PGR2019-00037
`Patent 10,003,553
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`FLEX LOGIX TECHNOLOGIES INC.,
`
`Petitioner
`
`V.
`
`VENKAT KONDA,
`
`Patent Owner
`
`____________
`
`Case PGR2019-00037
`
`Patent 10,003,553 B2
`
`_________
`
`MOTION TO AMEND UNDER 37 C.F.R. § 42.221
`
`Page i of 55
`
`Page 1 of 55
`
`FLEX LOGIX EXHIBIT 1048
`
`
`Patent 10,003,553
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`FLEX LOGIX TECHNOLOGIES INC.,
`
`Petitioner
`
`V.
`
`VENKAT KONDA,
`
`Patent Owner
`
`____________
`
`Case PGR2019-00037
`
`Patent 10,003,553 B2
`
`_________
`
`MOTION TO AMEND UNDER 37 C.F.R. § 42.221
`
`Page i of 55
`
`Page 1 of 55
`
`FLEX LOGIX EXHIBIT 1048
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`TABLE OF CONTENTS
`
`
`
`I.
`
`INTRODUCTION AND STATEMENT OF RELIEF REQUESTED ..... 1
`
`II.
`
`PATENT OWNER'S RESPONSE TO PETITIONER'S CHALLENGES
`
`3
`
`A. CHALLENGE GROUND 1 ............................................................................................. 3
`
`B. CHALLENGE GROUND 2 ............................................................................................. 4
`
`C. CHALLENGE GROUND 3 ............................................................................................. 5
`
`III. COMPLIANCE WITH STATUTORY AND REGULATORY
`REQUIREMENTS ........................................................................................ 5
`
`A. The Proposed Amendments Include A Reasonable Number Of Substitute Claims ... 5
`
`B. The Substitute Claims Do Not Enlarge The Scope Of The Claims Or Introduce New
`Subject Matter ................................................................................................................... 6
`
`C. The Proposed Amendments Respond To A Ground Of Unpatentability Alleged By
`The Petitioner .................................................................................................................... 7
`
`D. Explanation Of Substitute Claims And Support In The Original Disclosure And
`Earlier-Filed Disclosure .................................................................................................... 7
`
`IV. PATENTABILITY OF THE SUBSTITUTE CLAIMS ........................... 25
`
`V. CONCLUSION ............................................................................................ 26
`
`
`
`Page ii of 55
`
`
`Page 2 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`I.
`
`INTRODUCTION AND STATEMENT OF RELIEF REQUESTED
`
`Prior to filing this motion, pursuant to 37 C.F.R. § 42.221(a) Patent Owner
`
`complied with the conference call requirement with the Board on December 3,
`
`2019 (Paper 15). During the call, the Board directed the parties to the Board’s
`
`order in Lectrosonics, Inc. v. Zaxcom, Inc., Case IPR2018-01129, Paper 15 (PTAB
`
`Feb. 25, 2019) (precedential), which provides information and guidance on
`
`motions to amend, and to the Notice Regarding a New Pilot Program Concerning
`
`Motion to Amend Practice and Procedures in Trial Proceedings under the America
`
`Invents Act before the Patent Trial and Appeal Board, 84 Fed. Reg. 9497 (Mar. 15,
`
`2019). Accordingly, Patent Owner is submitting this paper by following those
`
`instructions1.
`
`Patent Owner requests that claims 1-20 of U.S. Patent No. 10,003,553 (“the
`
`‘553 Patent,” Ex. 1001) be cancelled and that new claims 21-40 be treated on a
`
`contingent basis. See Lectrosonics, Inc. v. Zaxcom, Inc., Case IPR2018-01129,
`
`(PTAB, Feb. 25, 2019) (Paper 15) (“A request to cancel claims will not be
`
`regarded as contingent. However, a request to substitute claims ordinarily will be
`
`
`1 Prior to filing this paper, in an email communication the Board approved
`
`that the page limit for Patent Owner’s motion to amend is increased to 30 pages.
`
`
`
`Page 1 of 55
`
`
`Page 3 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`treated as contingent.”). This Motion To Amend Under 37 C.F.R. § 42.221 is made
`
`on a contingent basis and is made in lieu of a response under 37 C.F.R. § 42.220.
