PETITIONER’S
`PETITIONER’S
`DEMONSTRATIVE EXHIBIT
`DEMONSTRATIVE EXHIBIT
`1016
`1016
`
`
`PETITIONER’S
`DEMONSTRATIVE EXHIBIT
`DEMONSTRATIVE EXHIBIT
`1016
`1016
`
`
`
`Advanced Micro Devices, Inc. et al.
`v.
`Monterey Research LLC
`
`Petitioners’ Presentation For IPR2020-00985
`U.S. Patent No. 6,651,134
`September 1, 2021
`
`1
`
`Demonstrative Exhibit 1016, 0001
`
`
`
`Overview
`
`Alleged Invention
`“Non-Interruptible” Limitation
`Wada
`Wada + Barrett
`Patent Owner Fails To Distinguish Prior Art
`“Predetermined Number” Limitation
`No Objective Indicia of Non-Obviousness
`
`2
`
`Demonstrative Exhibit 1016, 0002
`
`
`
`Overview
`
`Alleged Invention
`“Non-Interruptible” Limitation
`Wada
`Wada + Barrett
`Patent Owner Fails To Distinguish Prior Art
`“Predetermined Number” Limitation
`No Objective Indicia of Non-Obviousness
`
`3
`
`Demonstrative Exhibit 1016, 0003
`
`
`
`’134 Patent – Non-Interruptible Burst Memory
`
`’134 Patent (Ex-1001) at Cover, claim 1
`
`4
`
`Demonstrative Exhibit 1016, 0004
`
`
`
`Grounds Presented In Petition
`
`Ground
`1
`2
`2a
`3
`3a
`4
`4a
`5
`5a
`
`Prior Art and Claims
`Wada anticipates claims 1-3, 8, 12-13, 16, and 17
`Wada renders obvious claims 1-4, 8, 12-14, 16, and 17
`Wada + Barrett renders obvious claims 1-4, 8, 12-14, 16, and 17
`Wada + Fujioka renders obvious claims 4-7 and 18-20
`Wada + Barrett + Fujioka renders obvious claims 4-7 and 18-20
`Wada + Reeves renders obvious claims 9-10, 14, and 21
`Wada + Barrett + Reeves renders obvious claims 9-10, 14, and 21
`Wada + Lysinger renders obvious claims 11 and 15
`Wada + Barrett + Lysinger renders obvious claims 11 and 15
`
`Petition (Paper 1) at 5
`
`5
`
`Demonstrative Exhibit 1016, 0005
`
`
`
`Overview
`
`Alleged Invention
`“Non-Interruptible” Limitation
`Wada
`Wada + Barrett
`Patent Owner Fails To Distinguish Prior Art
`“Predetermined Number” Limitation
`No Objective Indicia of Non-Obviousness
`
`6
`
`Demonstrative Exhibit 1016, 0006
`
`
`
`U.S. 6,115,280 (“Wada”)
`
`Wada (Ex-1005) at 6:3-8, 16:12-15; Petition (Paper 1) at 23, 47; Pet. Reply (Paper 21) at 4
`
`7
`
`Demonstrative Exhibit 1016, 0007
`
`
`
`An Interruption Anywhere Defeats Wada’s Goals
`
`Wada’s prior art
`embodiment of Figures
`15-16 is unacceptable
`
`Interruption
`introduced
`
`Wada (Ex-1005) at 5:59-63, Figs. 15, 16; Pet. Reply (Paper 21) at 2-4
`8
`
`Demonstrative Exhibit 1016, 0008
`
`
`
`Wada’s Bursts Are Not Interruptible
`
`Wada’s second embodiment
`(Figs. 3-4) eliminates
`interruptions in burst
`addresses generated
`corresponding to external
`address Am.
`
`Wada (Ex-1005) at 16:8-10, Fig. 4; Pet. (Paper 1) at 22-23; Pet. Reply (Paper 21) at 5.
`
`9
`
`Demonstrative Exhibit 1016, 0009
`
`
`
`Patent Owner’s Expert Agrees
`
`Patent Owner’s expert
`agrees “data corresponding
`to the address Am” is one
`burst.
`
`. . .
