Petitioners’ Oral Argument
`
`Petitioners Samsung Electronics Co., Ltd., Dell Technologies Inc., and Anker Innovations Ltd.
`
`Case Nos. IPR2022-00311 and -00312
`
`February 24, 2023
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`Samsung/Dell, Exh. 1033, p. 1
`Samsung/Dell v. MYPAQ, IPR2022-00311
`
`

`

`Case Overview
`
`IPR No.
`
`Challenged Patents
`
`IPR2021-00311 (“-311 IPR”)
`
`U.S. 8,477,514 (‘514 Patent)
`
`IPR2021-00312 (“-312 IPR”)
`
`U.S. 7,675,759 (‘759 Patent)
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`2
`
`Paper 8 (Scheduling Order)
`
`Samsung/Dell, Exh. 1033, p. 2
`Samsung/Dell v. MYPAQ, IPR2022-00311
`
`

`

`Agenda
`
`Brief Overview
`
`•
`
`•
`
`‘514 and ‘759 Patents
`
`Prior Art Grounds
`
`Common Issues -311 IPR & -312 IPR
`
`•
`
`•
`
`•
`
`•
`
`•
`
`“system operational state of [a/said] load”
`
`“control said duty cycle”
`
`power converter “controller”
`
`“power system controller”
`
`“core state”
`
`-311 IPR Specific Issues (‘514 Patent)
`
`•
`
`•
`
`•
`
`•
`
`•
`
`“signal characterizing a power requirement of a processor system”
`
`“[enable/enabling] components of a processor system”
`
`“over a period of time”
`
`“upon startup”
`
`Motivation to Combine Hwang/Chagny
`
`-312 IPR Specific Issues (’759 Patent)
`
`•
`
`•
`
`•
`
`•
`
`•
`
`“power converter operational state”
`
`“power converter status”
`
`“a power system controller configured to receive a signal”
`
`“within a transition time”
`
`Markush Groups
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`3
`
`Samsung/Dell, Exh. 1033, p. 3
`Samsung/Dell v. MYPAQ, IPR2022-00311
`
`

`

`Challenged Patents
`U.S. Patent No. 8,477,514
`
`U.S. Patent No. 7,675,759
`
`‘514 Patent, -311 IPR, EX1001 at Cover
`
`‘759 Patent, -312 IPR, EX1001 at Cover
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`4
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`Samsung/Dell, Exh. 1033, p. 4
`Samsung/Dell v. MYPAQ, IPR2022-00311
`
`

`

`Overview – Challenged Patents
`
`“A switch-mode power converter (also referred to as a ‘power converter’) is a power
`supply or power processing circuit that converts an input voltage waveform into a
`specified output voltage waveform.”
`
`‘514 Patent, -311 IPR, EX1001 at 2:42-45
`‘759 Patent, -312 IPR, EX1001 at 1:21-24
`
`“As known in the art, and explained in
`the ’514 Patent background, the duty
`cycle of the switches (i.e., ratio of on-
`time to the total switching period) in a
`power converter can be adjusted to
`regulate the output voltage Vout of the
`power converter. Id., 2:57-3:9, 11:15-
`18; EX1002,¶38.”
`
`-311 IPR, Petition (Paper 3) at 4 (citing EX1001 and EX1002 )
`See also -312 IPR, Petition (Paper 3) at 4 (citing EX1001 and EX1002 )
`
`‘514 Patent, -311 IPR, EX1001 at FIG. 2
`‘759 Patent, -312 IPR, EX1001 at FIG. 2
`
`“The ’514 Patent acknowledges that it was ‘well known’ to control output characteristics
`(e.g., the output voltage) of a converter based on the needs of a microprocessor coupled to
`the output. Id., 4:63-5:4. But, the ’514 Patent purports to improve upon the prior art by
`adjusting an internal operating characteristic of the power converter based on a signal from
`an external source. Id., 6:36-44.”
`
`-311 IPR, Petition (Paper 3) at 4-5 (citing EX1001 )
`See also -312 IPR, Petition (Paper 3) at 4-5 (citing EX1001 )
`
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`5
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`Samsung/Dell, Exh. 1033, p. 5
`Samsung/Dell v. MYPAQ, IPR2022-00311
`
`

