UNITED STATES INTERNATIONAL TRADE COMMISSION
`
`Washington, D.C.
`
`CERTAIN STATIC RANDOM ACCESS
`
`NIEMORIES AND PRODUCTS CONTAINING
`
`Inv. NO. 337-TA—792
`
`
`
`In the Matter of
`
`
`
`
`THE SAME
`
`ORDER 29: CONSTRUINGTHE TERMS OF THE ASSERTED CLAIMS OF
`THE PATENTS AT ISSUE
`
`(February 9, 2012)
`
`Petitioner STMic’rOélectronicfi Inc.’, BX. 101 1
`'
`IPR2021-00355
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`Petitioner STMicroelectronics, Inc., Ex. 1011
`IPR2021-00355
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`TABLE OF CONTENTS
`
`I.
`
`INTRODUCTION..................... .......
`
`............................ . .......1
`
`11.
`
`IN GENERAL ....... ...-u ------ cOno.beI.InooooatotooIooooao'o-aonotoscoot...can...ctoscaoooooctoovooonto-octat-oocooa .......2
`
`III.
`
`RELEVANI LA 0» nub...”unannuuuun .................... u .............. ......u........u...” .......... ......2
`
`IV c
`
`LE V BL OF ORDINARY SKILL IN IHE ART on...no-ooooatooooevooouooov .......... . ....... a... ......... 5
`
`V.
`
`THE ’805 PATENT ...........
`
`.....
`
`........... . ......
`
`.................
`
`Overview ......
`
`..........
`
`................ . ........
`
`A.
`
`B.
`
`Agreed-Upon and Disputed Claim Terms
`1.
`Construction ongreed-Upon Claim Terms ...... . ...... .
`a)
`“active regions”
`13)
`“substantially oblong active regions”
`c)
`“substantially oblong polysilicon structures” ......... .. ......
`(21)
`“substantially oblong local interconnects”.................................8
`Construction ofDisputed Claim Term.................
`....... . ...... 9
`a)
`“local interconnects” .............................................................9
`
`2.
`
`OONIQNJQONQ
`
`VI.
`
`THE ’134 PATENT... .........
`
`......11
`
`A.
`
`B.
`
`Overview... ... ..
`
`..................
`
`......................................... . ...............
`
`..... .11
`
`............. ......12
`Agreed—Upon and Disputed Claim Terms ............... . .....
`.....12
`1.
`Construction ongreed—Upon Claim Terms...
`a)
`_ “external address s1gna1”12
`b)
`“non-interruptible”...................................................................12
`c)
`“burst” ......
`....................
`........ .. .......13
`Construction ofDisputed Claim Terms13
`a)
`“internal address sign’
`...
`... ..
`...13
`b)
`“logic circuit” ............
`.............
`................ . .......15 V
`c)
`“predetermined number of [said] internal address signals.......17
`
`2.
`
`V11.
`
`THE ’477 PATENT ...............
`
`...................................................... 19
`
`A. 0verv1ew19
`
`B.
`
`........ . ........... . .......... . ......20
`..........
`Agreed-Upon and Disputed Claim Terms
`1.
`Construction ongreed—Upon Claim TermsZO
`a)
`. “sensing read da ”20
`b)
`“sending write data across-a write pa ”..................................20
`c)
`“multiplexer”
`... .... 20
`d)
`“'mparallel”...............
`... ..
`... .......20
`e)
`“while” ........................................ . ...........21
`Construction of'Disputed Claim Terms... ..... .. ......
`......21
`a)
`“storing” and‘‘sending.
`................
`..21
`b)
`“holding the write address held within a set of registers” .......24
`
`2.
`
`1H0
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`Petitioner STMiCrOelectronics Inc., Ex. 1011
`IPR2021- 003 55
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`Petitioner STMicroelectronics, Inc., Ex. 1011
`IPR2021-00355
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`VIII. THE ’937 PATENT ...... . ........
`
`.....................................27
`
`A. OverVIew ..............................................................27
`
`B.
`
`2.
`
`........28
`Agreed—Upon and Disputed Claim Terms ...........................
`1.
`Construction of Agreed—Upon Claim Term ............... ..............‘.......... ..28
`a)
`“periodic signa ” .............................