`
`Wada at 16:8-10
`
`Brogioli Dep. at 211:23-212:7 (emphasis added)
`
`Wada (Ex-1005) at 16:8-10; Brogioli Dep. (Ex-1015) at 211:23-212:7; Pet. Reply (Paper 21) at 5
`
`10
`
`Demonstrative Exhibit 1016, 0010
`
`
`
`Board Concurrence Recognized Wada’s Overall Goal
`
`Institution Decision,
`APJ Horvath,
`concurring
`
`Institution Decision (APJ. Horvath, concurring) (Paper 13) at 28.
`
`11
`
`Demonstrative Exhibit 1016, 0011
`
`
`
`U.S. 5,584,033 (“Barrett”)
`
`Barrett (Ex-1010) at 1:64-67, 2:39-41; Petition (Paper 1) at 50-51, Pet. Reply (Paper 21) at 17
`12
`
`Demonstrative Exhibit 1016, 0012
`
`
`
`Board Agreed Wada + Barrett Teaches Non-Interruptible Burst
`
`Institution Decision
`
`Institution Decision (Paper 13) at 21
`
`13
`
`Demonstrative Exhibit 1016, 0013
`
`
`
`Overview
`
`Alleged Invention
`“Non-Interruptible” Limitation
`Wada
`Wada + Barrett
`Patent Owner Fails To Distinguish Prior Art
`“Predetermined Number” Limitation
`No Objective Indicia of Non-Obviousness
`
`14
`
`Demonstrative Exhibit 1016, 0014
`
`
`
`Patent Owner Fails To Distinguish Prior Art
`
`Wada’s teachings not limited to eliminating
`interruptions only between bursts
`Wada’s control signals make it no more
`“interruptible” than those of the ’134 Patent
`Wada and Barrett are not directed to opposing
`goals
`
`Pet. Reply (Paper 21) at 2-3, 8-12, 17; Petition (Paper 1) at 8, 51-53
`15
`
`Demonstrative Exhibit 1016, 0015
`
`
`
`Patent Owner Fails To Distinguish Prior Art
`
`Wada’s teachings not limited to eliminating
`interruptions only between bursts
`Wada’s control signals make it no more
`“interruptible” than those of the ’134 Patent
`Wada and Barrett are not directed to opposing
`goals
`
`Pet. Reply (Paper 21) at 2-3, 8-12, 17; Petition (Paper 1) at 8, 51-53
`16
`
`Demonstrative Exhibit 1016, 0016
`
`
`
`Wada Eliminates Interruptions Between And Within Bursts
`
`Wada solves all problems
`preventing high speed operation
`
`Wada’s First Conventional Embodiment
`
`Wada’s Second Conventional Embodiment
`
`Wada (Ex-1005) at 6:3-7, Figs. 13, 16 (annotated); Pet. Reply (Paper 21) at 2-4
`17
`
`Demonstrative Exhibit 1016, 0017
`
`
`
`Wada Eliminates Interruptions Between And Within Bursts
`
`Wada’s second embodiment
`expressly teaches
`eliminating interruptions in
`the burst addresses
`corresponding to external
`address Am.