`
`This Motion satisfies the requirements for a motion to amend. Claims 1-20
`
`are the challenged claims in this proceeding. Accordingly substitute claims are
`
`presented for challenged claims 1-202 in Appendix. This constitutes a “reasonable
`
`number of substitute claims.” 35 U.S.C. § 326(d)(1)(B). Additionally, the
`
`substitute claims: (1) do not “enlarge the scope of the claims;” (2) do not
`
`“introduce new [subject] matter;” and (3) “respond to [the] ground[s] of
`
`unpatentability involved in the trial.” 35 U.S.C. § 326(d)(3); 37 C.F.R. §
`
`42.221(a)(2)(i), (ii). Patent Owner has therefore satisfied his burden of production.
`
`Patent Owner respectfully requests preliminary guidance from the Board
`
`concerning this Motion, in accordance with the New Pilot Program Concerning
`
`Motion to Amend Practice. See 84 Fed. Reg. 9,497 (Mar. 15, 2019).
`
`
`
`
`2 In addition to this PGR, the Board instituted another PGR2019-00042 filed
`
`by the same Petitioner concurrently on the ‘553 Patent. During the conference call
`
`with the Board on December 3, 2019, Patent Owner indicated to the Board that he
`
`intends to move for the same amendments to the claims in both proceedings.
`
`Accordingly, the same amended claims are submitted in both the proceedings, i.e.
`
`PGR2019-00037 and PGR2019-00042.
`
`
`
`Page 2 of 55
`
`
`Page 4 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`II. PATENT OWNER'S RESPONSE TO PETITIONER'S CHALLENGES
`
`A. CHALLENGE GROUND 1
`
`In response to the Petition, the following is submitted in the proposed substitute
`
`claims 31 – 40 submitted in the Appendix: 1) Term “Zero or more cross links” in
`
`Claims 1 and 11 are deleted. 2) Term “Zero or more straight links” in Claim 1 and
`
`Claim 11 are deleted. 3) Terms “plurality of forward connecting links” and
`
`“forward connecting links” in Claim 1 and Claim 9 are deleted. 4) Terms “plurality
`
`of backward connecting links” and “backward connecting links” in Claim 1 and
`
`Claim 9 are deleted. 5) Term “subnetwork(s)” in claims 1 – 3, 7 – 13, and 15 – 20
`
`is substituted with “partial multi-stage hierarchical network(s)” in claims 21 – 23,
`
`27 – 33, and 35 – 40. 6) Term “incoming links” in claims 1, 5, 9, 11, and 17 is
`
`substituted with “inputs” in claims 21, 25, 29, 31, and 37. Furthermore, term
`
`“outgoing links” in claims 1, 5, 9, 11, and 17 is substituted with “outputs” in
`
`claims 21, 25, 29, 31, and 37. 7) Term “multiplexers of size
`
`” is first defined
`
`in claims 21 and 31 to remedy the antecedent issue. 8) Exemplary definition of
`
`term “a plurality of subnetworks” and referring to it subsequently as “each
`
`subnetwork” in several claims is corrected with substituted definition of term “a
`
`plurality of partial multi-stage hierarchical networks” and referred to it
`
`subsequently as “each partial multi-stage hierarchical network of said plurality of
`
`partial multi-stage hierarchical networks” in several substitute claims, to remedy
`
`
`
`Page 3 of 55
`
`
`2d
`
`Page 5 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`the antecedent issue. All the similar antecedent issues are remedied in several
`
`substitute claims. 9) Term “straight links” in claims 1 and 11 is substituted with
`
`“internal connections” in claims 21 and 31. 10) Term “cross links” in claims 1, 2, 6
`
`- 9, 11, 15 – 16, and 19 – 20 is substituted with “external hop wires” in claims 1, 2,
`
`and 6 – 9, and substituted with “hop wires” in claims 11, 15 – 16, and 19 – 20. 11)
`
`Term “incoming cross links” in claim 25 is deleted. 12) Term “outgoing cross
`
`links” in claim 25 is deleted. 13) Term “number of rows” in claims 28, 36, and 40
`
`is deleted. 14) Term “number of columns” in claims 28, 36 and 40 is deleted. 15)
`
`Terms “higher stage”, “small in number”, and “large in number” in claims 8, 16,
`
`and 20 are deleted.