`

`Overview – Invalidity Grounds
`
`U.S. Patent No. 8,477,514 (IPR2022-00311)
`
`Ground
`
`Claims
`
`1A
`
`1B
`
`2A
`
`2B
`
`2C
`
`2D
`
`1-12, 14-17, 19-20
`
`1-20
`
`1-10, 16-17, 19-20
`
`11-12, 14-17, 19-20
`
`18
`
`13, 18
`
`Basis
`
`§ 102
`
`§ 103
`
`§ 102
`
`§ 103
`
`§ 103
`
`§ 103
`
`Prior Art
`
`Chagny
`
`Chagny
`
`Hwang
`
`Hwang, Chagny
`
`Hwang
`
`Hwang, Chagny
`
`U.S. Patent No. 7,675,759 (IPR2022-00312)
`
`Ground
`
`Claims
`
`1A
`
`1B
`
`2A
`
`2B
`
`2C
`
`3
`
`1-3, 5-13, 15-20
`
`1-3, 5-13, 15-20
`
`1-2, 4-6, 11, 14-16, 20
`
`1-2, 4-6, 11, 14-16, 20
`
`3, 12-13, 19
`
`1-2, 4-6, 11, 14-16, 20
`
`Basis
`
`§ 102
`
`§ 103
`
`§ 102
`
`§ 103
`
`§ 103
`
`§ 103
`
`Prior Art
`
`Hirst
`
`Hirst
`
`Chagny
`
`Chagny
`
`Chagny, Clark
`
`Hwang
`
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`6
`
`Samsung/Dell, Exh. 1033, p. 6
`Samsung/Dell v. MYPAQ, IPR2022-00311
`
`

`

`Hirst Reference Overview
`
`“Hirst discloses a multiple frequency
`switching power supply that can operate with
`a first switching frequency when a load is in a
`normal operating mode and with a second
`switching frequency when a load is in a
`standby operating mode. Ex. 1003, code (57),
`3:17–23.”
`
`-312 IPR, Inst. Dec. (Paper 11) at 12 (citing EX1003)
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`7
`
`‘759 Patent, -312 IPR, EX1003 at Cover
`
`Samsung/Dell, Exh. 1033, p. 7
`Samsung/Dell v. MYPAQ, IPR2022-00311
`
`

`

`Chagny Reference Overview
`
`“On this record, it appears that Chagny’s
`VRM 200 is coupled to and provides power
`to processor 292 in the same way that the
`power converter described in the ’514 Patent
`is coupled to and provides power to a
`microprocessor. Compare Ex. 1001, 10:12–15
`… with Ex. 1004, 3:54–58 … .”
`
`-311 IPR, Inst. Dec. (Paper 11) at 13 (citing EX1004, code (57))
`
`“Chagny ‘relates to a system and method for
`improving the efficiency of a [voltage
`regulator module (VRM)] used to provide
`power to portable information handling
`system devices.’ Ex. 1004, 2:40–43.”
`
`-312 IPR, Inst. Dec. (Paper 11) at 22 (citing EX1004, 2:40-43 )
`
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`8
`
`‘514 Patent, -311 IPR, EX1004 at Cover
`‘759 Patent, -312 IPR, EX1004 at Cover
`
`Samsung/Dell, Exh. 1033, p. 8
`Samsung/Dell v. MYPAQ, IPR2022-00311
`
`

`

`Hwang Reference Overview
`
`“Hwang discloses a pulse-skipping power
`converter. Ex. 1006, codes (54), (57), ¶ 6.”
`
`“Hwang Figure 1 illustrates a two-stage
`power converter 100, including power factor
`correction (‘PFC’) stage 102, pulse width
`modulation (‘PWM’) stage 103, controller
`105, and optional linear converter 101. Ex.
`1006 ¶ 19, Fig. 1.”
`
`“Hwang describes the function of controller
`105, including sensing signals from load 104
`and causing PFC stage 102 and PWM stage
`103 to enter certain operational modes. Id. ¶
`21.”
`
`-311 IPR, Inst. Dec. (Paper 11) at 20-21
`See also, -312 IPR, Inst. Dec. (Paper 11) at 26-27
`
`‘514 Patent, -311 IPR, EX1006 at Cover
`‘759 Patent, -312 IPR, EX1006 at Cover
`
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`9
`
`Samsung/Dell, Exh. 1033, p. 9
`Samsung/Dell v. MYPAQ, IPR2022-00311
`
`