`.........28
`Construction ofDisputed Claim Terms ...... .............28
`a)
`“wherein said periodic signal is configured to control data
`transfer operations”.... ....... . ............................... . ......................28
`“in response to a .
`.
`. transition of said periodic signa ” ..... .....32
`b)
`c) “tran51t10n”34
`d)
`“complementary”36
`
`.u
`11
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`Petitioner STMicroelectronics, 1110., BX. 101 1
`1PR2021-003 55
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`Petitioner STMicroelectronics, Inc., Ex. 1011
`IPR2021-00355
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`I.
`
`INTRODUCTION
`
`This Investigation was instituted by the Commission on July 28, 2011 to determine
`
`Whether certain static random access memories and products containing same inflinge U-.S.'
`
`Patent Nos. 6,534,805 (the “’805 patent”); 6,651,134 (the “’ 134 patent”); 7,142,477 (the “’477
`
`patent” ; and 6,262,937 (the “’937 patent”).1 See Fed. Reg. 45,295-96 (July 28, 2011). The
`
`named respondents are GSI Technology, Inc; Telefonaktiebolaget LM Ericsson; Ericsson Inc; ,
`
`Motorola Mobility, Inc; Motorola Solutions, Inc.; Tellabs, Inc; Cisco Systems, Inc; Avnet, Inc;
`
`and Hewlett-Packard Company/Tipping Point (collectively, “Respondents”).
`
`Pursuant to Ground Rule 5A, a Markman hearing was held on October 14, 2011
`regarding the interpretation of certain terms ofthe asserted claims ofthe patents at issue, namely:
`
`- Claims 1, 2, and M of the ’805 patent;
`
`0 Claims 1, 2 and 12915 of the ’ 134 patent;
`
`0 Claims 8 and 9 of the ’477 patent; and
`
`0 Claims 1, 2, 6, 12, and 13 of the ’937 patent.
`
`Prior to the hearing, Complainant Cypress Semiconductor Corp. (“Cypress”) and
`Respondents met and conferred in an effort to reduce the number ofdisputed claim terms to a
`
`minimum. The parties also filed initial and reply claim construction briefs, wherein each party
`
`offered its construction for the claim terms in dispute, along with support for its proposed
`
`interpretation. After the hearing and pursuant to Order No. 7, the parties submitted anupdated
`
`Joint Claim Construction Chart.2
`
`1 Complainant Cypress Semiconductor Corp. is presently the owner, by assignment, ofthe patents-in—suit. (2d Am.
`Compl. at 1} 1.3; EX. 4 to 2d Am. Compl.)
`,
`2 The claim terms discussed in detail in this Order were identified in the Updated Joint Proposed Claim Construction
`Chart as being agreed upon or remaining in dispute. For convenience, the briefs and chart submitted by the parties
`for the Markman hearing are referred to hereafter as follows:
`
`Petitioner STMicroelectronicks, Inc, BX. 101 l
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`IPR2021-003 55
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`Petitioner STMicroelectronics, Inc., Ex. 1011
`IPR2021-00355
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`II.
`
`IN GENERAL
`
`The claim terms construed in this Order are done so for the purposes ofthis Seetion 337
`
`Investigation. Those terms not in dispute need not be construed. See Vanderlande Indus.
`
`Nederland BVv. Int ’2 Trade Comm ’n, 366 F.3d 1311, 1323 (Fed. Cir. 2004) (noting that the
`
`administrative law judge need only construe disputed claim terms).
`
`‘
`
`Hereafier, discovery and briefing in this Investigation shall be goVerned by this
`
`construction of the claim terms. All other claim terms shall be deemed undisputed and shall be
`
`‘
`
`interpreted by the undersigned in accordance with “their ordinary meaning as Viewed by one of
`
`ordinary skill in the art.” Apex Inc. v. Raritan Computer, Inc, 325 F.3d 1364, 1371 (Fed. Cir.
`
`2003), cert. denied, 540 US. 1073 (2003).
`
`III.
`
`RELEVANT LAW
`
`“An infringement analysis entails two steps. The first step is determining the meaning
`
`and scope of the patent claims asserted to be infiinged. The second step is comparing the
`
`properly construed claims to the device accused of infringing.” Markman v. Westview
`
`Instruments, Inc, 52 F.3d 967, 976 (Fed. Cir. 1995) (en banc) (internal citations omitted), afl’d,
`517 US. 3370 (1996). Claim construction is a “matter oflaw exclusively for the court.” Id; at
`
`970-71. “The construction of claims is simply a way of elaborating the normally terse claim
`
`language in order to understand and explain, but not to change, the scope of the claims.”