`
`B. CHALLENGE GROUND 2
`
`In response to the Petition, the following is submitted in the proposed substitute
`
`claims 31 – 40 in the Appendix: 1) The term “Flip-flop” in Claim 9 is deleted. 2)
`
`Term “ stages, where
`
` ” in claims 1 and 11 is substituted with “plurality of
`
`stages” in claims 21 and 31, and also used in claims 27 – 30, 36 – 38 and 40. 3)
`
`Term “vertical links” in claims 2 – 4 and 12 – 14 is substituted with “plurality of
`
`vertical external hop wires” in claims 22 – 24 and 32 – 34. 4) Term “horizontal
`
`links” in claims 2 – 4 and 12 – 14 is substituted with “plurality of horizontal
`
`external hop wires” in claims 22 – 24 and 32 – 34. 5) Term “hop length
`
`... where
`
`
`
`Page 4 of 55
`
`
`y
`
`1y
`
`h
`
`Page 6 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`” in claims 4 and 14 is remedied with “hop length
`
`... where
`
`” in claims
`
`24 and 34. 6) Term “hop length
`
`... where
`
`” in claims 4 and 14 is remedied
`
`with “hop length
`
`... where
`
`” in claims 24 and 34. 6) Term “incoming cross
`
`links” in claim 25 is deleted. 7) Term “outgoing cross links” in claim 25 is deleted.
`
`8) Term “final stage” in claim 19 is deleted.
`
`C. CHALLENGE GROUND 3
`
`In response to the Petition, the following is submitted in the proposed
`
`substitute claims 31 – 40 in the Appendix: 1) Term “ stages, where
`
` ” in
`
`claims 1 and 11 is substituted with “a plurality of stages” in claims 21 and 31.
`
`Furthermore, term “network” in claims 1 – 20 is substituted with “multi-stage
`
`hierarchical network” in claims 21 – 40. 2) Term “may or may not” in claims 1 and
`
`11 is deleted.
`
`III. COMPLIANCE WITH STATUTORY AND REGULATORY
`REQUIREMENTS
`
`A. The Proposed Amendments Include A Reasonable Number Of Substitute
`Claims
`
`The proposed amendments are presented in the Appendix attached hereto,
`
`pursuant to 37 C.F.R. § 42.221(b). Patent Owner cancels claims 1-20 and proposes
`
`substitute claims, claim 21-40. Because the challenged claims have been cancelled
`
`and substitute claims are proposed, this constitutes a “reasonable number of
`
`
`
`Page 5 of 55
`
`
`0h
`
`h
`
`1h
`
`h
`
`0v
`
`h
`
`1v
`
`y
`
`1y
`
`Page 7 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`substitute claims.” 37 C.F.R. § 42.221(a)(3). As shown in the Appendix, claims 21-
`
`40 include all of the limitations of original claims 1-20. Changes in claims 1-20 are
`
`shown by underlining for additions and brackets for deletions.
`
`B. The Substitute Claims Do Not Enlarge The Scope Of The Claims Or
`Introduce New Subject Matter
`
`Substitute claims 21-30 are based on cancelled claims 1-20, but further
`
`include narrowing amendments. Substitute claims 21-40 are narrower than original
`
`claims 1 – 20 because the “network” in Claims 1 – 20 is substituted with “multi-
`
`stage hierarchical network” in claims 21 – 40. Term “a ring” in claims 21 and 27-
`
`28 and term “at least one ring” introduced in claims 31, 36, and 40 narrows claims
`
`21, 27, 28, 31, 36, and 40. Usage of term “entry stage” in claim 21 and 31 and
`
`usage of term “last stage” in claims 21 and 31, for example “each inlet link of
`
`said... is connected to... said switch of size
`
` of [a] either said entry stage or
`
`said last stage of said plurality of stages” narrows both of the independent claims
`
`since each inlet and each outlet are connected to either entry stage or last stage of
`
`said plurality of stages, which in turn narrows all of the dependent claims as well.
`
`Definition of term “a plurality of multiplexers of size
`
`” and referring to them
`
`in claims 21 and 31 narrows both of the independent claims, which in turn narrows
`
`all of the dependent claims as well.