`

`Agenda
`
`Brief Overview
`
`•
`
`•
`
`‘514 and ‘759 Patents
`
`Prior Art Grounds
`
`Common Issues -311 IPR & -312 IPR
`
`•
`
`•
`
`•
`
`•
`
`•
`
`“system operational state of [a/said] load”
`
`“control said duty cycle”
`
`power converter “controller”
`
`“power system controller”
`
`“core state”
`
`-311 IPR Specific Issues (‘514 Patent)
`
`•
`
`•
`
`•
`
`•
`
`•
`
`“signal characterizing a power requirement of a processor system”
`
`“[enable/enabling] components of a processor system”
`
`“over a period of time”
`
`“upon startup”
`
`Motivation to Combine Hwang/Chagny
`
`-312 IPR Specific Issues (’759 Patent)
`
`•
`
`•
`
`•
`
`•
`
`•
`
`“power converter operational state”
`
`“power converter status”
`
`“a power system controller configured to receive a signal”
`
`“within a transition time”
`
`Markush Groups
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`10
`
`Samsung/Dell, Exh. 1033, p. 10
`Samsung/Dell v. MYPAQ, IPR2022-00311
`
`

`

`“system operational state of [a/said] load”
`
`Disputed Issue
`
`Patents and Claims
`
`“system operational state
`of [a/said] load”
`
`‘514 Patent, Independent Claim 1
`
`‘759 Patent, Independent Claims 1, 6, 16
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`11
`
`Samsung/Dell, Exh. 1033, p. 11
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`
`

`

`“system operational state of [a/said] load”
`
`U.S. Patent No. 8,477,514
`
`1[b]
`
`a power converter controller configured to receive a signal from said load
`indicating a system operational state of said load and control an internal
`operating characteristic of said power converter as a function of said signal.
`
`‘514 Patent, -311 IPR, EX1001 at 28:2-8 (Claim 1)
`
`U.S. Patent No. 7,675,759
`
`1[pre]
`
`A power converter coupled to a power system controller configured to
`receive a signal indicating a system operational state of a load coupled
`thereto, comprising:
`
`‘759 Patent, -312 IPR, EX1001 at 22:38-54 (Claim 1)
`
`6[a]
`
`a power system controller configured to receive a signal indicating
`a system operational state of said load and to select a power converter
`operational state as a function thereof; and
`
`‘759 Patent, -312 IPR, EX1001 at 23:7-24 (Claim 6)
`
`16[a]
`
`receiving a signal indicating a system operational state of said load;
`
`‘759 Patent, -312 IPR, EX1001 at 24:18-33 (Claim 16)
`
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`12
`
`Samsung/Dell, Exh. 1033, p. 12
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`
`

`

`“system operational state of [a/said] load”
`
`Specification – Background Section
`
`“Power conversion systems of the prior art have only partially responded to such
`system operational state considerations in the optimization of operating efficiency,
`particularly at a system level. For example, the advanced configuration and power
`interface (“ACPI”) specification is an open industry standard initially produced in
`December 1996 that describes ‘P-states’ and ‘C-states’ of a processor … .”
`
`‘514 Patent, -311 IPR, EX1001 at 5:19-26
`‘759 Patent, -312 IPR, EX1001 at 3:65-4:5
`-311 IPR: Pet. (Paper 3) at 18 n.1; Reply Br. (Paper 22) at 3-4, 6; -312 IPR: Reply Br. (Paper 22) at 3-4, 9
`
`“Although these state indicators have been used to substantially reduce the energy
`requirement of a digital system at the system level, particularly the power level during an
`idling state, corresponding states have not been described for elements of the power system
`as it responds to the various operational levels of the load … . Accordingly, opportunities
`for further improvement in power converter operational efficiency have not been realized.”
`
`‘514 Patent, -311 IPR, EX1001 at 5:60-6:2
`‘759 Patent, -312 IPR, EX1001 at 4:40-49
`-311 IPR: POR (Paper 17) at 21; Reply Br. (Paper 22) at 6; -312 IPR: POR (Paper 17) at 48
`
`“Accordingly, what is needed in the art is a controller for a power converter and power
`system that adaptively improves power conversion efficiency of a power converter in
`response to … system operational state of a load coupled to the power system.”
`
`‘514 Patent, -311 IPR, EX1001 at 6:36-44
`‘759 Patent, -312 IPR, EX1001 at 5:18-26
`-311 IPR: Pet. (Paper 3) at 4-5; Reply Br. (Paper 22) at 6; -312 IPR: Pet. (Paper 3) at 4
`
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`
`13
`
`Samsung/Dell, Exh. 1033, p. 13
`Samsung/Dell v. MYPAQ, IPR2022-00311
`
`

