Petition, pp. 49-52; EX1003, ¶¶141-143.
`
`
`
`Ground 1: The Claimed “Power Switch” Was Obvious
`
`Mutoh021 Discloses Power MOSFETs “disposed
`around,” i.e., Encircling a Unit Cell Array
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`Petition, pp. 52-55; EX1003, ¶¶144-146.
`10
`
`
`
`Ground 1: The Claimed “Power Switch” Was Obvious
`
`Petition Demonstrated Why a POSA Would Have Been
`Motivated To Combine Urano and Mutoh021 with Support
`from Dr. Holberg and Corroborating References
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`Petition, pp. 40-41; EX1003, ¶127.
`
`11
`
`
`
`Ground 1: The Claimed “Power Switch” Was Obvious
`
`Dr. Holberg Explained Why a POSA Would Have Combined
`Urano and Mutoh021
`
`EX1003, ¶¶120-125; EX1048, ¶21.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`EX1003, ¶¶126-127; EX1048, ¶¶21-22.
`12
`
`
`
`Ground 1: The Claimed “Power Switch” Was Obvious
`
`Petition Demonstrated How a POSA Would Have Combined
`Urano and Mutoh021 with Support from Dr. Holberg and
`Corroborating References
`
`…
`
`…
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`Petition, pp. 38-41; EX1003, ¶¶123-127.
`
`13
`
`
`
`Ground 1: The Claimed “Power Switch” Was Obvious
`
`Dr. Holberg Explained Why and How a POSA
`Would Have Combined Urano and Mutoh021
`
`EX1048, ¶10; EX1003, ¶128; Petition, pp. 34-41.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`14
`
`
`
`Patent Owner’s Arguments: No Problem in Urano
`
`Patent Owner Response
`
`POR, p. 22.
`
`Petitioner Reply
`
`• “The rationale to modify or combine the prior art does
`not have to be expressly stated in the prior art . . .”
`
`•
`
`See MPEP § 2144.I; In re Fine, 837 F.2d 1071, 5 USPQ2d 1596 (Fed.
`Cir. 1988); In re Jones, 958 F.2d 347, 21 USPQ2d 1941 (Fed. Cir.
`1992); see also In re Kotzab, 217 F.3d 1365, 1370, 55 USPQ2d 1313,
`1317 (Fed. Cir. 2000); In re Eli Lilly & Co., 902 F.2d 943, 14 USPQ2d
`1741 (Fed. Cir. 1990) . . . ; In re Nilssen, 851 F.2d 1401, 1403, 7
`USPQ2d 1500, 1502 (Fed. Cir. 1988)
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`Reply, p. 8.
`
`15
`
`
`
`Patent Owner’s Arguments: No Advantage in Mutoh021
`
`Patent Owner Response
`
`POR, p. 22.
`
`Petitioner Reply
`
`• Mutoh021 disclosed a benefit associated with its “on all
`sides arrangement” in the “Means for Solving the
`Problem”
`
`EX1013, ¶¶0015, 0035; Petition, pp. 37-38; EX1003, ¶¶117-
`119; Reply, pp. 11-12; EX1048, ¶¶20-23, 26.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`16
`
`
`
`Patent Owner’s Arguments: No Advantage in Mutoh021
`
`Mutoh021
`
`EX1013, ¶¶0015, 0035; Petition, pp. 37-38; EX1003, ¶¶118-119; Reply, pp. 11-12 ; EX1048, ¶¶20-21.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`17
`
`
`
`Patent Owner’s Arguments: No Advantage in Mutoh021
`
`Patent Owner Response
`
`Petitioner Reply
`
`POR, p. 22.
