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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`SAMSUNG ELECTRONICS CO., LTD AND DELL TECHNOLOGIES INC.
`
`Petitioners
`
`v.
`
`MYPAQ HOLDINGS LTD.
`
`Patent Owner
`
`_____________________
`
`Case No. IPR2022-00311
`
`U.S. Patent No. 8,477,514
`
`_______________________
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`PATENT OWNER SUR-REPLY
`
`_______________________
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`Case IPR2022-00311
`U.S. Pat. No. 8,477,514
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`TABLE OF CONTENTS
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`Page
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`I.
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`INTRODUCTION ....................................................................................... 1
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`II. CLAIM 1 ....................................................................................................... 1
`
`A.
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`“System Operational State of Said Load” ...................................... 1
`
`B.
`
`Chagny’s “activity input 202” is not a signal “indicating a
`system operational state of said load” ............................................. 6
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`C. Hwang’s “standby signal” is not a “signal indicating a
`system operational state of said load” ............................................. 7
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`III. CLAIM 6 ....................................................................................................... 9
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`A. Chagny’s “activity input 202” is not a “signal
`characterizing a power requirement” ............................................. 9
`
`B. Hwang’s “standby signal” is not a “signal characterizing a
`power requirement of a processor system” .................................... 12
`
`IV. CLAIMS 11 AND 16 .................................................................................... 12
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`A. Chagny and Hwang do not disclose “enabling operation of
`components of a processor system to establish a state of
`power drain thereof” ......................................................................... 12
`
`1.
`
`2.
`
`Chagny ..................................................................................... 12
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`Hwang ...................................................................................... 14
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`B. Hwang does not disclose “sensing a power level of said state
`of power drain in response to said signal” ...................................... 15
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`V.
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`“POWER SYSTEM CONTROLLER” ..................................................... 15
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`A. Chagny’s software program 296 is not a “power system
`controller” .......................................................................................... 15
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`B. Hwang’s microprocessor is not a “power system controller” ....... 16
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`VI. DEPENDENT CLAIMS 2, 7, 12, 17 .......................................................... 17
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`A. Chagny does not disclose “in accordance with said
`[signal/power level]” .......................................................................... 17
`
`B.
`
`Petitioners Mischaracterize Hwang’s Duty Cycle .......................... 19
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`VII. DEPENDENT CLAIMS 3, 8, 14, 19 .......................................................... 20
`
`A.
`
`“Over a period of time” .................................................................... 20
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`VIII. DEPENDENT CLAIMS 4 AND 9 .............................................................. 22
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`A. Chagny and Hwang do not disclose core states .............................. 22
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`IX. DEPENDENT CLAIMS 13 AND 18 .......................................................... 24
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`A. Chagny and Hwang do not disclose “upon startup” ...................... 24
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`X. GROUND 2B (Hwang and Chagny) .......................................................... 25
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`XI. CONCLUSION ............................................................................................ 26
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`TABLE OF AUTHORITIES
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`Page(s)
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`Cases
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`Arendi S.A.R.L. v. Apple Inc.,
`832 F.3d 1355 (Fed. Cir. 2016) .........................................................................25
`
`Regulations
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`37 C.F.R. § 42.104 ...................................................................................................10
`
`Patent Procedures
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`Consolidated Trial Practice Guide (Nov. 2019) ........................................................ 8
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`EXHIBIT LIST
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`2001 Defendants’ Joint Preliminary Invalidity Contentions, served on January
`12, 2022 in MyPAQ Holdings, Ltd. v. Samsung Electronics Co., Ltd. et
`al., 6:21-CV-398-ADA
`2002 Complaint in MyPAQ Holdings, Ltd. v. Samsung Electronics Co., Ltd. et
`al., 6:21-CV-398-ADA (W.D. Tex.)
`2003 Complaint in MyPAQ Holdings, Ltd. v. Samsung Electronics Co., Ltd. et
`al., 6:21-CV-398-ADA (W.D. Tex.)
`2004 Albright Says He’ll Very Rarely Put Cases On Hold For PTAB, Ryan
`Davis, Law360, May 11, 2021, available at
`https://www.law360.com/articles/1381597/print?section=ip; last accessed
`February 8, 2022.