`

`“system operational state of [a/said] load”
`
`Specification – Exemplary System Operational State
`
`“The power converter … provides power to a system (not shown) such as a microprocessor
`coupled to an output thereof.”
`
`‘514 Patent, -311 IPR, EX1001 at 10:12-15
`‘759 Patent, -312 IPR, EX1001 at 8:14-16
`-311 IPR, Inst. Dec. (Paper 11) at 16 (quoting ‘514 Patent at 10:12-15)
`
`“A transition to the fifth power converter operational state PCop — state5 (‘idle’) may be
`enabled upon … receipt of a system operational state such as a processor core state with a
`value greater than or equal to one.”
`
`‘514 Patent, -311 IPR, EX1001 at 26:7-12
`‘759 Patent, -312 IPR, EX1001 at 21:21-25
`-311 IPR, Reply Br. (Paper 22) at 3 & n.4; -312 IPR, Reply Br. (Paper 22) at 3-4 & n.4
`
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`
`14
`
`Samsung/Dell, Exh. 1033, p. 14
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`
`

`

`“system operational state of [a/said] load”
`
`Chagny discloses “system operational state of [a/said] load”
`
`“[S]oftware program 296 …
`monitors the processor loading.
`Based on the processor 292
`loading and/or the forecasted
`values, the software program 296
`generates the activity input 202
`indicative of levels of activity of
`the processor 292.”
`
`Chagny, EX1004, 4:35-43
`-311 IPR, Pet. (Paper 3) at 17-18
`-312 IPR, Pet. (Paper 3) at 41-42
`
`Chagny, EX1004, Fig. 2A (annotated)
`-311 IPR, Pet. (Paper 3) at 17
`See also -312 IPR, Pet. (Paper 3) at 22
`
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`
`15
`
`Samsung/Dell, Exh. 1033, p. 15
`Samsung/Dell v. MYPAQ, IPR2022-00311
`
`

`

`“system operational state of [a/said] load”
`
`’514 Patent
`
`Chagny
`
`“Power conversion systems of the prior art have only
`partially responded to such system operational state
`considerations in the optimization of operating
`efficiency, particularly at a system level. For example,
`the advanced configuration and power interface
`(“ACPI”) specification is an open industry standard
`initially produced in December 1996 that describes
`‘P-states’ and ‘C-states’ of a processor employed in a
`digital system … .”
`
`‘514 Patent at 5:19-26; ‘759 Patent at 3:65-4:5
`
`“Another processor state indicator, the core state (“C-
`state”), also under software operating system control,
`affects its level of power consumption … . The
`highest processor C-state, C0, describes a processor at
`its full operational level. Lower C-state levels, C1,
`C2, …, C4 describe various levels of a processor
`sleep state. … The various sleep levels are achieved
`by halting instruction execution, gating internal
`clocks, … and disabling ports that respond to certain
`levels of interrupts.”
`‘514 Patent at 5:19-26; ‘759 Patent, at 3:65-4:5
`
`-311 IPR, Pet. (Paper 3) at 18 n.1; Reply Br. (Paper 22) at 3-4, 6;
`-312 IPR, Reply Br. (Paper 22) at 3-4, 9
`
`“The processor 292 loading, usage or activity level
`will vary depending on the number of instructions
`executed within a predefined time interval.”
`
`Chagny, EX1004 at 4:18-20
`
`“[T]he software program 296 defines
`UREG_B1 272 and UREG_B2 274, which are 2 bits
`in a register of the processor 292 to control the
`maximum number of instructions executed per clock
`cycle. The demand for power required by the
`processor 292 is advantageously controlled by
`limiting the number of instructions executed for a
`predefined time period.”
`
`Chagny, EX1004 at 5:62-64
`
`-311 IPR, Pet. (Paper 3) at 18 n.1
`(comparing ‘514 Patent (EX1001) and Chagny (EX1004))
`
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`
`16
`
`Samsung/Dell, Exh. 1033, p. 16
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`
`

`

`“system operational state of [a/said] load”
`
`PO’s position regarding a ‘particular context’
`
`“PO … argues that a system operational state must indicate a ‘particular context’ beyond just
`the ‘current or future operational state of the load.”
`
`“PO adds that the system operational state is ‘driven by various factors, including external
`requirements, and is ultimately dependent on the context in which the system is being utilized.”
`
`-311 IPR, Reply Br. (Paper 22) at 2 (quoting POR (Paper 17) at 20, 21-22)
`see also -312 IPR, Reply Br. (Paper 22) at 2 (quoting POR (Paper 17) at 20, 21)
`
`“[I]n related district court cases, PO proposed ‘system operational state of [a/said] load’ should be
`construed to mean ‘operational condition of the load’ with its only proposed caveat being that the
`operational condition of the load be ‘more than just the present output voltage of the power converter”
`that powers the load. EX2028, 2.’”
`
`-311 IPR, Reply Br. (Paper 22) at 3
`see also -312 IPR, Reply Br. (Paper 22) at 3
`
`“PO’s requirement of a ‘particular context’ finds no support in the claims or the specification.”
`
`-311 IPR, Reply Br. (Paper 22) at 2
`see also -312 IPR, Reply Br. (Paper 22) at 2
`
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`
`17
`
`Samsung/Dell, Exh. 1033, p. 17
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`
`