`
`• A POSA would have recognized that Mutoh021’s
`arrangement in Urano would achieve the benefit of
`circuit design efficiencies:
`o Reduced wiring complexity
`o Reduced parasitics
`o Better response time
`o Increased layout pattern density
`Petition, pp. 39-41; EX1003, ¶¶121-127; Reply, pp. 11-13 ; EX1048, ¶¶20-32.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`18
`
`
`
`Patent Owner’s Arguments: No Advantage
`
`Dr. Przybylski Admitted the Advantages of the Power Switch
`Arrangement Would Have Been Understood by a POSA
`
`…
`
`EX1047, 58:19-60:10; Reply, pp. 13-14; EX1048, ¶¶28-29.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`19
`
`
`
`Patent Owner’s Arguments: No Advantage
`
`Patent Owner Response
`
`• Patent Owner Arbitrarily Limits Urano and Mutoh021 to
`Two Metal Layers
`
`• Argues Two Metal Layer Combination Would Not
`Achieve Benefits
`
`POR, pp. 26-28, 42.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`POR, p. 28.
`
`20
`
`
`
`Patent Owner’s Arguments: No Advantage
`
`Petitioner Reply
`
`• Combination would achieve benefits because it is not
`limited to two layers of metal
`
`• Use of 2+ layers of metal was well-known at the time
`
`• Patent Owner’s declarant admitted the use of 2+ layers
`of metal was well-known at the time
`
`• Patent Owner’s declarant admitted the ’614 patent is not
`limited to two metal layers
`
`Reply, pp. 16-18; EX1048, ¶¶33-45.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`21
`
`
`
`Patent Owner’s Arguments
`
`• Ground 1: Whether a POSA Would Combine the
`Prior Art To Disclose Power Switch Cells “Disposed
`Around Said Unit Cell Array”
`
`• Ground 2: Whether a POSA Would Combine the
`Prior Art To Disclose Power Switch Cells “Disposed
`Around Said Unit Cell Array”
`
`• Ground 3: Whether a POSA Would Combine the
`Prior Art To Disclose Capacitors “Constructed by
`Connecting MOS Transistors Placed Within Unit
`Cells in Array Form”
`
`POR, p. 50.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`22
`
`
`
`Ground 2: The Claimed “Power Switch” Was Obvious
`
`“a power switch disposed around said unit cell array and
`comprised of a plurality of third MOS transistors”
`
`• Mutoh discloses the “power switch . . . comprised of a
`plurality of third MOS transistors”
`Petition, pp. 71-72; EX1003, ¶¶186-187.
`
`• Mutoh021 discloses power MOSFETs “disposed around,” i.e.,
`encircling a unit cell array
`Petition, pp. 72-73; EX1003, ¶188.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`23
`
`
`
`Ground 2: The Claimed “Power Switch” Was Obvious
`
`Mutoh Discloses the “power switch . . . comprised
`of a plurality of third MOS transistors”
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`Petition, pp. 71-72; EX1003, ¶¶186-187.
`24
`
`
`
`Ground 2: The Claimed “Power Switch” Was Obvious
`
`Mutoh021 Discloses Power MOSFETs “disposed
`around,” i.e., Encircling a Unit Cell Array
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`Petition, pp. 72-73 ; EX1003, ¶188.
`25
`
`
`
`Ground 2: The Claimed “Power Switch” Was Obvious
`
`Petition Demonstrated Why a POSA Would Have Been
`Motivated To Combine Mutoh and Mutoh021 with Support
`from Dr. Holberg and Corroborating References
`
`Petition, pp. 62-63; EX1003, ¶¶41-46, 168-171.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`26
`
`
`
`Ground 2: The Claimed “Power Switch” Was Obvious
`
`Dr. Holberg Explained Why a POSA Would Have Been
`Motivated To Combine Mutoh and Mutoh021
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`EX1003, ¶169.
`27
`
`
`
`Ground 2: The Claimed “Power Switch” Was Obvious
`
`Dr. Holberg Explained How and Why a POSA Would Have
`Been Motivated To Combine Mutoh and Mutoh021
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`EX1003, ¶171.
`
`28
`
`
`
`Patent Owner’s Arguments: The Same as Ground 1
`
`Patent Owner Response
`
`• Patent Owner Repeats All of the Arguments of
`Ground 1 for Ground 2
`
`Petitioner Reply
`
`POR, pp. 35-49.