`2005 Second Amended Standing Order Regarding Motions for Inter-District
`Transfer, Judge Albright (W.D. Tex. Aug. 18, 2021)
`2006 Order Granting Early Discovery in MyPAQ Holdings, Ltd. v. Dell
`Technologies, Inc. and Dell Inc., 6:21-cv-00933-ADA, Dkt. No. 42
`(February 24, 2022)
`2007 Standing Order Governing Proceedings—Patent Cases, Eastern District
`of Texas, Waco Division (Mar. 7, 2022)
`2008 Defendants’ First Venue-Related Requests for Production (Nos. 1-6) in
`MyPAQ Holdings, Ltd. v. Dell Technologies, Inc. and Dell Inc., 6:21-cv-
`00933-ADA (March 15, 2022)
`2009 Defendants’ First Set of Venue-Related Interrogatories (Nos. 1-4) in
`MyPAQ Holdings, Ltd. v. Dell Technologies, Inc. and Dell Inc., 6:21-cv-
`00933-ADA (March 15, 2022)
`2010 Plaintiff’s Notice of Deposition of Merle Wood in MyPAQ Holdings, Ltd.
`v. Dell Technologies, Inc. and Dell Inc., 6:21-cv-00933-ADA, (February
`16, 2022)
`2011 Plaintiff’s Notice of Deposition of Andy Sultenfuss in MyPAQ Holdings,
`Ltd. v. Dell Technologies, Inc. and Dell Inc., 6:21-cv-00933-ADA
`(February 16, 2022)
`2012 Plaintiff’s Notice of Deposition of Dell Venue Witnesses in MyPAQ
`Holdings, Ltd. v. Dell Technologies, Inc. and Dell Inc., 6:21-cv-00933-
`ADA (March 11, 2022)
`2013 Plaintiff’s First Notice of Deposition of Samsung Venue Witnesses in
`MyPAQ Holdings, Ltd. v. Dell Technologies, Inc. and Dell Inc., 6:21-cv-
`00933-ADA (February 21, 2022)
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`2014 Plaintiff’s Second Notice of Deposition of Samsung Venue Witnesses in
`MyPAQ Holdings, Ltd. v. Dell Technologies, Inc. and Dell Inc., 6:21-cv-
`00933-ADA (March 16, 2022)
`2015 Order appointing technical advisor in MyPAQ Holdings, Ltd. v. Dell
`Technologies, Inc. and Dell Inc., 6:21-cv-00933-ADA (April 21, 2022)
`2016 Linkedin profile for Joshua Yi, available at
`https://www.linkedin.com/in/yijoshua/, last accessed April 22, 2022
`2017 Personal webpage for Joshua Yi, available at www-
`mount.ece.umn.edu/~jjyi/, last accessed April 22, 2022
`2018 Declaration of Dr. Frank Ferrese
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`2019 CV of Dr. Frank Ferrese
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`2020 U.S. Pat. No., 6,344,986 (Jain)
`
`2021 U.S. Pat. App. No. 2007/0222463 (Qahouq)
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`2022 Advanced Configuration and Power Interface specification, Dec. 1996
`(“ACPI”)
`2023 Alon Naveh, et al., “Power and Thermal Management in the Intel® Core
`Duo™ Processor,” Intel Technology Journal, May 15, 2006 (“Naveh”)
`2024 U.S. Pat. No. 6,344,986 (Jain)
`
`2025 U.S. Pat. App. No. 2007/0222463 (Qahouq)
`
`2026
`
`John Crowe, Barrie Hayes-Gill, Introduction to Digital Electronics, 1998
`
`2027 Harry Henderson, “Encyclopedia of Computer Science and Technology,
`4th Edition (2021).
`2028 May 2, 2022 Preliminary Claim Construction email in MyPAQ v.
`Samsung/Dell, Nos. 6:21-CV-00398, 6:22-CV-00933 (W.D. Tex.)
`(“Preliminary Constructions”)
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`I.
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`INTRODUCTION
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`The ’514 Patent is directed to adaptive power system controllers that control
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`system power not based on the instantaneous activity level of a given processor,
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`but instead based on the current and forecasted power required of all elements of
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`the system, and taking into account specific states and the context the system is
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`being operated in. See, e.g., EX1001 [’514 Patent], Title, Abstract, 2:32-38.