`
`
`
`Page 6 of 55
`
`
`d i
`
`0d
`
`2d
`
`Page 8 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`Phrase “said switch comprising at least one input connected from one of the
`
`outputs of said switch of a second stage of said plurality of stages of said ring of
`
`one partial multi-stage hierarchical network of said plurality of partial multi-stage
`
`hierarchical networks” in claims 21 and 31 narrows both of the independent
`
`claims, which in turn narrows all of the dependent claims as well.
`
`Because substitute claims 21-40 narrow the scope of claims 1-20, the
`
`substitute claims do not expand the scope of the patent and thus comply with the
`
`requirements of 37 C.F.R. § 42.221(a)(2)(ii).
`
`C. The Proposed Amendments Respond To A Ground Of Unpatentability
`Alleged By The Petitioner
`
`The proposed substitute claims respond to an asserted ground of
`
`unpatentability. The substitute claims respond to Petitioner’s argument that claims
`
`1-20 are unpatentable under AIA 35 U.S.C. § 112(b) as failing to particularly point
`
`out and distinctly claim the subject matter (ground 1), unpatentable under AIA 35
`
`U.S.C. § 112(a) as failing to satisfy the written description requirement (ground 2),
`
`and Claims 1-20 are unpatentable under AIA 35 U.S.C. § 112(a) as failing to
`
`satisfy the enablement requirement (ground 3).
`
`D. Explanation Of Substitute Claims And Support In The Original Disclosure
`And Earlier-Filed Disclosure
`
`Support for the proposed substitute claims is found in “the original disclosure of
`
`the patent.” See 37 C.F.R. § 42.221(b)(1)-(2). The ‘553 patent is a continuation
`
`
`
`Page 7 of 55
`
`
`Page 9 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`application to patent application No. 14/199,168, filed on March 6, 2014 (“the ‘168
`
`application”, Ex. 1005), which was granted as U.S. Patent No. 9,374,322 (“the
`
`‘322 patent”, Ex. 1035) which in turn is a continuation application to PCT
`
`Application No. PCT/US12/53814 (the ’814 PCT application, Ex. 1006), filed
`
`September 6, 2012 which in turn is continuation-in-part and claims priority to U.S.
`
`Provisional Patent Application Serial No. 61/531,615, filed September 7, 2011
`
`(“the ‘615 provisional application”, Ex. 1007).
`
`Exemplary support for the proposed substitute claims is provided in the following
`
`table with reference to the above-identified patent applications and/or patents
`
`(bracketed language for the deletions is not shown in the following table to save
`
`space, but is shown in the substitute claims in the Appendix).
`
`Claim 21. (Proposed substitute for original claim 1):
`
`21. A multi-stage hierarchical network implemented in a non-
`
`transitory medium comprising a plurality of partial multi-stage
`
`hierarchical networks and a plurality of inlet links and a plurality of
`
`outlet links,
`
`said plurality of partial multi-stage hierarchical networks arranged in a
`
`two-dimensional grid of a plurality of rows and a plurality of columns;
`
`Exemplary
`
`Support
`
`Ex. 1001
`
`8:57- 9:3,
`
`9:27-61
`
`
`
`
`
`
`
`Page 8 of 55
`
`
`Page 10 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`and
`
`each partial multi-stage hierarchical network of said plurality of partial
`
`multi-stage hierarchical networks comprising a ring and said ring
`
`comprising a plurality of stages; and
`
`Ex. 1001
`
`one of said plurality of stages comprising an entry stage and one of said
`
` 5:1-3,
`
`plurality of stages comprising a last stage; and
`
`8:57- 9:3,
`
`each stage of said plurality of stages comprising a switch of size
`
`,
`
`11:33-37,
`
`where
`
` and
`
`and said switch of size
`
` having
`
` inputs
`
`9:62-10:9,
`
`and
`
` outputs; and said switch of size
`
` further comprising a
`
`plurality of multiplexers of size
`
` with each multiplexer of said
`
`plurality of multiplexers of size
`
` comprising
`
` inputs and an
`
`output; and
`
`said
`
` inputs of said switch of size
`
`, and said
`
` outputs of said
`
`switch of size
`
`, connected to a plurality of internal connections or
`
`a plurality of external hop wires; and
`
`said switch of size
`
` where
`
` or at least one input of said
`
`
`
`inputs of said switch of a first stage of said plurality of stages of said
`
`ring of a first partial multi-stage hierarchical network of said plurality
`
`18:44-19:2,
`
`19:2-19-5,
`
`17:16-22,
`
`20:37-41,