`
`Reply, p. 22; EX1048, ¶57.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`29
`
`
`
`Patent Owner’s Arguments: Mutoh’s Standard Cell Array
`
`Patent Owner Response
`
`Petitioner Reply
`
`POR, p. 47.
`
`• Standard cells and gate arrays were well known and
`available to IC designers
`
`• Patent Owner and its declarant did not identify any
`reason why a POSA would not have looked to Mutoh021
`
`Reply, pp. 22-23; EX1048, ¶58.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`30
`
`
`
`Patent Owner’s Arguments
`
`• Ground 1: Whether a POSA Would Combine the
`Prior Art To Disclose Power Switch Cells “Disposed
`Around Said Unit Cell Array”
`
`• Ground 2: Whether a POSA Would Combine the
`Prior Art To Disclose Power Switch Cells “Disposed
`Around Said Unit Cell Array”
`
`• Ground 3: Whether a POSA Would Combine the
`Prior Art To Disclose Capacitors “Constructed by
`Connecting MOS Transistors Placed Within Unit
`Cells in Array Form”
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`31
`
`
`
`Ground 3: Claim 4
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`EX1001, 7:1-20.
`
`32
`
`
`
`Ground 3: Claim 4 Is Obvious over Douseki and Ramus
`
`Douseki Discloses Every Claimed Element, Including: “said first and
`second capacitors”
`
`• “first capacitor” – C1
`• “second capacitor” – C2
`
`EX1010, 5:33-53; Petition, pp. 80-89; EX1003, ¶¶210-226.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`33
`
`
`
`Ground 3: Claim 4 Was Obvious over Douseki and Ramus
`
`Ramus Discloses Capacitors Being “constructed by connecting MOS
`transistors placed within unit cells in array form”
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`EX1011, Abstract;
`Petition, pp. 78-79,
`88-89; EX1003,
`¶¶207, 225-226.
`
`34
`
`
`
`Ground 3: Claim 4 Was Obvious over Douseki and Ramus
`
`Petition Explained Why a POSA Would have Combined
`Douseki and Ramus with Support from Dr. Holberg
`
`Petition, pp. 78-79; EX1003, ¶¶206-207.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`3535
`
`
`
`Ground 3: Claim 4 Was Obvious over Douseki and Ramus
`
`Petition Explained Why a POSA Would have Combined
`Douseki and Ramus with Support from Dr. Holberg
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`Petition, pp. 78-79; EX1003, ¶209.
`3636
`
`
`
`Patent Owner’s Attorney Arguments: Douseki’s “Decoupling
`Capacitors”
`
`Patent Owner Response
`
`Petitioner Reply
`
`POR, p. 50.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`Reply, p. 24; EX1048, ¶63.
`
`37
`
`
`
`Patent Owner’s Attorney Arguments: Douseki’s “Decoupling
`Capacitors”
`
`Patent Owner Response
`
`Petitioner Reply
`
`POR, p. 51.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`Reply, p. 24; EX1048, ¶64.
`38
`
`
`
`Patent Owner’s Arguments
`
`• Ground 1: Whether a POSA Would Combine the
`Prior Art To Disclose Power Switch Cells “Disposed
`Around Said Unit Cell Array”
`
`• Ground 2: Whether a POSA Would Combine the
`Prior Art To Disclose Power Switch Cells “Disposed
`Around Said Unit Cell Array”
`
`• Ground 3: Whether a POSA Would Combine the
`Prior Art To Disclose Capacitors “Constructed by
`Connecting MOS Transistors Placed Within Unit
`Cells in Array Form”
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`39
`
`
`
`Claim 2: Undisputed
`
`EX1001, 6:62-64.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`40
`
`
`
`Claim 3: Undisputed
`
`EX1001, 6:65-67.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`41
`
`
`
`Claim 5: Undisputed
`
`EX1001, 7:21-8:3.
`
`Petitioner’s Demonstrative Exhibit - Not Evidence
`
`42
`
`
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