`

`“system operational state of [a/said] load”
`
`PO’s position contradicts the plain language of the claims
`
`“The plain language dictates that the ‘system operational state’ is a state ‘of said load.’”
`
`-311 IPR, Reply Br. (Paper 22) at 3; -312 IPR, Reply Br. (Paper 22) at 3
`
`1[b]
`
`(’514)
`
`a power converter controller configured to receive a signal from said load
`indicating a system operational state of said load and control an internal
`operating characteristic of said power converter as a function of said signal.
`
`‘514 Patent, -00311 IPR, EX1001 at 28:2-8 (Claim 1)
`
`1[pre]
`
`(’759)
`
`A power converter coupled to a power system controller configured to
`receive a signal indicating a system operational state of a load coupled
`thereto, comprising:
`
`‘759 Patent, -00312 IPR, EX1001 at 22:38-54 (Claim 1)
`
`6[a]
`
`(’759)
`
`16[a]
`
`(’759)
`
`a power system controller configured to receive a signal indicating
`a system operational state of said load and to select a power converter
`operational state as a function thereof; and
`
`‘759 Patent, -312 IPR, EX1001 at 23:7-24 (Claim 6)
`
`receiving a signal indicating a system operational state of said load;
`
`‘759 Patent, -312 IPR, EX1001 at 24:18-33 (Claim 16)
`
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`
`18
`
`Samsung/Dell, Exh. 1033, p. 18
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`
`

`

`“system operational state of [a/said] load”
`
`PO’s “particular context” requirement excludes specification embodiments
`
`“Further examples indicating a system operational state include, without limitation, a signal providing a
`performance state or a core state of a processor such as a P-state or C-state, indicating, for example, that
`the system is operating from emergency power or battery reserve, that redundant hardware such as a
`redundant power converter may have been disabled, that the system is not providing a critical function
`such as during an off-hours timeframe, that the system is sustaining substantial thermal margins
`allowing selected fans to be disabled and/or the fan speed to be substantially reduced, that the system is
`about to transition to a higher level of system performance, or that a requirement for a specified
`holdover time can be relaxed. An example of a signal indicating a change in a system operational state
`is a signal indicating that a load current will change from a first current level to a second current level at
`or around a particular time.”
`
`‘514 Patent, -311 IPR, EX1001 at 9:11-27; ‘759 Patent, -312 IPR, EX1001 at 7:16-32
`-311 IPR, POR (Paper 17) at 19; Reply Br. (Paper 22) at 3 n.4, 4; -312 IPR, POR (Paper 17) at 19-20; Reply Br. (Paper 22) at 3 n.4, 4
`
`“The P-state, typically designated as P-states P0, P1, and P2, describes the ‘performance’ state (or,
`alternatively, the ‘power’ state) of the processor as high, medium, or low … .”
`
`“Another processor state indicator, the core state (“C-state”) … affects its level of power consumption
`from another perspective. The highest processor C-state, C0, describes a processor at its full operational
`level. Lower C-state levels, C1, C2, . . . , C4, describe various levels of a processor sleep state.”
`
`‘514 Patent, -311 IPR, EX1001 at 9:11-27; ‘759 Patent, -312 IPR, EX1001 at 7:16-32
`-311 IPR, POR (Paper 17) at 19; Reply Br. (Paper 22) at 3 n.4, 4; -312 IPR, POR (Paper 17) at 19-20; Reply Br. (Paper 22) at 3 n.4, 4
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
`
`19
`
`Samsung/Dell, Exh. 1033, p. 19
`Samsung/Dell v. MYPAQ, IPR2022-00311
`
`