`
`Embrex, Inc. v. Serv. Eng ’g Corp, 216 F.3d 1343, 1347 (Fed. Cir. 2000).
`
`
`
`
`
`
`
`
`
`
`
`_
`- 2 ..
`Petitioner STMicroelectroniCs, Inc, BX. 101 l
`IPR2021-003 55"
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`Petitioner STMicroelectronics, Inc., Ex. 1011
`IPR2021-00355
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`Claim construction focuses on the intrinsic evidence, which consists of the claims
`
`themselves, the specification, and the prosecution history. See Phillips v. AWH Carp. , 415 F.3d
`
`1303, 1314 (Fed. Cir. 2005) (en bane); see also Markman, 52 F.3d at 979. As the Federal Circuit
`
`.
`
`in Phillips explained, courts must analyze each of these components to determine the “ordinary
`
`and customary meaning of a claim term” as understood by a person of ordinary skill in art at the
`
`time ofthe invention. 415 F.3d at 1313. “Such intrinsic evidence is the most significant source
`ofthe legally operative meaning ofdisputed claim language.” Bell Ail. Network Saws, Inc. v. 3
`
`Covad Commc ’ns Gm, Inc, 262 F.3d 1258, 1267 (Fed. Cir. 2001).
`
`“It is a ‘bedrock principle’ of patent law that ‘the claims of a patent define the invention
`
`to which the patentee is entitled the right to exclude.” Phillips, 415 F.3d at 1312 (quoting
`
`Inflow/Pure Water, Inc. v. Safari Water Filtration Sys, Inc. , 381 F.3d 1111, 1115 (Fed. Cir.
`
`2004)). “Quite apart from the written description and the prosecution history, the claims
`
`themselves provide substantial guidance as to the meaning of particular claims terms.” Id. at
`
`1314; see also Interactive Gift" Express, Inc. v. Compuserve Inc, 256 F.3d 1323, 1331 (Fed. Cir.
`
`2001) (“In construing claims, the analytical focus must begin and remain centered on the
`
`, language ofthe claims themselves, for it is that language that the patentee chose to use to
`
`‘particularly point [ ] out and distinctly claim [ ] the subject matter which the patentee regards as
`
`his invention”). The context in which a term is used in an asserted claim can be “highly
`
`instructive.” Phillips, 415 F.3d at 1314. Additionally, other claims in the same patent, asserted
`
`or unasserted, may also provide guidance as to the meaning of a claim term. Id.
`The specification “is always highly relevant,to the claim construction analysis. Usually it
`is dispositive; it is the single best guideto the meaning ofa disputed term.” Id. at 1315 (quoting
`
`Vitronz‘cs Corp. v. Conceptronic, Inc, 90 F.3d 1576, 1582 (Fed. Cir. 1996)). “[T]he specification
`
`- 3 -
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`Petitioner STMicroelectronics, Inc, BX. 101 1
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`IPR2021-003 55
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`Petitioner STMicroelectronics, Inc., Ex. 1011
`IPR2021-00355
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`may reveal a special definition given to a claim term by the patentee that differs from the
`
`meaning it would otherwise possess. In such cases, the inventor’s lexicography governs.” Id. at
`
`1316. I “In other cases, the specification may reveal an intentional disclaimer, or disavowal, of
`
`claim scope by the inventor.” Id. As a general rule, however, the particular examples or
`
`embodiments discussed in the specification are not to be read into the claims as limitations. Id
`
`, at 1323. In the end, “[t]he construction that stays true to, the claim language and most naturally
`
`aligns with the patent’s description of the invention Will/be .
`
`.
`
`. the correct construction.” Id. at
`
`1316 (quoting Renishaw PLC v. MarpoSs Societa ’per Aziom', 158 F.3d 1243, 1250 (Fed. Cir.
`
`1 998)).