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`Petitioners’ arguments disregard these teachings and, as a result, repeatedly stretch
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`Hwang and Chagny to cover claim limitations that they do not disclose.
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`Accordingly, Petitioners fail to establish by a preponderance of the evidence that
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`claims 1-20 are unpatentable.
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`II. CLAIM 1
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`A.
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`“System Operational State of Said Load”
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`Petitioners argue that there “is no basis for injecting a requirement of a
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`particular context external to the load as argued by PO.” Reply, 3. Petitioners’
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`argument is misplaced.
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`First, the claim recites the “system operational state” of the entire load, not
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`just the current state of certain components of the load. EX1001 [’514 Patent],
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`Claim 1; POR, 18, EX2018 [Ferrese Decl.], ¶52.
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`Second the “system operational state” of the load refers to a particular
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`context in which the load is being operated. POR, 18-21. Whether a processor in
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`the load at a particular point in time is executing instructions does not reflect the
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`system operational state of the load. POR, 19-20. For example, a processor may be
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`busy at a particular instant yet the load itself may still be “sustaining substantial
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`thermal margins allowing selected fans to be disabled and/or the fan speed to be
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`substantially reduced.” POR, 19, EX1001 [’514 Patent], 9:14-27. See also EX1001
`
`[’514 Patent], 5:8-17. The point is that the system operational state is a state that
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`accounts for considerations beyond the instant activity level of a particular
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`processor.
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`Third, the POR only argues that “external requirements” are one factor that
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`impacts the system operational state. POR, 21. The POR is not limiting the system
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`operational state to only external factors.
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`Petitioners further contend PO’s district court construction is inconsistent
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`with the POR. Reply, 3. This is incorrect. The district court construction sought to
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`clarify that the system operational state was more than just the instantaneous
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`measure of a single metric relating to one component of the larger system (there,
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`the “present output voltage of the power converter.”). EX2028, 2. The issue here
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`(instant activity level of prior art processors) is different, but the point being made
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`is similar—“system operational state” refers to the “system as a whole” and not
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`just a single component at a single instant in time. POR, 18.
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`Petitioners argue PO is excluding “processor core states” from being
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`“system operational states.” Reply, 3-4. While C-states may be one consideration
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`for setting system operational states, they do not indicate system operational states.
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`The ’514 Patent expressly distinguishes C-states from system operational states,
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`stating that “corresponding states have not been described for elements of the
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`power system as it responds to the various operational levels of the load…”
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`EX1001 [’514 Patent], 5:60-67; POR, 21. The ’514 Patent, discussing C-states,
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`states that “[p]ower conversion systems of the prior art have only partially
`
`responded to such system operational state considerations.” EX1001 [’514 Patent],
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`5:19-22; POR, 20-21. Thus, the ’514 Patent discloses that C-states “only partially
`
`respond[ ]” to system operational state considerations. Id. While C-states may be
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`one consideration for setting system operational states, they do not indicate system
`
`operational states. Id.
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`Petitioners cite the ’514 Patent at 26:10-11 as “describ[ing] ‘system
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`operational states’ as including core states or C-states with no reference to a
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`particular context external to the processor (i.e., the load).” Reply, 3 n.4.
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`Petitioners are incorrect. The context of the paragraph cited by Petitioners is the
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`transition of power converter operational state based upon both power converter
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`status and system operational state. In this case, the system operational state is not
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`the C-state itself, rather, it is, “a processor core state with a value greater than or
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`equal to one.” Examples of system operational states given in the ’514 patent
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`include, “providing a performance state or a core state of a processor such as a P-
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`state or C-state, indicating, for example that the system is operating from
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`emergency power or battery reserve,” EX1001 [’514 Patent], 9:13-15. In the
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`context of this example, involving a failed power converter and a C-state greater
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`than or equal to one, the implication is that the power converter is no longer
`
`functional and the C-state is indicative of the processor being in one of the sleep
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`states so it is still energized, but it is receiving power from an alternate source. In
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`this case, the transition to power converter operational state five is warranted.
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`Petitioners fail to consider the context in which the C-state is being used in this
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`case.
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`Petitioners, citing the ’514 Patent, 9:23-27, contend “the ’514 Patent
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`discloses ‘a signal indicating that a load current will change’ as an ‘example of a
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`signal indicating a change in a system operational state’” and that “[t]his example
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`is again focused on the load itself, not a particular context external to the load.”