`

`“system operational state of [a/said] load”
`
`PO’s “particular context” requirement excludes specification embodiments
`
`“Further examples indicating a system operational state include, without limitation, a signal providing a
`performance state or a core state of a processor such as a P-state or C-state, indicating, for example, that
`the system is operating from emergency power or battery reserve, that redundant hardware such as a
`redundant power converter may have been disabled, that the system is not providing a critical function
`such as during an off-hours timeframe, that the system is sustaining substantial thermal margins
`allowing selected fans to be disabled and/or the fan speed to be substantially reduced, that the system is
`about to transition to a higher level of system performance, or that a requirement for a specified
`holdover time can be relaxed. An example of a signal indicating a change in a system operational state
`is a signal indicating that a load current will change from a first current level to a second current level at
`or around a particular time.”
`
`‘514 Patent, -311 IPR, EX1001 at 9:11-27; ‘759 Patent, -312 IPR, EX1001 at 7:16-32
`-311 IPR, POR (Paper 17) at 19; Reply Br. (Paper 22) at 3 n.4, 4; -312 IPR, POR (Paper 17) at 19-20; Reply Br. (Paper 22) at 3 n.4, 4
`
`“A ‘load current’ is simply the electrical current drawn by a load. EX1029, 5.”
`
`“Thus, this example of a signal indicating a change in a system operational state is focused on a change in the
`load itself, specifically a change in the load current itself, not a particular context external to the load.”
`
`-311 IPR, EX1026 (Kiaei Declaration) at ¶10 (cited by Reply Br. (Paper 22) at 4)
`-312 IPR, EX1026 (Kiaei Declaration) at ¶10 (cited by Reply Br. (Paper 22) at 4-5)
`
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`

`

`“system operational state of [a/said] load”
`
`PO’s Position in POR verus Sur-Reply
`
`PO
`Response
`
`“Another system operational state is the core state, or C-states. Ex. 1001 [’514 Patent],
`5:44-46. ‘The highest processor C-state, C0, describes a processor at its full operational
`level.’ Ex. 1001 [’514 Patent], 5:46-48. ‘Lower C-state levels, C1, C2, . . . , C4, describe
`various levels of a processor sleep state.’ Ex. 1001 [’514 Patent], 5:48-49.”
`
`-311 IPR, POR (Paper 17) at 6-7
`See also -312 IPR, POR (Paper 17) at 7
`
`PO
`Sur-Reply
`
`“The ’514 Patent expressly distinguishes C-states from system operational states … .”
`
`-311 IPR, PO Sur-Reply (Paper 23) at 3
`See also -312 IPR, PO Sur-Reply (Paper 23) at 3
`
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`

`“system operational state of [a/said] load”
`
`PO’s “particular context” requirement excludes specification embodiments
`
`“Power conversion systems of the prior art have only partially responded to such system operational state
`considerations in the optimization of operating efficiency, particularly at a system level. For example, the
`advanced configuration and power interface (“ACPI”) specification is an open industry standard … that
`describes ‘P-states’ and ‘C-states’ of a processor employed in a digital system … .”
`
`‘514 Patent, -311 IPR, EX1001 at 5:19-26; ‘759 Patent, -312 IPR, EX1001 at 3:65-4:5
`-311 IPR: Pet. (Paper 3) at 18 n.1; Reply Br. (Paper 22) at 3-4, 6; -312 IPR: Reply Br. (Paper 22) at 3-4, 9
`
`“[W]hat is needed … is a controller for a power converter and power system that adaptively improves power conversion
`efficiency of a power converter in response to … system operational state of a load coupled to the power system.”
`
`‘514 Patent, -311 IPR, EX1001 at 6:36-44; ‘759 Patent, -312 IPR, EX1001 at 5:18-26
`-311 IPR: Pet. (Paper 3) at 4-5; Reply Br. (Paper 22) at 6; -312 IPR: Pet. (Paper 3) at 4
`
`“A transition to the fifth power converter operational state PCop — state5 (‘idle’) may be enabled upon …
`receipt of a system operational state such as a processor core state with a value greater than or equal to one.”
`
`‘514 Patent, -311 IPR, EX1001 at 26:7-12; ‘759 Patent, -312 IPR, EX1001 at 21:21-25
`-311 IPR, Reply Br. (Paper 22) at 3 & n.4; -312 IPR, Reply Br. (Paper 22) at 3-4 & n.4
`
`“[T]he specification does not distinguish ‘core states’ or ‘C-states’ from ‘system operational states.’ To the contrary, the
`’514 Patent describes processor ‘core states’ as examples of ‘system operational states.’ See EX1001, 26:10-11.”
`
`“What the ’514 Patent was attempting to distinguish was how conventional power converter controllers were purportedly
`not configured to respond to signals indicating the system operational state of the load connected to the power converter.
`See id., 5:19-22, 5:60-6:2, 6:36-44; EX1026,¶¶12-13. But, as described in the Petition, that feature was disclosed by the
`prior art.”
`
`-00311 IPR, Reply Br. (Paper 22) at 6
`
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`