`
`20:42-22:53,
`
`22:37-53,
`
`24:48-60,
`
`47:27-29
`
`
`
`
`
`Page 9 of 55
`
`
`d i
`
`0d
`
`2id
`
`2od
`
`d i
`
`0d
`
`id
`
`0d
`
`d i
`
`0d
`
`2d
`
`2d
`
`d
`
`id
`
`d i
`
`0d
`
`0d
`
`d i
`
`0d
`
`d
`i
`
`d
`
`o
`
`d i
`
`0d
`
`id
`
`Page 11 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`of partial multi-stage hierarchical networks connected from one output
`
`of said
`
` outputs of said switch of a second stage of said plurality of
`
`stages of said ring of said first partial multi-stage hierarchical network
`
`or a second partial multi-stage hierarchical network of said plurality of
`
`partial multi-stage hierarchical networks, and
`
`each inlet link of said plurality of inlet links is connected to one or
`
`more of Said
`
` inputs of said switch of size
`
` of either said entry
`
`stage or said last stage of said plurality of stages of one partial multi-
`
`stage hierarchical network of said plurality of partial multi-stage
`
`hierarchical networks, and each outlet link of said plurality of outlet
`
`links is connected to one of said
`
` outputs of said switch of size
`
`
`
`Ex. 1001
`
`17:34-41
`
`of either said entry stage or said last stage of said plurality of stages of
`
`one partial multi-stage hierarchical network of said plurality of partial
`
`multi-stage hierarchical networks; and
`
`said ring of a first partial multi-stage hierarchical network of said
`
`Ex. 1001
`
`plurality of partial multi-stage hierarchical networks comprising the
`
`20:1-16,
`
`same or different number of said plurality of stages as said ring of a
`
`19:6-19,
`
`second partial multi-stage hierarchical network of said plurality of
`
`17:22-33
`
`
`
`Page 10 of 55
`
`
`id
`
`d i
`
`0d
`
`0d
`
`d i
`
`0d
`
`0d
`
`Page 12 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`partial multi-stage hierarchical networks; a first stage of said plurality
`
`of stages comprising said switch comprising the same or different
`
`number of said plurality of multiplexers as a second stage of said
`
`plurality of stages; a first multiplexer in said plurality of multiplexers of
`
`size
`
` is the same or different size as a second multiplexer in said
`
`plurality of multiplexers of size
`
`; and
`
`each internal connection of said plurality of internal connections
`
`connected from the output of a first multiplexer of said plurality of
`
`multiplexers of size
`
` of said switch of a first stage of said plurality
`
`of stages of said ring of a first partial multi-stage hierarchical network
`
`of said plurality of partial multi-stage hierarchical networks to one
`
`input of said
`
` inputs of a second multiplexer of said plurality of
`
`Ex. 1001
`
`10:36-42
`
`multiplexers of size
`
` of said switch of a second stage either
`
`succeeding or preceding to said first stage of said plurality of stages of
`
`said ring of said first partial multi-stage hierarchical network of said
`
`plurality of partial multi-stage hierarchical networks; and
`
`
`
`Page 11 of 55
`
`
`2d
`
`2d
`
`2d
`
`d
`
`2d
`
`Page 13 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`each external hop wire of said plurality of external hop wires connected
`
`from said output of one multiplexer of said plurality of multiplexers of
`
`size
`
` of said switch of a first two successive stages of said plurality
`
`of stages of said ring of a first partial multi-stage hierarchical network
`
`of said plurality of partial multi-stage hierarchical networks to one or
`
`more inputs of said
`
` inputs of one or more multiplexers of said
`
`plurality of multiplexers
`
` of said switch of said first two successive
`
`stages or a second two successive stages of said plurality of stages of
`
`said ring of a second partial multi-stage hierarchical network different
`
`from said first partial multi-stage hierarchical network of said plurality
`
`of partial multi-stage hierarchical networks.
`
`Ex. 1001
`
`20:37-41,
`
`20:42-22:53,
`
`29:3-33:25,
`
`Claim 22. (Proposed substitute for original claim 2):
`
`
`
`22. The multi-stage hierarchical network implemented in the non-
`
`transitory medium of claim 21 wherein said plurality of external hop
`
`wires are connected as either vertical links (hereinafter “plurality of
`
`vertical external hop wires”) only, or horizontal links (hereinafter
`
`Ex. 1001
`
`22:37-22:63
`
`“plurality of horizontal external hop wires”) only.