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`Reply, 4. While the instantaneous measure of the load current is not an example of
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`system operational state, the fact that the load current will change is a prediction
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`that it is a function of overall system operational context and a change in the
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`operating point or operating conditions of the load.
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`Finally, Petitioners’ footnote argues that Dr. Ferrese was not a POSITA on
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`December 1, 2006. Reply, 2, n.2. This is incorrect. By December 1, 2006, Dr.
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`Ferrese had a Master’s in Computer Engineering and Bachelor’s in Electrical
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`Engineering (Ex. 2019, 1) and fifteen years’ experience as an electrical engineer,
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`including work on “power systems” and “power electronic devices” as Lead
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`Engineer at the Naval Surface Warfare Center (id., EX2018 [Ferrese Decl.], ¶12).
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`Thus, Dr. Ferrese qualified as a POSITA by December 1, 2006 under Petitioners’
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`definition of the term. Pet., 9.
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`Petitioners argue that Dr. Ferrese’s “first experience with switching power
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`converters was not until around 2010.” But experience with “switching power
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`converters” is not part of Petitioners’ definition of the level of ordinary skill. Pet.,
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`9. Further, the term “system operational state” is a concept from systems
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`engineering, a field Dr. Ferrese worked in for many years prior to 2006 (EX2019
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`[Ferrese CV], 2-3) and is not specific to the application or design of power
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`converters.
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`Further still, Petitioners’ footnote is irrelevant. Petitioners does not contest
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`the fact that Dr. Ferrese is extraordinarily skilled in the art.
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`B. Chagny’s “activity input 202” is not a signal “indicating a system
`operational state of said load”
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`As discussed in the POR, Chagny’s activity input 202 indicates the level of
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`activity of the processor at a particular moment in time. POR, 18. The activity level
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`of a processor is not indicative of the state of the load because processors may have
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`different activity levels in a particular system operational state or the same activity
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`level in different operational states. POR, 18-23.
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`Petitioners argue that “[s]imilar to [core states] in the ’514 Patent, the
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`activity level of Chagny’s processor 292 depends ‘on the number of instructions
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`executed within a predefined time interval’ (EX1004, 4:18-20), and thus reflects
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`the ‘demand for power required by the processor 292.’” Reply, 5-6. First, core-
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`states are not system operational states. Supra §II.A; EX1001 [’514 Patent], 5:19-
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`43, 5:60-6:2, 6:14-20.
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`Second, the “level of power consumption” isn’t indicative of a system
`
`operational state. Low power modes are the type of “state indicators” that the ’514
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`Patent criticizes as failing to describe “elements of the power system as it responds
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`to the various operational levels of the load.” EX1001 [’514 Patent], 5:60-67.
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`Processor low power modes are not indicative of the state of the system as a whole.
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`EX2018 [Ferrese Decl.], ¶¶57-58. Dr. Ferrese gives a number of examples of
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`system operational states that are independent of whether the processor activity
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`level is low or the system is in a low power mode, including an indication “that the
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`system is operating from emergency power or battery reserve” (Id., ¶52), “that the
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`system is sustaining substantial thermal margins” (Id), and levels of criticality at
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`different times of the day (Id., ¶¶53, EX1001 [‘514 Patent] 5:8–5:17, 9:14-27.).
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`Petitioners do not rebut any of these examples. Accordingly, Chagny’s activity
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`input 202 is not a system operational state.
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`C. Hwang’s “standby signal” is not a “signal indicating a system
`operational state of said load”
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`Petitioners contend Hwang’s “standby signal” is a “signal indicating system
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`operational state of said load.” Reply, 6. As discussed above, low power modes
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`like “sleep” modes do not indicate a system operational state. See supra, §II.B;
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`EX2018 [Ferrese Decl.], ¶101. Further, the ’514 patent identifies that examples of
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`“environmental parameters” include “an indication that a particular portion of the
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`load … is operating at a reduced power level.” POR, 43, EX1001 [’514 Patent],
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`9:4-11. Hwang’s standby signal, which is used “during periods of low activity”
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`(EX1004, ¶[0021]), is “operating at a reduced power level” and is therefore an
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`“environmental parameter”, not a system operational state. POR, 42, EX2018
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`[Ferrese Decl.], ¶¶102-103.