`

`“system operational state of [a/said] load”
`
`Hwang discloses “system operational state of [a/said] load”
`
`“The load 104 may be a smart load in that
`it may instruct the controller 105 to enter
`a standby mode. For example, the load
`104 may include a microprocessor that
`may enter a standby mode during periods
`of low activity or non-use.”
`
`Hwang, EX1006, ¶[0031]
`
`“The controller 105 may sense a signal
`from the load 104 that indicates the level
`of power drawn by the load 104. A
`standby signal from the load 104 may
`instruct the controller 105 to enter
`standby mode. For example, where the
`load 104 is a microprocessor or
`controller, it may enter a standby or
`‘sleep’ mode during periods of low
`activity for power conservation.”
`
`Hwang, EX1006, ¶[0021]
`
`-311 IPR, Pet. (Paper 3) at 47-48
`-312 IPR, Pet. (Paper 3) at 66-67
`
`Hwang, EX1006, Fig. 1 (annotated)
`-311 IPR, Pet. (Paper 3) at 47
`
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`

`

`“system operational state of [a/said] load”
`
`PO’s position on “system operational state of [a/said] load” and
`“environmental parameter”
`
`“PO argues that Hwang’s standby signal indicates that the system is operating at a ‘reduced power level,’
`which in PO’s view would be consistent with one example of an ‘environmental parameter’ disclosed in the
`’514 Patent. POR, 43 (citing EX1001, 9:4-11).”
`
`-311 IPR, Reply Br. (Paper 22) at 7 (citing POR (Paper 17) at 43)
`See also -312 IPR, Reply Br. (Paper 22) at 10 (citing POR (Paper 17) at 59)
`
`“The parameters mentioned above are typically measured after the power converter(s) are
`implemented and/or after a signal is received from an external source representing an
`environmental parameter or a signal indicating a system operational state or a change in a
`system operational state.”
`
`‘514 Patent, -311 IPR, EX1001, 8:49-54 (cited by POR (Paper 17) at 43)
`‘759 Patent, -312 IPR, EX1001, 7:3-8 (cited by POR (Paper 17) at 59-60)
`
`“… a signal from an external source representing an environmental parameter or system
`operational state of a load coupled to the power system.”
`
`‘514 Patent, -311 IPR, EX1001, 6:42-44 (cited by POR (Paper 17) at 43)
`‘759 Patent, -312 IPR, EX1001, 5:24-26 (cited by POR (Paper 17) at 60)
`
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`
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`

`

`“system operational state of [a/said] load”
`
`Hwang discloses “system operational state of [a/said] load”
`
`“[T]he output voltage of Hwang’s power
`converter is constant. EX1006, [0021],
`[0030].”
`
`“Because power equals voltage times
`current (P = V*I) (EX1030, 12), in
`scenarios like Hwang … a signal
`indicating a change in the load’s power
`demand would also be a signal indicating
`a change in the load’s current demand.
`EX1026,¶16.”
`
`“The ’514 Patent refers to such a signal
`… as a signal indicating a system
`operational state of the load.”
`
`-311 IPR, Reply Br. (Paper 22) at 8
`
`Hwang, EX1006, Fig. 1 (annotated)
`-311 IPR, Pet. (Paper 3) at 47
`
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`

`“system operational state of [a/said] load”
`
`Hirst discloses “system operational state of [a/said] load”
`(-312 IPR)
`
`“Commands from a print engine controller
`select a first switching frequency for the
`power supply when the printer is in a
`normal mode of operation and select a
`second switching frequency for the power
`supply when the printer is in a standby
`mode of operation.”
`
`Hirst, EX1003, 3:17-23
`-312 IPR, Pet. (Paper 3) at 15
`
`“In normal operation, the power
`consumption monitor 22 detects normal
`power consumption and provides control
`signals to maintain normal power supply
`functions. When, however, no input data
`are present at the data input port 14 and the
`print engine 20 is not active, power
`consumption decreases. When the power
`consumption monitor 22 detects reduced
`power consumption, signals from the
`power consumption monitor 22 place the
`multiple frequency switching power
`supply 12 in a standby mode.”
`
`Hirst, EX1003, 4:32-41
`-312 IPR, Pet. (Paper 3) at 15
`26
`
`Hirst, EX1003, Fig. 1 (annotated)
`-312 IPR, Pet. (Paper 3) at 15
`
`DEMONSTRATIVE EXHIBIT – NOT EVIDENCE
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`