`
`Wada (Ex-1005) at 16:8-10, Fig. 4 (annotated); Pet. (Paper 1) at 22-23
`18
`
`Demonstrative Exhibit 1016, 0018
`
`
`
`Patent Owner Fails To Distinguish Prior Art
`
`Wada’s teachings not limited to eliminating
`interruptions only between bursts
`Wada’s control signals make it no more
`“interruptible” than those of the ’134 Patent
`Wada and Barrett are not directed to opposing
`goals
`
`Pet. Reply (Paper 21) at 2-3, 8-12, 17; Petition (Paper 1) at 8, 51-53
`19
`
`Demonstrative Exhibit 1016, 0019
`
`
`
`Wada Is As “Uninterruptible” As The ’134 Patent
`
`Wada, Fig. 12 (excerpt)
`
`’134 Patent, Fig. 2
`
`Wada (Ex-1005) at Fig. 12 (annotated); ’134 Patent (Ex-1001) at Fig. 2 (annotated); Pet. Reply (Paper 21) at 8-9; Petition (Paper 1) at 8
`20
`
`Demonstrative Exhibit 1016, 0020
`
`
`
`Wada Is As “Uninterruptible” As The ’134 Patent
`
`When ’134 Patent’s
`ADV/LDB signal goes low,
`next burst is generated
`
`’134 Patent (Ex-1001) at 3:14-23, Fig. 5A (annotated); Pet. Reply (Paper 21) at 9-11
`
`21
`
`Demonstrative Exhibit 1016, 0021
`
`
`
`Wada Is As “Uninterruptible” As The ’134 Patent
`
`Patent Owner’s expert agrees that ADV low starts the burst over:
`
`Brogioli Dep. (Ex-1015) at 116:6-24 (emphasis added); Pet. Reply (Paper 21) at 11-12
`
`22
`
`Demonstrative Exhibit 1016, 0022
`
`
`
`Wada Is As “Uninterruptible” As The ’134 Patent
`
`Wada, Fig. 13
`
`’134 Patent, Fig. 5A
`
`Wada (Ex-1005) at Fig. 13 (annotated); ’134 Patent (Ex-1001) at Fig. 5A (annotated); Petition (Paper 1) at 28; Pet. Reply (Paper 21) at 10-11
`
`23
`
`Demonstrative Exhibit 1016, 0023
`
`
`
`Patent Owner Fails To Distinguish Prior Art
`
`Wada’s teachings not limited to eliminating
`interruptions only between bursts
`Wada’s control signals make it no more
`“interruptible” than those of the ’134 Patent
`Wada and Barrett are not directed to opposing
`goals
`
`Pet. Reply (Paper 21) at 2-3, 8-12, 17; Petition (Paper 1) at 8, 51-53
`24
`
`Demonstrative Exhibit 1016, 0024
`
`
`
`Wada and Barrett’s Goals Not Opposed
`Barrett and Wada are in similar fields:
`Barrett
`Wada
`“[T]he present invention [] provide[s]
`“multiple CPUs and memory units communicating
`semiconductor memory working in burst mode for
`with other units via system I/O bus...” Barrett at 4:46-
`a high-speed read operation...” Wada at 6:3-7.
`48
`Barrett and Wada share goal of high-speed uninterrupted burst data transfer:
`Barrett
`Wada
`“a burst data transmission comprised of a plurality
`“allows the data corresponding to address Am to be
`of uninterruptible streams of n data transfer
`output uninterrupted in burst mode.” Wada at 16:8-
`cycles.” Barrett at claim 1.
`10
`“a semiconductor memory operating in burst mode
`at a sufficiently high speed irrespective of the
`operating speed of its memory cell array.” Wada at
`5:67-6:2.
`
`“allowing a pause at any point defeats the purpose
`of burst transmission, which is to send data as
`rapidly as possible in an uninterrupted stream.”
`Barrett at 2:39-41.
`
`Wada (Ex-1005) at 5:67-6:7, 16:8-10; Barrett (Ex-1010) at 2:39-41, 4:46-48, claim 1; Petition (Paper 1) at 51-52; Pet. Reply (Paper 21) at 17
`25
`
`Demonstrative Exhibit 1016, 0025
`
`
`
`Wada and Barrett’s Goals Not Opposed
`Patent Owner argues:
`
`P.O. Sur-Reply (Paper 22) at 13-14
`
`26
`
`Demonstrative Exhibit 1016, 0026
`
`
`