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`Petitioners argue that Hwang’s standby signal is a system operational state
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`because “core states” are “system operational states” and that “core states”
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`“describe various levels of a processor sleep state.” Reply, 8 (quoting EX1001,
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`5:19-27, 5:44-49). This is incorrect. First, as discussed above, the ’514 Patent is
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`clear that core states are not system operational states. Supra, §II.A
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`Second, the ’514 Patent discloses the “core state (or ‘C-state’)” is a
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`parameter that is described in the ACPI specification. EX1001 [’514 Patent], 5:22-
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`27; 5:44-45. Thus, C-states are specific parameters defined in the ACPI
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`specification. Hwang does not use the term core state (or C-state) and has nothing
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`to do with the ACPI specification.
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`Petitioners argue that “in scenarios like Hwang with a constant output
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`voltage powering the load, a signal indicating a change in the load’s power demand
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`would also be a signal indicating a change in the load’s current demand” and that
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`such signals indicate the system operational state of the load. Reply, 8. This is a
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`new argument that was not made in the Petition and should not be considered by
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`the Board. See Consolidated Trial Practice Guide (Nov. 2019), 73 (“Petitioner may
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`not submit new evidence or argument in reply that it could have presented earlier,
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`e.g., to make out a prima facie case of unpatentability.”). PO does not have a
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`chance at this stage to provide technical opinions from its expert or additional
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`evidence on Petitioners’ new argument, underscoring the prejudice to PO.
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`Further, Petitioners do not identify what signal from Hwang Petitioners’ new
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`argument relies upon. Reply, 8, EX1026 [Kiaei Reply Decl.], ¶16. Hwang ¶[0021]
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`does mention “a signal from the load 104 that indicates the level of the power
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`drawn by the load 104” (id.) but that is different than the signal Petitioners
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`reference in the ’514 Patent, which indicates “that a load current will change from
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`a first current level to a second current level at or around a particular time.”
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`EX1001 [’514 Patent], 9:23-26. Even if the level of power drawn by the load
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`directly correlates to current in Hwang (which Petitioners have not established),
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`the signal does not indicate a change in current levels or that the change will occur
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`at a particular time as required by the ’514 Patent.
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`III. CLAIM 6
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`A. Chagny’s “activity input 202” is not a “signal characterizing a
`power requirement”
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`Chagny’s activity input 202—which indicates the activity level of the
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`processor—is not a signal characterizing a power requirement because it doesn’t
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`characterize any particular power requirement. POR, 24. The activity level of the
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`processor is simply the measure of the number of instructions on the processor
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`over a given period of time. Id. It does not characterize how much power is
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`needed by the system or characterize a requirement in general. Id., EX2018
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`[Ferrese Decl.], ¶60.
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`Petitioners present a new claim construction for the term “characterizing,”
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`arguing that the POR’s use of the term “tell” is “an improperly narrow
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`interpretation.” Reply, 9. First, Petitioners are not permitted to propose new
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`constructions in its Reply. 37 C.F.R. § 42.104(b)(3). Supra, §II.C.
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`Second, the Petition points to Chagny’s “activity input 202” and argues that
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`it meets this limitation because Chagny teaches “the ‘demand for power by the
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`processor 292’ depends on the activity level—i.e., the ‘number of instructions
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`executed per clock cycle.’” Pet., 25. Thus, the Petition argues that Chagny’s
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`activity input 202 indicates (or tells) the processor’s demand for power. See also
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`Reply, 11. PO is interpreting the claim in the same manner that the Petition did.
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`Third, the POR’s “example of a power requirement” as a “signal indicating
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`the processor system needs a certain level of power” was not limiting and its
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`discussion was specific to the Petition’s arguments regarding Chagny. POR, 24.
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`Thus, Petitioners’ new construction is a strawman and its footnote argument that
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`PO’s expert was “backtracking” mischaracterizes PO’s arguments. Reply, 9.
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`Dr. Ferrese’s point was that a POSITA would understand that “a signal
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`characterizing a power requirement” indicates how much power is required.