`
`In addition to the claims and the specification, the prosecution history should be
`
`examined, ifin evidence. Id. at 1317; see also Liebel-Flarsheim Co. v. Medrad, Inc, 358 F.3d
`
`898, 913 (Fed. Cir. 2004). The prosecution history can “often inform the meaning of the claim
`
`language by demonstrating how the inventor understood the invention and Whether the inventor
`
`limited the invention in the course of prosecution, making the claim scope narrower, than it
`
`would otherwise be.” Phillips, 415 F.3d at 1317; see also Chimie v. PPG Indus. Inc., 402 F.3d
`
`1371, 1384 (Fed. Cir. 2005) (“The purpose of consulting the prosecution history in construing a
`
`claim is to exclude any interpretation that was disclaimed during prosecution”).
`
`When the intrinsic evidence does not establish the meaning of a claim, then extrinsic
`
`evidence (1'. e. , all evidence external to the patent and the prosecution history, including
`
`dictionaries, inventor testimony, expert testimony, and learned treatises) may be considered.
`
`Phillips, 415 F.3d at 1317. Extrinsic evidence is generally viewed as less reliable than the patent
`
`itself and its prosecution history in determining how to define claim terms. Id. at 1317.? f‘The
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`court may receive extrinsic evidence to educate itself about the invention and the relevant
`
`~ 4 -
`,
`,
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`Petitioner STMicroelectronics, Inc., Ex. 101 1
`IPR2021-00355
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`Petitioner STMicroelectronics, Inc., Ex. 1011
`IPR2021-00355
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`technology, but the court may not use extrinsic evidence to arrive at a claim construction that is
`
`clearly at odds with the construction mandated by the intrinsic evidence.” Elkay Mfg. Co. v.
`
`Ebco Mfg. Co., 192 F.3d 973, 977 flied. Cir. 1999).
`
`If, after a review of the intrinsic and extrinsic evidence, a claim term remains ambiguous,
`
`the claim should be construed so as to maintain its validity. Phillips, 415 {F.3d at 1327. Claims,
`
`however, cannot be judicially reWritten in order to fulfill the axiom ofpreserving their validity.
`
`See Rhine v. Casio, Inc, 183 F.3d 1342, 1345 (Fed. Cir. 1999). Thus, “if the only claim
`
`construction that is consistent with the claim’s language and the Written description renders the
`
`claim invalid, then the axiom does not apply and the claim is simply invalid.” Id.
`
`IV.
`
`LEVEL OF ORDINARY SKILL IN THE ART
`
`Neither Cypress nor Respondents set forth a position as to the level ofordinary skill in
`
`the art in their briefs. Respondents’ expert, Dr. Robert Murphy, did, however, address this issue
`
`with respect to the ’134, ’937, and ’477 patents in his initial expert report on claim construction,
`wherein he stated:
`9
`
`A person of ordinary skill in the relevant art of the ’ 134, ’937, and
`’477 patents at that time would have had a BS in Electrical
`Engineering and 5 years experience with direct SRAM design
`experience.
`
`(RX-9 at 11 15.)
`
`Accordingly, as to “one of ordinary skill in the art,” the undersigned finds that, with
`
`respect to the ’134, ’937, and ”477 patents, one of ordinary skill in the art for the would be an
`
`engineer with a bachelor’s degree or higher in electrical engineering or its equivalent and five or
`more yearsofexperience in direct SRAM design. The undersigned similarly finds that With
`
`respect to the ’805 patent, one of ordinary skill in the art would be an engineer with a bachelor’s
`
`- 5 -
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`,
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`‘ Petitioner STMicroelectronics, Inc., Ex. 1011
`IPR2021-003 55
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`Petitioner STMicroelectronics, Inc., Ex. 1011
`IPR2021-00355
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`degree or higher in electrical engineering or its equivalent and five or more years of experience
`
`in SRAM design.
`
`V.
`
`THE ’805 PATENT
`
`A.
`
`Overview
`
`The ’805 patent is entitled “SRAM Cell Design? The ’805 patent issued on March 18,
`
`2003 to named inventor Bo Jin, and was subsequently assigned to Cypress. The ”805 patent has
`
`10 claims of which claims 1, 2, and 4—6 are asserted against Respondents. Claim 1 is an
`
`independent claim. Claims 2 and 4—6 are dependent claims. The asserted claims read as follows
`
`(with theiirst instance ofthe agreed—upon terms highlighted in italics and the first instance ofthe
`
`disputed term highlighted in hold):
`
`1.
`
`2.
`
`4.
`
`5.
`
`6.