`Wada And Barrett Do Not Defeat Each Other’s Goals
`
`Barrett
`
`Barrett (Ex-1010) at 3:52-61; Pet Rep. (Paper 21) at 19
`
`27
`
`Demonstrative Exhibit 1016, 0027
`
`
`
`Overview
`
`Alleged Invention
`“Non-Interruptible” Limitation
`Wada
`Wada + Barrett
`Patent Owner Fails To Distinguish Prior Art
`“Predetermined Number” Limitation
`No Objective Indicia of Non-Obviousness
`
`28
`
`Demonstrative Exhibit 1016, 0028
`
`
`
`Wada Teaches Predetermined Number of Addresses
`’134 Patent
`
`’134 Patent (Ex-1001) at claim 1
`
`29
`
`Demonstrative Exhibit 1016, 0029
`
`
`
`Wada Teaches Predetermined Number of Addresses
`Wada
`
`Wada’s burst counter is
`configured to generate 2^k
`internal addresses
`
`Wada (Ex-1005) at Fig. 12 (annotated excerpt); Pet. Reply (Paper 21) at 7
`
`30
`
`Demonstrative Exhibit 1016, 0030
`
`
`
`Wada Teaches Predetermined Number of Addresses
`
`Patent Owner’s expert agrees that k bits represent 2^k states:
`
`Brogioli Dep. (Ex-1015) at 193:16-194:5; Pet. Reply (Paper 21) at 7
`
`31
`
`Demonstrative Exhibit 1016, 0031
`
`
`
`Wada Teaches Predetermined Number of Addresses
`
`Institution Decision
`
`Institution Decision (Paper 13) at 21
`
`32
`
`Demonstrative Exhibit 1016, 0032
`
`
`
`Patent Owner’s Argument Fails
`Wada
`
`Wada (Ex-1005) at Figs. 12 (annotated excerpt), 13; Pet. Reply (Paper 21) at 7-8
`
`33
`
`Demonstrative Exhibit 1016, 0033
`
`
`
`Overview
`
`Alleged Invention
`“Non-Interruptible” Limitation
`Wada
`Wada + Barrett
`Patent Owner Fails To Distinguish Prior Art
`“Predetermined Number” Limitation
`No Objective Indicia of Non-Obviousness
`
`34
`
`Demonstrative Exhibit 1016, 0034
`
`
`
`No Objective Indicia of Non-Obviousness
`
`Alleged long-felt need to mitigate DRAM/SDRAM refresh
`requirement fails to show non-obviousness
`No nexus: ’134 Patent claims encompass SRAM, which has no
`need of refresh
`’134 Patent does not eliminate need to refresh DRAM
`Mitigation for DRAM refresh had already been solved in the
`prior art
`Timeline of JDEC specification publications shows opposite of
`what Patent Owner claims
`
`Pet. Rep. (Paper 21) at 21-26
`
`35
`
`Demonstrative Exhibit 1016, 0035
`
`
`
`No Nexus Between Claims And Alleged Long-Felt Need
`
`Patent Owner Response:
`
`Patent Owner’s
`alleged “long-felt
`need” is to mitigate
`need to refresh
`DRAM/SDRAM
`
`P.O. Resp. (Paper 19) at 64; Pet. Reply (Paper 21) at 21
`
`36
`
`Demonstrative Exhibit 1016, 0036
`
`
`
`No Nexus: Claims Encompass SRAM
`
`’134 Patent
`
`‘134 Patent (Ex-1001) at claims 1, 8; Petition (Paper 1) at 33; Pet. Reply (Paper 21) at 13-14, 24
`
`37
`
`Demonstrative Exhibit 1016, 0037
`
`
`
`No Nexus: ’134 Patent Does Not Eliminate Refresh
`
`Patent Owner’s expert admits no teaching in ’134 Patent:
`
`Brogioli Dep. (Ex-1015) at 27:12-19; Pet. Rep. (Paper 21) at 14
`
`38
`
`Demonstrative Exhibit 1016, 0038
`
`
`
`Mitigation For DRAM Refresh Was Already Known
`
`Reeves (Ex-1008) at Abstract; Petition (Paper 1) at 60-65; Pet. Reply (Paper 21) at 14-15, 21
`39
`
`Demonstrative Exhibit 1016, 0039
`
`
`
`Solved Problem Cannot Demonstrate Long Felt Need
`
`Nike's arguments and evidence on long-felt need focused
`solely on Nishida and its response to the problem in the
`art of making cutting waste less expensive, but ignored
`the teachings of other asserted prior art references. . . .