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`EX1027 [Ferrese Dep. Tr.], 85:10-86:2. Petitioners argue that internal operating
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`characteristics may be used for purposes other than “providing a specific level of
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`power”. Reply, 10, FN6. But that is a different issue than whether “a signal
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`characterizing a power requirement” is indicative of how much power is required
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`by the system or whether Chagny teaches “a signal characterizing a power
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`requirement.” Dr. Ferrese wasn’t specifically linking “a signal characterizing a
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`power requirement” to the “internal operating characteristic” and, when asked that
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`hypothetical, indicated he had not opined on it and would need time to consider it.
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`EX1027 [Ferrese Dep. Tr.], 86:10-87:7.
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`Petitioners advance the new argument that the claim term “processor
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`system” does not include anything other than the processor itself. Reply, 10-11.
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`Petitioners’ argument is incorrect. The claim term is “processor system,” not
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`“processor”, indicating that there are additional components beyond the processor
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`itself that are part of the system and that also draw power. The specification
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`confirms that a “processor system” is not just a processor and includes other
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`components such as memory and hard drives that draw power. POR, 25, EX1001
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`[’514 Patent], 13:29-33. See, e.g., Pet., 29 FN6 (“the processor system of Chagny
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`also includes other associated components such as ‘memory’ and various
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`‘input/output devices’.”). Thus, the “power requirement of a processor system” are
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`not just the power requirements of the processor itself.
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`The Reply’s remaining arguments regarding this limitation rehash arguments
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`from the Petition and rely on Petitioners’ new interpretations for “characterizing”
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`and “processor system” (Reply, 11) which, as discussed above, are incorrect.
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`Accordingly, Chagny does not teach a “signal characterizing a power requirement
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`of a processor system.”
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`B. Hwang’s “standby signal” is not a “signal characterizing a power
`requirement of a processor system”
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`Hwang does not teach this limitation for the reasons discussed in the POR.
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`POR, 44-45. The Reply does not independently address Hwang for this limitation,
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`but instead appears to rely on its new construction of “characterizing.” Reply, 9.
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`For the reasons discussed above for Chagny, Petitioners’ interpretation is incorrect.
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`IV. CLAIMS 11 AND 16
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`A. Chagny and Hwang do not disclose “enabling operation of
`components of a processor system to establish a state of power
`drain thereof”
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`1.
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`Chagny
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`Petitioners’ arguments rely on its new construction for the term “processor
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`system.” Reply, 12. Petitioners additionally argue that “processor system” is
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`limited to the internal components of a processor itself, and not, as discussed in the
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`specification and claims, external components such as memory or hard drives.
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`Reply, 11-12. Notably, Petitioners’ new construction does not cite to the ’514
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`Patent itself. Reply, 11-12.
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`As discussed above in §III.A, Petitioners’ new construction fails. The ’514
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`Patent states that processor systems contain components such as “memory, hard
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`drives, and specialized circuit cards that are specified and installed when the
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`system is assembled for a particular application.” EX1001 [’514 Patent], 13:29-33.
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`The specification tracks the claim language, stating that “power system drains are
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`generally unknown until such a [processor] system is specified and assembled.”
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`EX1001 [’514 Patent], 13:33-35. Thus, the specification is talking about
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`components such as “memory, hard drives, and specialized circuit cards”
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`establishing a state of power drain. Nothing in the ’514 Patent indicates that
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`“processor system” refers to the internal components of a processor as Petitioners
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`urge.
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`Petitioners argue that “PO’s only alleged support in the specification
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`describes how processor systems may ‘often’ be constructed, not how they must be
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`constructed.” Reply, 12. But the only “system components” identified in the ’514
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`Patent are “memory, hard drives and specialized circuit cards.” EX1001 [’514
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`Patent], 13:29-33. Each example of a component identified as a “system
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`component” is “‘peripheral’ to the processor.” Reply, 12. This indicates that
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`internal processor components (as identified by Petitioners) are not separate
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`“components of a processor system” as required by claims 11 and 16. In addition,
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`the term “processor system” is described in a group of devices including “personal
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`computer, processor system, or a server”, indicating that a “processor system” is
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`similar to a personal computer or server—i.e., a device with a number of
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`components in addition to a processor. EX1001 [’514 Patent]. 13:29-30. Further,
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`claims 11 and 16 require “components” plural, not a single component. Thus, there
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`must be components other than the processor itself.