`
`' A memory cell comprising aseries of four substantially oblong active regions formed
`within a semiconductor substrate and arranged side-by—side with long axes substantially
`parallel, wherein each of the inner active regions of the series comprises a pair of
`source/drain regions for a respective p—channel transistor, and each of the outer active
`regions of the series comprises a pair of source/drain regions for a respective n—channel
`transistor;
`
`The memory cell as recited in claim 1, further comprising a plurality of substantially
`oblongpolyszlzcon structures arranged above and substantially perpendicular to the active
`regions
`
`The memory cell as recited in claim 2, further comprising source/drain contacts to the '
`source/drain regions of transistors, wherein at least one of the source/drain contacts
`comprises a shared contact to one of the inner active regions and one of the polysilicon
`structures.
`
`The memory cell as recited in claim 4, further comprising a series of substantially oblong
`local interconnects arranged substantially perpendicular to the active regions, wherein the
`shared contact is connected to another of the source/drain contacts by one of the local
`interconnects.
`
`The memory cell as recitedin claim 5 wherein thelocal interconnects are dielectrically ‘
`spaced above the semiconduCtor substrate.
`
`_
`,
`,
`_
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`- 6 -
`Petitioner STMicroelectronics, Inc, Ex. 1011
`IPR2021-003 55
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`Petitioner STMicroelectronics, Inc., Ex. 1011
`IPR2021-00355
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`B.
`
`Agreed-Upon and Disputed Claim Terms
`
`1. Construction of Agreed-Upon Claim Terms
`
`a) “active regions”
`
`The term “active regions” appears in claim 1 of the ’805 patent. The parties have agreed ‘1
`
`that said term should be interpreted to mean “areas, separated by isolation regions, where active ‘
`
`transistors and/or diffusion regions are formed.” ‘(JC at 7.)
`
`I Accordingly: the undersigned adopts the parties’ proposed construction and construes the
`
`term “active regions” as “areas, separated by isolation regions, where active transistors and/or
`
`diffusion regions arefor-me .”
`
`b) “substantially ublong3 active regions”
`
`Cypress and Respondents agree that the phrase “substantially oblong active regions,”
`
`which appears in appears in claim 1 ofthe ’805 patent, should be construed as “an active region:
`
`(1) the length of which is substantially constant and the width of which varies by approximately
`
`one-third or less along the length ofthe region; (2) the length ofwhich is substantially constant
`
`and the Width of which by design varies only with respect to the widths of the access and latch,
`
`transistors; or (3) the length ofwhich is greater than or equal to approxirnately three times its
`
`maximum width; and (4) which does not include markedly L-shaped regions.” (See Notice Of
`
`Claim Construction With Respect To “Substantially Oblong” As Used In U.S. Patent No.
`
`6,534,805 (Jan. 9, 2012); JC at 6.)
`
`i
`
`Accordingly, the undersigned hereby adopts the parties’ proposed construction and shall
`
`construe “substantially oblong active regions” to mean “an active region: (1) the length of
`
`3 Cypress previously proposed the term “substantially oblong” as it is used in claims 1, 2, and 5 ofthe ’805 patent be
`construed. Subsequent to the Markman hearing, Cypress withdrew its proposed construction of “substantially
`oblong” and stipulated to Respondents’ construction of “substantially oblong” as used in the ’805 patent. (See
`Notice Of Claim Construction With Respect To “Substantially Oblong” As Used In US. Patent No. 6,534,805 (Jan.
`9, 2012).)
`,
`,_
`
`,
`.4 7i-
`Petitioner STMicroelectronics, Inc, BX. 101 1
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`IPR2021-00355
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`Petitioner STMicroelectronics, Inc., Ex. 1011
`IPR2021-00355
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`which is substantially constant and the Width ofwhich varies by approximately one-third or
`
`less along the length ofthe region; (2) the length ofwhich is substantially constant and the
`
`width ofwhich by design varies only with respect to the widths ofthe access and latch
`
`transistors; or (3) the length ofwhich is greater than or equal to approximately three times its
`maximum width; and (4) which does not include markedly li—shaped regions.”- ‘
`c) “substantially oblong polysilicon structures”
`
`The term “substantially oblong polysilieon structures”_appears in claim 2 of the ’805
`patent. Cypress has stipulated to Respondents” proposed construction for this term-,which is “a
`
`polysilicon structure the length of which is greater than about three times its Width, provided that
`
`a polysilicon structure still is substantially oblong despite having a substantially wider region.”