`
`Claim 23. (Proposed substitute for original claim 3):
`
`
`
`
`
`Page 12 of 55
`
`
`2d
`
`d
`
`2d
`
`Page 14 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`23. The multi-stage hierarchical network implemented in the non-
`
`transitory medium of claim 22 wherein each partial multi-stage
`
`hierarchical network of said plurality of partial multi-stage hierarchical
`
`networks is replicated in either said plurality of rows or said plurality of
`
`columns of the two-dimensional grid, or
`
`each partial multi-stage hierarchical network of the plurality of partial
`
`multi-stage hierarchical networks with said plurality of horizontal
`
`external hop wires and said plurality of vertical external hop wires are
`
`replicated in either said plurality of rows or said plurality of columns of
`
`Ex. 1001
`
`9:27-61,
`
`14:4-27
`
`the two-dimensional grid.
`
`Claim 24. (Proposed substitute for original claim 4):
`
`
`
`24. The multi-stage hierarchical network implemented in the non-
`
`transitory medium of claim 22, wherein said plurality of horizontal
`
`external hop wires between switches in two said stages are substantially
`
`of equal length and said plurality of vertical external hop wires between
`
`Ex. 1001
`
`switches in two said stages are substantially of equal length in the two-
`
`22:37-22:63
`
`dimensional grid of said plurality of rows and said plurality of columns,
`
`or
`
`said plurality of horizontal external hop wires between switches in two
`
`
`
`Page 13 of 55
`
`
`Page 15 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`said stages are substantially of hop length
`
` and said plurality of
`
`vertical external hop wires between switches in two said stages are
`
`substantially of hop length
`
` where
`
` and
`
`.
`
`Claim 25. (Proposed substitute for original claim 5):
`
`
`
`25. The multi-stage hierarchical network implemented in the non-
`
`transitory medium of claim 21, wherein said plurality of inlet links and
`
`Ex. 1001
`
`said plurality of outlet links are connected to a computational block
`
`3:63-65
`
`comprising Lookup Tables, or memory blocks, or DSP blocks.
`
`Claim 26. (Proposed substitute for original claim 6):
`
`
`
`26. The multi-stage hierarchical network implemented in the non-
`
`transitory medium of claim 23, comprises either generalized multi-stage
`
`pyramid network, or generalized folded multi-stage pyramid network,
`
`or generalized butterfly fat pyramid network, or generalized multi-link
`
`multi-stage pyramid network, or generalized folded multi-link multi-
`
`stage pyramid network, or generalized multi-link butterfly fat pyramid
`
`Ex. 1001
`
`8:32-55
`
`network.
`
`Claim 27. (Proposed substitute for original claim 7):
`
`
`
`27. The multi-stage hierarchical network implemented in the non-
`
`Ex. 1001
`
`
`
`Page 14 of 55
`
`
`h
`
`v
`
`1h
`
`1v
`
`Page 16 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`transitory medium of claim 26, wherein said plurality of hop wires are
`
`29:3-33:25
`
`connected from said plurality of stages of said ring in a random order.
`
`Claim 28. (Proposed substitute for original claim 8):
`
`
`
`28. The multi-stage hierarchical network implemented in the non-
`
`transitory medium of claim 26, wherein said switch of size
`
` of
`
`one or more stages of said plurality of stages of said ring of said one or
`
`Ex. 1001
`
`more partial multi-stage hierarchical networks of said plurality of
`
`18:44-19:5
`
`partial multi-stage hierarchical networks where
`
` and
`
`.