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`Petitioners’ new construction also contradicts its positions in the Petition.
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`When discussing Chagny with respect to this limitation, Petitioners argued that
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`“the processor system of Chagny also includes other associated components such
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`as ‘memory’ and various ‘input/output devices.’” Pet., 29 FN6. Thus, Chagny and
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`Hwang do not “enable operation of components of a processor system” because
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`their activity input and microprocessor only affect the processor and do not relate
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`to any additional components of the processor system.
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`2. Hwang
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`Petitioners’ arguments with respect to Hwang and “processor system” fail
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`with respect to Hwang for the reasons discussed above with respect to Chagny.
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`In addition, Petitioners take issue with PO’s statement that Hwang “does not
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`disclose the capability to selectively power individual components of a processor”
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`regardless of how they are defined.1 Reply, 12. Petitioners argue that “[n]othing
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`requires that the components be ‘selectively’ enabled, much less ‘selectively’
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`powered on or off in a binary manner. But the claims require “enabl[ing] operation
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`of components of a processor system to establish a state of power drain thereof.”
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`EX1001 [’514 Patent], claims 11 and 16. Thus, the claims require (1) more than
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`1 Petitioners indicate this argument applies to “the prior art” (Reply, 12), but
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`the POR only makes this specific argument as to Hwang. POR, 46.
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`one component must be enabled, and (2) each of those components has an
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`individual power drain. Id. Providing power to the processor alone (as in Hwang)
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`does not satisfy the claim.
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`Petitioners’ remaining arguments rehash the arguments from the Petition
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`(Reply, 13-14), which fail for the reasons discussed above and in the POR. See
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`supra, §IV.A.1; POR, 27-28, 45-47.
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`B. Hwang does not disclose “sensing a power level of said state of
`power drain in response to said signal”
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`For the reasons discussed above in §IV.A and in the POR, Hwang does not
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`disclose this limitation.
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`V.
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`“POWER SYSTEM CONTROLLER”
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`A. Chagny’s software program 296 is not a “power system
`controller”
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`The Reply repeats the arguments from the Petition and Institution Decision.
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`Reply, 15, D.I, 18. But, as discussed above and in the POR, Chagny does not
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`perform the functions recited in claims 6 and 11 for the power system controller.
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`See supra §§III-IV; POR, 28-29.
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`The POR demonstrated Chagny’s software program 296 “does not control
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`the power system, and is limited to reporting the activity level of the processor,
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`which is only one component of the overall [processor] system.” POR, 30. Chagny
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`discloses that its processor is “included in an information handling device 290”
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`(EX1004 [Chagny], 3:57-60), and identifies “servers, desktop and notebook
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`computers, storage systems, personal digital assistants, cellular phones and gaming
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`consoles” as devices in an “information handling system.” EX1004 [Chagny], 1:7-
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`12; POR, 30-31. In other words, these devices correspond to the ’514 Patent’s
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`“processor systems”. But Chagny’s software program 296 has nothing to do with
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`any of the components of the information handling device 290 (corresponding to
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`the claimed “processor system”) other than processor 292. It is not a power system
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`controller because it does not control the “power system” and its software program
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`does not “provide a signal characterizing a processor system” or “enable operation
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`of components of a processor system.” POR, 30-32.
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`B. Hwang’s microprocessor is not a “power system controller”
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`The Reply makes similar arguments for Hwang. Reply, 16-17. As discussed
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`above and in the POR, Hwang’s microprocessor does not perform the functions
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`recited in claims 6 and 11 for the power system controller. See §§III-IV, supra;
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`POR, 47-50. And Petitioners do not allege any additional control functions
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`performed by Hwang’s microprocessor. Indeed, the “standby signal” sent by
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`Hwang’s microprocessor is exactly the type of static sleep mode the ’514 Patent
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`was designed to improve upon. EX1001 [’514 Patent], 5:60-67 (“corresponding
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`states have not been described for elements of the power system… .”).
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`Accordingly, Hwang does not disclose this limitation.
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`VI.
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`DEPENDENT CLAIMS 2, 7, 12, 17
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`A. Chagny does not disclose “in accordance with said [signal/power
`level]”
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`Claim 2 requires the power converter controller is “configured to provide
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`another signal to co