`
`(See Notice Of Claim Construction With Respect To “Substantially Oblong” As Used In US.
`
`Patent-No. 6,534,805 (Jan. 9, 2012);.JC at 6.)
`Accordingly, the undersigned hereby construes “subStantially oblong polysilicon
`: structures” as “apolysiliconstructure the length ofwhich is greater than about three times its
`
`width, provided that a pob’silic'on structure still is substantially oblong despite having a
`
`substantially widerregion ifthe wider region solely accommodates a contact region.”
`
`(1) “substantially oblong local interconnects”
`
`, Cypress and Respondents do not dispute the construction ofthe claim term “substantially '
`oblong local interconnects,”which appears in claim 5 ofthe ’805 patent All parties agree that
`said term should be construed as “a local interconnect the length ofwhichIS greater than or equal
`
`to approximately three times its maximum width.” (See Notice OfClaim Construction With
`
`Respect To “Substantially Oblong” As Used In US. Patent No. 6,534,805 ’(Jan. 9, 2012); JC at '
`5’6.)
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`-3-
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`Petitioner STMlcroelectromcs Inc, EX 1011
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`L
`IPR2021-00355 I
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`Petitioner STMicroelectronics, Inc., Ex. 1011
`IPR2021-00355
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`Accordingly, the undersigned shall hereby construe “substantially oblOng local
`interconnects” to mean “a local interconnect the length ofwhich is greater than or equal to
`
`approximately three times its maximum width.”
`
`2. Construction of Disputed Claim Term
`
`a)
`
`“local interconnects”
`
`The term “local interconnects” appears in claim 5 of the ’805 patent. The parties disagree
`
`on the proper claim construction of the term, and have proposed the following constructions:
`
`cell
`
`A relatively short c1rcu1t connection that does
`not extend across the entire memo
`
`Short, Circuit connections confined to a
`articular re ’on within a sinle memo
`
`cell
`
`Cypress asserts that its claim construction comes straight from the specification. Cypress
`
`cites the following language: “Local interconnections are generally used for short runs relative to
`
`much longer metal conductors used for global connections. Thus, the term ‘local interconnect’
`
`may refer to the function of connecting features within a circuit .
`
`.
`
`. .” (CMIB at 11 (Citing ’805
`
`patent at l 1:l7~22).) Cypress states that the prosecution history further confirms this definition
`
`of the term wherein the patentee stated that the “local interconnects” are “confined to a particular
`
`region within a single memory cell.” (CMIB at 11 (citing Ex. 2 at 4).)
`
`Cypress argues that, contrary to the position of Respondents, the specification does not
`
`state that “local interconnects” are “relatively short circuit connection[s.]” Cypress argues that
`the specification actually says that “[1]ocal interconnects are generally used for short runs
`relative to much longer [] global connections.” (CMIB at 11; CMRB at 7 (citing ’805 patent at
`
`11:18~20).) Cypress states that what the specification language is saying is that in comparison to
`global connections, that is “relatively” to global connections, localconnections are Shorter.
`’
`
`Thus, Cypress asserts, in this context, it is clear what “relatively” means. ,(CMRB at 7.)
`
`_
`,
`,
`_
`,,
`_
`'— 9 ~
`Petitioner STMicroelectronics, Inc, EX. 1011
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`IPR2021-00355
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`Petitioner STMicroelectronics, Inc., Ex. 1011
`IPR2021-00355
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`Cypress disagrees with Respondents’ assertion that the part of their construction, “does
`
`not extend across the entire memory cell,” is more “objectively stated” and easier to apply than
`
`the definition given in the prosecution history. Yet, Cypress alleges, Respondents concede that
`
`the prosecution history defines the term as “confined to a particular region within a memory
`
`cell.” (CMRB at 8 (citing EX. 2 at 4).) Cypress also argues that its definition is also consistent
`with the specification, which contemplates that local interconnects may “refer to the fianction of
`
`connecting features ‘Within a circuit.”’ (Id. (citing ’805 patent at 11:20-21 (emphasis added)).)