`

`“system operational state of [a/said] load”
`
`Findings regarding Hirst in the Institution Decision
`
`“Patent Owner argues that Hirst does not disclose that the power system controller
`receives ‘a signal indicating a system operational state of a load,’ as recited in claim
`1, because power monitor 22 ‘monitors the output of the power supply, not the
`system operational state of the load.’ On this record, we disagree with Patent
`Owner’s argument.”
`
`-312 IPR, Inst. Dec. (Paper 11) at 13
`
`“Hirst explains that during ‘normal operation’ of the load (e.g., print engine 20),
`power monitor 22 ‘detects normal power consumption’ but that, when ‘print engine
`20 is not active,’ power monitor 22 ‘detects reduced power consumption.’ Ex. 1003,
`4:33–41. Thus, on this record, we are persuaded by Petitioner’s assertion that Hirst’s
`power monitor 22 determines an operational state (normal or standby) of a load
`(e.g., print engine 20) based on the power consumption by the load. See Pet. 15.”
`
`-312 IPR, Inst. Dec. (Paper 11) at 13
`
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`
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`

`“system operational state of [a/said] load”
`
`’759 Patent
`
`Hirst
`
`“An example of a signal indicating a
`change in a system operational state is a
`signal indicating that a load current will
`change from a first current level to a second
`current level at or around a particular time.”
`
`‘759 Patent, -312 IPR, EX1001 at 7:28-32
`-312 IPR, Reply Br. (Paper 22) at 4
`
`“In normal operation, the power consumption
`monitor 22 detects normal power consumption
`and provides control signals to maintain normal
`power supply functions. … When the power
`consumption monitor 22 detects reduced power
`consumption, signals from the power consumption
`monitor 22 place the multiple frequency switching
`power supply 12 in a standby mode.”
`
`Hirst, EX1003, 4:32-41
`-312 IPR, Pet. (Paper 3) at 15
`
`“[T]he power consumed by the load in Hirst is drawn
`from the power converter output in the same manner as
`a ‘load current’ described in the ’759 Patent would be
`drawn from a power converter output. EX1026,¶12.
`
`“Thus, there is no basis for distinguishing the signal
`from Hirst’s power monitor based on the power
`monitor’s location.”
`
`-312 IPR, Reply Br. (Paper 22) at 6-7
`
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`

`

`Agenda
`
`Brief Overview
`
`•
`
`•
`
`‘514 and ‘759 Patents
`
`Prior Art Grounds
`
`Common Issues -311 IPR & -312 IPR
`
`•
`
`•
`
`•
`
`•
`
`•
`
`“system operational state of [a/said] load”
`
`“control said duty cycle”
`
`power converter “controller”
`
`“power system controller”
`
`“core state”
`
`-311 IPR Specific Issues (‘514 Patent)
`
`•
`
`•
`
`•
`
`•
`
`•
`
`“signal characterizing a power requirement of a processor system”
`
`“[enable/enabling] components of a processor system”
`
`“over a period of time”
`
`“upon startup”
`
`Motivation to Combine Hwang/Chagny
`
`-312 IPR Specific Issues (’759 Patent)
`
`•
`
`•
`
`•
`
`•
`
`•
`
`“power converter operational state”
`
`“power converter status”
`
`“a power system controller configured to receive a signal”
`
`“within a transition time”
`
`Markush Groups
`
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`

`“control said duty cycle”
`
`Disputed Issue
`
`Patents and Claims
`
`“control said duty cycle” …
`“as a function of …” and
`“in accordance with…”
`
`‘514 Patent, Claims 2, 7, *12, *17
`
`‘759 Patent, Independent Claims 1, 6, *16
`
`* Some claims have slightly different language, but the issues disputed in papers are the same.
`
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`

`“control said duty cycle”
`
`U.S. Patent No. 8,477,514
`
`2 & 7
`
`“to provide another signal to control said duty cycle of said power switch as
`a function of said output characteristic and in accordance with said signal.”
`
`12
`
`17
`
`“to control said duty cycle of said power switch dependent on said output
`characteristic and in accordance with said power level.”
`
`“controlling said duty cycle of said power switch dependent on said output
`characteristic and in accordance with said power level.”
`
`‘514 Patent, -311 IPR, EX1001 at 28:9-13 (Claim 2), 28:42-46 (Claim 7), 29:8-14 (Claim 12), 29:10-17 (Claim 17)
`
`U.S. Patent No. 7,675,759
`
`1[c] &
`6[d]
`
`“provide a signal to control said duty cycle of said power switch as a
`function of said output characteristic and in accordance with said command”
`
`16[d]
`
`“providing a signal to control a duty cycle of a power switch of said power
`converter as a function of an output characteristic thereof and in accordance
`with said power converter operational state”
`
`‘759