`
`
`
`Claim 29. (Proposed substitute for original claim 9):
`
`
`
`29. The multi-stage hierarchical network implemented in the non-
`
`transitory medium of claim 24, wherein said plurality of external hop
`
`wires are implemented in two or more metal layers, or
`
`each switch of size
`
` of each stage of said plurality of stages is
`
`configurable by an SRAM cell or a Flash Cell, or
`
`Ex. 1001
`
`47:3-21,
`
`47:27-29,
`
`47:22-26,
`
`17:42-19:5
`
`said plurality of internal connections and said plurality of external hop
`
`Ex. 1006
`
`wires use a plurality of buffers to amplify signals driven through them;
`
`Page 80, lines
`
`and said buffers are either inverting or non-inverting buffers, or
`
`22-23
`
`
`
`Page 15 of 55
`
`
`8id
`
`4od
`
`d i
`
`0d
`
`d i
`
`0d
`
`Page 17 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`said switch in one or more stages of said plurality of stages in said
`
`
`
`plurality of partial multi-stage hierarchical networks comprising six 2:1
`
`multiplexers, or eight 2:1 multiplexers, or four 2:1 multiplexers, or two
`
`2:1 multiplexers.
`
`Claim 30. (Proposed substitute for original claim 10):
`
`
`
`30. The multi-stage hierarchical network implemented in the non-
`
`Ex. 1001
`
`transitory medium of claim 21, wherein said switch of size
`
` of
`
`47:16-21
`
`each stage of said plurality of stages is either fully populated or
`
`Ex. 1006
`
`partially populated, or
`
`Page 82, lines
`
`said plurality of partial multi-stage hierarchical networks are
`
`22-23
`
`implemented in a 3D integrated circuit device.
`
`Claim 31. (Proposed substitute for original claim 11):
`
`31. A multi-stage hierarchical network implemented in a non-
`
`
`
`
`
`transitory medium comprising a plurality of partial multi-stage
`
`Ex. 1001
`
`hierarchical networks and a plurality of inlet links and a plurality of
`
`8:57- 9:3,
`
`outlet links,
`
`9:27-61
`
`said plurality of partial multi-stage hierarchical networks arranged in a
`
`
`
`two-dimensional grid of a plurality of rows and a plurality of columns;
`
`
`
`Page 16 of 55
`
`
`d i
`
`0d
`
`Page 18 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`and
`
`each partial multi-stage hierarchical network of said plurality of partial
`
`multi-stage hierarchical networks comprising at least one ring and each
`
`ring of said at least one ring comprising a plurality of stages; and
`
`Ex. 1001
`
`one of said plurality of stages comprising an entry stage and one of said
`
` 5:1-3,
`
`plurality of stages comprising a last stage; and
`
`8:57- 9:3,
`
`each stage of said plurality of stages comprising a switch of size
`
`,
`
`11:33-37,
`
`where
`
` and
`
`and said switch of size
`
` having
`
` inputs
`
`and
`
` outputs; and said switch of size
`
` further comprising a
`
`plurality of multiplexers of size
`
` with each multiplexer of said
`
`plurality of multiplexers of size
`
` comprising
`
` inputs and an
`
`output; and
`
`said
`
` inputs of said switch of size
`
`, and said
`
` outputs of said
`
`switch of size
`
`, connected to a plurality of internal connections or
`
`a plurality of hop wires; and said plurality of hop wires further
`
`9:62-10:9,
`
`18:44-19:2,
`
`19:2-19-5,
`
`17:16-22,
`
`20:37-41,
`
`20:42-22:53,
`
`22:37-53,
`
`24:48-60,
`
`47:27-29
`
`comprising a plurality of internal hop wires and a plurality of external
`
`
`
`hop wires; and
`
`
`
`
`
`Page 17 of 55
`
`
`d i
`
`0d
`
`2id
`
`2od
`
`d i
`
`0d
`
`id
`
`0d
`
`d i
`
`0d
`
`2d
`
`2d
`
`d
`
`id
`
`d i
`
`0d
`
`0d
`
`d i
`
`0d
`
`Page 19 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`said switch of size
`
` where
`
` or at least one input of said
`
`
`
`inputs of said switch of a first stage of said plurality of stages of a first
`
`ring of said at least one ring of a first partial multi-stage hierarchical
`
`network of said plurality of partial multi-stage hierarchical networks
`
`connected from one output of said
`
` outputs of said switch of a second
`
`stage of said plurality of stages of a second ring of said at least one ring
`
`of said first partial multi-stage hierarchical network or a second partial
`
`multi-stage hierarchical network of said plurality of partial multi-stage
`
`hierarchical networks, and
`
`each inlet link of Said plurality of inlet links is connected to one or
`
`more of said
`
` inputs of said switch of size
`
` of either said entry
`
`stage or said last stage of said plurality of stages of one partial multi-
`