`
`Cypress also argues that the prosecution history states that “a local interconnect does not extend
`
`across the entire cell such that when memory cells are abutted against each other, a local
`
`_
`
`'
`
`interconnect would extend globally across the entire integrated circuit comprising an array of
`
`memory cells.” (Id. (citing Ex. 2 at 4).). Cypress claims that this confirms that the local
`
`interconnect is used in a single memory cell. (Id)
`
`’
`
`In support of their claim interpretation, Respondents argue that the local interconnects
`
`should be “relatively short,” as opposed to “short,” as proposed by Cypress. Respondents state
`
`that the “relatively short” language comes from both the specification and the prosecution
`
`history. (RMIB at 19.) Respondents note that the specification states that the “[l]ocal
`interconnections are generally used for shorter runs relative to much longer metal connections
`
`used for global connections.” (RMIB at 20; RMRB) at 8 (citing ’805 patent at 11:18-20).)
`Respondents argue that, during prosecution, the applicant stated, in the context ofdistinguishing
`
`prior art, that “ [a] local interconnect is defined in the present specification as one Which is
`relatively short .
`.
`. .” (RMIB at 20 (citing RX~3 at 4—5).) Thus, Respondents argue that the
`
`“relatively short” language of Respondents’ proposed construction iswell-supported in the
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`intrinsic evidence.
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`,
`_
`,
`,,
`,
`,
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`,_ Second,._Respondents note that their construction states that a local interconnect “does not
`
`extend across the entire memory cell,” Whereas Cypress states that a local interconnect “is
`
`' confined to a particular region Within a memory cell.” Respondents state that both of these _
`
`statements come verbatim from the prosecution history except that Cypress adds the word
`
`, “single” to its construction. (RMIB at 20 (citing RX-3 at 4-5).) Respondents state that they
`
`believe that these two statements make the same point, but “that the point is more objectively ,,
`
`stated (and that it is easier to determine Whether the claimed feature exists in a memory device)
`
`using the phrase ‘does not extend acress the entire memory cell?” (1d,)
`
`Taking into account the language from the prosecution history cited by the parties GRX-3
`
`at 4—5) and the language of the specification (’805 patent at 11:18-20), the undersigned hereby
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`construes the claim term “local interconnect” to mean “a connection that is short relative to a
`
`much longer metal connection usedfor a global connection, is confined to a particular region
`
`within a memory cell, and does not extend across the entire memory cel .”
`
`VI.
`
`THE ’134 PATENT
`
`A.
`
`Overview
`
`The ’ 134 patent is entitled “Memory Device With Fixed Length Non Interruptible Burst.”
`
`The ’ 134 patent issued on November 18, 2003 to named inventor Cathal G. Phelan, and was
`subsequently assigned to Cypress. The ’ 134 patent has 21 claims ofwhich claims 1, 2 and 12-
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`15 are asserted against Respondents. Claim 1 is an independent claim. Claim 2, 12, 13, 14, and
`15 depend from claim 1. These claims read as follows (with the first instance ofthe agreed-upon,
`
`terms highlighted in italics and the first instance ofthe disputed terms highlighted in hold):
`1.
`A circuit comprising: amemory comprising a plurality of storage elements each
`configured to read and write data in response to an internal address signal; and a logic
`circuit configured to generate a predetermined number of said internal address ,
`signals in response to (i) anextemal address signal, (ii) a clock signal and (iii) one or
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`,‘
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`2.
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`12.
`
`13.
`
`14.
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`15.
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`more control signals, wherein said generation of said predetermined number of internal
`address signals is non-interruptible.
`
`The circuit according to claim 1, wherein said predetermined number of internal address
`signals is determined by a fixed burst length.
`
`The circuit according to claim 1, wherein said logic circuit comprises a counter
`configured to generate said predetermined number of internal address signals.
`
`The circuit according to claim 1, wherein said external address signal comprises an initial
`address for data transfers to and from said memory.
`
`A memory device according to claim 1, wherein said circuit is an integrated circuit.
`
`The circuit according to claim 1, further comprising address and control busses
`configured to present said external address signal and said one or more control signals,
`wherein said busses are freed up during the generation of said predetermined number of
`internal address signals.
`
`_
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`B.
`
`Agreed—Upon and Disputed Claim Terms
`
`1. Construction of Agreed-Upon Claim Terms
`
`a) “external address signal”
`
`Cypress and Respondents agree that the term “esternal address sign ,” which appears in
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`appears in claims 1, 13, and 15 of the ’ 134 patent, should be construed as “an address signal that
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`originates outside of the circuit.” (JC at 7.)