`‘any alleged, long-felt need was met by the teachings of at
`least Schuessler I, namely, knitting textile elements
`'without requiring cutting’
`
`Nike, Inc. v. Adidas AG, 955 F.3d 45, 55 (Fed. Cir. 2020)
`
`Pet. Reply (Paper 21) at 21
`
`40
`
`Demonstrative Exhibit 1016, 0040
`
`
`
`Patent Owner’s Sur-Reply
`
`Patent Owner Argues in Sur-Reply:
`
`P.O. Sur-Reply (Paper 22) at 16
`
`41
`
`Demonstrative Exhibit 1016, 0041
`
`
`
`JEDEC Specification Timeline Does Not Show Long Felt Need
`
`JDEC DDR at 23
`
`JDEC DDR at 1
`
`JDEC DDR (Ex-2010) at 1, 23; Pet. Reply (Paper 21) at 22
`
`42
`
`Demonstrative Exhibit 1016, 0042
`
`
`
`DDR2 Specification In 2004 and 2005 Still Specifies Interrupts
`
`However, in case of BL=8 setting,
`two cases of interrupt by a new
`burst access are allowed, one reads
`interrupted by a read, the other
`writes interrupted by a write with 4
`bit burst boundary respectively.
`
`JDEC DDR 2 at 29-30
`
`JDEC DDR2 at 1
`
`JDEC DDR2 at 100
`
`JDEC DDR2 (Ex-2011) at 1, 29-30, 100; Pet. Reply (Paper 21) at 22-23
`
`43
`
`Demonstrative Exhibit 1016, 0043
`
`
`
`Back-up / Rebuttal Slides
`
`44
`
`Demonstrative Exhibit 1016, 0044
`
`
`
`Claim 16 Means Plus Function Structure Mapping
`
`16[a]: means for reading data from and writing data to a plurality of
`storage elements in response to a plurality of internal address signals
`
`’134 Patent, Fig. 1
`
`Wada, Fig. 12
`
`’134 Patent (Ex-1001) at Fig. 1 (annotated); Wada (Ex-1005) at Fig. 12 (annotated); Petition (Paper 1) at 40-41
`
`45
`
`Demonstrative Exhibit 1016, 0045
`
`
`
`Claim 16 Means Plus Function Structure Mapping
`
`16[b]: means for generating a predetermined number of said internal address signals in response to (i)
`an external address signal, (ii) a clock signal and (iii) one or more control signals, wherein said
`generation of said predetermined number of internal address signals is non-interruptible
`
`’134 Patent, Fig. 3
`
`Wada, Fig. 12
`
`’134 Patent (Ex-1001) at Fig. 3 (annotated); Wada (Ex-1005) at Fig. 12 (excerpt); Petition (Paper 1) at 43-44
`
`46
`
`Demonstrative Exhibit 1016, 0046
`
`
`
`’134 Patent Solution Was Known In The Art
`Alleged problem of interrupted bursts did not exist
`for SRAM
`’134 Patent’s references to refresh cycles apply
`only to DRAM, not SRAM
`’134 Patent:
`
`Yet ’134 Patent claims cover both SRAM and
`DRAM/SDRAM
`
`Pet. Reply (Paper 21), 13-14
`
`47
`
`Demonstrative Exhibit 1016, 0047
`
`
`
`’134 Patent Solution Was Known In The Art
`
`Reeves (Ex-1008) at Abstract; Petition (Paper 1) at 60-65; Pet. Rep. (Paper 21) at 14-15, 21
`48
`
`Demonstrative Exhibit 1016, 0048
`
`
`
`Patent Owner’s Sur-Reply
`
`Patent Owner Argues in Sur-Reply:
`
`P.O. Sur-Reply (Paper 22) at 10
`49
`
`Demonstrative Exhibit 1016, 0049
`
`
`
`’134 Patent Solution Was Known In The Art
`
`File History, ’134 Patent
`
`’134 File Hist. (Ex-1004) at 112; Pet. Prelim. Reply (Paper 10) at 1-2
`
`50
`
`Demonstrative Exhibit 1016, 0050
`
`
`
`’134 Patent Solution Was Known In The Art
`
`Patent Owner incorrectly argues
`“The ’134 Patent discloses a
`mechanism to achieve a non-
`interruptible burst.”
`
`PO Resp. (Paper 19) at 31; ’134 Patent (Ex-1001) at Fig. 2; Pet. Reply (Paper 21) at 15-16
`
`51
`
`Demonstrative Exhibit 1016, 0051
`
`
`
`’134 Patent Solution Was Known In The Art
`
`Patent Owner’s expert agrees
`
`Brogioli Dep. (Ex-1015) at 153:24-154:17; Pet. Reply (Paper 21) at 15-16
`
`52
`
`Demonstrative Exhibit 1016, 0052
`
`
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