`stage hierarchical network of said plurality of partial multi-stage
`
`hierarchical networks, and each outlet link of said plurality of outlet
`
`links is connected to one of said
`
` outputs of said switch of size
`
`
`
`Ex. 1001
`
`17:34-41
`
`of either said entry stage or said last stage of said plurality of stages of
`
`one partial multi-stage hierarchical network of said plurality of partial
`
`multi-stage hierarchical networks; and
`
`
`
`Page 18 of 55
`
`
`d
`i
`
`d
`
`o
`
`id
`
`d i
`
`0d
`
`0d
`
`d i
`
`0d
`
`d i
`
`0d
`
`id
`
`0d
`
`Page 20 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`a first partial multi-stage hierarchical network of said plurality of partial
`
`multi-stage hierarchical networks comprising the same or different
`
`number of said at least one ring as a second partial multi-stage
`
`hierarchical network of said plurality of partial multi-stage hierarchical
`
`networks; a first ring of said at least one ring of a first partial multi-
`
`stage hierarchical network of said plurality of partial multi-stage
`
`hierarchical networks comprising the same or different number of said
`
`plurality of stages as a second ring of said at least one ring of the said
`
`first or a second partial multi-stage hierarchical network of said
`
`plurality of partial multi-stage hierarchical networks; a first stage of
`
`said plurality of stages comprising said switch comprising the same or
`
`different number of said plurality of multiplexers as a second stage of
`
`said plurality of stages; a first multiplexer in said plurality of
`
`multiplexers of size
`
` is the same or different size as a second
`
`multiplexer in said plurality of multiplexers of size
`
`; and
`
`Ex. 1001
`
`20:1-16,
`
`19:6-19,
`
`17:22-33
`
`each internal connection of said plurality of internal connections
`
`connected from the output of a first multiplexer of said plurality of
`
`Ex. 1001
`
`multiplexers of size
`
` of said switch of a first stage of said plurality
`
`10:36-42
`
`of stages of a first ring of said at least one ring of a first partial multi-
`
`
`
`Page 19 of 55
`
`
`2d
`
`2d
`
`2d
`
`Page 21 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`stage hierarchical network of said plurality of partial multi-stage
`
`hierarchical networks to one input of said
`
` inputs of a second
`
`multiplexer of said plurality of multiplexers of size
`
` of said switch
`
`of a second stage either succeeding or preceding to said first stage of
`
`said plurality of stages of said ring of said at least one ring of said first
`
`partial multi-stage hierarchical network of said plurality of partial
`
`multi-stage hierarchical networks; and
`
`each internal hop wire of said plurality of internal hop wires is
`
`connected from the output of a first multiplexer of said plurality of
`
`multiplexers of size
`
` of said switch of a first two successive stages
`
`of said plurality of stages of a first ring of said at least one ring to a first
`
`input of said
`
` inputs of a second multiplexer of said plurality of
`
`multiplexers size
`
` of said switch of said first two successive stages
`
`or a second two successive stages of said plurality of stages of a second
`
`ring of said at least one ring different from the first ring of said at least
`
`one ring of the same partial multi-stage network of said plurality of
`
`Ex. 1001
`
`20:37-41,
`
`20:42-22:53,
`
`29:3-33:25
`
`partial multi-stage networks; and
`
`each external hop wire of said plurality of external hop wires connected
`
`
`
`Page 20 of 55
`
`
`2d
`
`2d
`
`d
`
`2d
`
`d
`
`Page 22 of 55
`
`
`
`PGR2019-00037
`Patent 10,003,553
`
`
`
`
`Paper No. 16
`Patent Owner’s Motion to Amend
`
`from said output of one multiplexer of said plurality of multiplexers of
`
`size
`
` of said switch of a first two successive stages of said plurality
`
`of stages of a first ring of said at least one ring of a first partial multi-
`
`stage hierarchical network of said plurality of partial multi-stage
`
`hierarchical networks to one or more inputs of said
`
` inputs of one or
`
`more multiplexers of said plurality of multiplexers
`
` of said switch
`
`of said first two successive stages or a second two successive stages of
`
`said plurality of stages of a second ring of said at least one ring of a
`
`second partial multi-stage hierarchical network different from said first
`
`partial multi-stage hierarchical network of said plurality of p
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