`
`_
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`Accordingly, the undersigned hereby adopts the parties’ proposed construction and shall
`
`construe “external address signal” to mean “an address signal that originates outside ofthe '
`
`circuit.”
`
`1)) “non-interruptible” '
`
`Cypress and Respondents do not dispute the construction of the claim term “non- _
`
`interruptible,” which appears in claim 1 of the ’ 134 patent. All parties agree that said term
`
`should be construed as “cannot be stopped or terminated once initiated until the fixed number of
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`internal addresses has been generated.” (Id. at 8.)
`
`_“12;,
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`_
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`_
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`Accordingly, the undersigned hereby construes “non-interruptible” as “cannot be stopped
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`or terminated once initiated until thefixed number ofinternal addresses has been generated.”
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`0) “burst”
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`The term “burst” appears in claim 2 of the ’ 134 patent. The parties have agreed that said
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`term should be interpreted to mean “a number of words transferred as a group.” (161.)
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`Accordingly, the undersigned shall hereby construe the term “burst” as “a number of
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`words transferred as a group.”
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`2. Construction of Disputed Claim Terms
`
`ya) “internal address signal”
`
`The term “internal address signa ” appears in claims 1, 2, 12, and 15 of the ’ 134 patent.
`
`The parties disagree on the proper claim constructiongand construe the term as follows:
`
`to read and write data to said memo
`
`gng
`g1
`associated with a memory to enable said
`memo
`
`sgn
`g
`circuit claimed by the preamble
`
`Cypress asserts that its proposed construction comes directly from the claim language
`
`itself; namely: “What is claimed is: A circuit comprising: a memory ., .
`
`. ;'and a logic circuit.”
`
`(CMIB at 13 (citing ’ 134 patent at 5:21-26; 10/14/11 Tr. at 56:20~22).) Cypress contends that,
`
`\
`
`contrary to Respondents’ objection, its construction does not read the word “interna ” out of the
`
`claim for “Cypress’s construction noted that the address signal is generated ‘by’ the ‘logic
`
`circuit’ and ‘memory,’ the two elements that make up the ‘circuit’ referenced by the preamble in
`
`claim 1.” (CMRB at 11; see also CMIB at 14 (arguing that the signal is generated inside the
`
`circuit referenced in the preamble).)
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`’1‘
`L
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`Respondents submit that their proposed construction is consistent with the plain meaning 7
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`of the'word “interna .” (RMIB at 25.) Respondents also claim that their construction is
`consistent with the understanding ofthe term to one ofordinary skill in the art, ‘iwho understands
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`that the internal address signals are generated within the circuit.” (Id. (citing ’RX-Q at '[I 27).)
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`Cypress’s construction, Respondents argue, fails to require that the claimed “internal
`
`address signal” be generated inside the circuit referenced in the preamble. (RMRB at 11; see
`
`also RMIB at 25 (arguing that Cypress’ 3 construction essentially writes the word‘internal” out
`ofthe claim).) Respondents also assert that Cypress5 construction incorrectly suggests that the
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`'
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`internal address signals read and write data to the memory. Internal address signals,
`
`, Respondents argue, do not themselves read and write; rather, they identify the locations in the
`
`memory to which data is written or from which it is read. (Id)
`
`The parties concede that While they agree on the substance (122., that the internal address
`
`signal comes from the circuit referenced in the preamble), they cannot agree on the winding of
`
`the construction. (See 10/14/11 Tr. at 56:4—9, 57:22-23, 58:4—7, 59:9-22;,CMIB at 14-15; RMIB
`
`at 25; see also ’ 134 patent at Fig. l.) The central dispute between the parties is whether the “a,
`circuit” in the preamble of claim 1 is a claim limitation.4
`I
`I
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`'
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`According to Federal Circuit precedent, “a preamble limits the invention if it recites
`
`'
`essential structure or steps, or if it is ‘necessary to give life, meaning, and vitality to the claim.
`Catalina Mg, Int’l, Inc. v. Coolsavings.com,'1nc., 289 F.3d 801, 808(Fed. Cir. 2002). In other
`words, “ifthe preamble helps to determine the scope ofthe pat