BiTMICRO LLC v. Intel Corp. – Civil Action No. 6:22-cv-00335-ADA
`Plaintiff’s Preliminary Disclosure of Asserted Claims and Infringement Contentions
`Appendix H – U.S. Patent No. 6,496,939 (“the ’939 Patent”)
`
`BiTMICRO LLC (“Plaintiff” or “BiTMICRO”) hereby provides preliminary infringement contentions in support of its claim that Intel
`Corporation (“Defendant” or “Intel”) infringes the ’939 Patent. Plaintiff currently contends that Defendant infringes the following
`claims (“Asserted Claims”) of the ’939 Patent:
`
`Claims 1, 2, 3, 6, 10, 11, 12, 15.
`
`Defendant directly infringes (or has directly infringed) the Asserted Claims of the ’939 Patent under 35 U.S.C. § 271(a) by making,
`using, selling, offering for sale, and/or importing into the United States solid state drives (SSDs) with power loss protection, including
`the Intel SSD DC S3500 Series; SSD DC S3700 Series; Optane™ Memory H10 with Solid State Storage; Optane™ SSD DC
`D4800X Series; SSD D3-S4510 Series; SSD D3-S4610 Series; SSD D5-P4320 Series; SSD D5-P4326 Series; SSD D5-P4420 Series;
`SSD DC P4510 Series; SSD DC P4511 Series; SSD DC P4610 Series; SSD DC P4618 Series; SSD 750 Series; SSD DC P3500
`Series; SSD DC P3520 Series; SSD DC P3600 Series; SSD DC P3608 Series; SSD DC P3700 Series; SSD DC P4500 Series; SSD DC
`P4501 Series; SSD DC P4600 Series; SSD DC P4608 Series; SSD DC S3320 Series; SSD DC S3510 Series; SSD DC S3520 Series;
`SSD DC S3610 Series; SSD DC S3710 Series; SSD DC S4500 Series; SSD DC S4600 Series; SSD E 5410s Series; SSD E 7000s
`Series; and all reasonably similar products (“the ’939 Accused Instrumentalities”).
`
`References to instrumentalities in this chart are exemplary only and should not be construed as limiting the scope of any claim of the
`’939 Patent. The Intel ’939 Accused Instrumentalities satisfy each element of each Asserted Claim below literally. In addition,
`depending on the Court’s claim construction, and to the extent any of the elements of the Asserted Claims may later be determined not
`to be literally present, the doctrine of equivalents may also apply.
`
`Because details of the structure and operation of the ’939 Accused Instrumentalities are not readily available for public inspection, and
`also because public documentation provides only a high level of abstraction aimed at customers, these contentions are intended to
`provide notice to Defendant regarding the subject matter to be explored in discovery. Details concerning the structure and manner of
`operation of the ’939 Accused Instrumentalities are expected to be found in internal Intel documentation.
`
`Plaintiff’s contentions regarding infringement of specific claims will depend on the claim construction ultimately adopted by the
`Court. Because said construction has not yet occurred, Plaintiff’s contentions herein are preliminary, and subject to change based
`upon the Court’s construction. In addition, Plaintiff’s investigation and analysis of the ’939 Accused Instrumentalities are based upon
`
`1
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`information made publicly available by Defendant and the Plaintiff’s own investigations. Plaintiff reserves the right to amend these
`contentions based upon discovery of additional information from Defendant or third parties regarding the operation of the ’939
`Accused Instrumentalities, or upon discovery of additional products or technologies of Defendant that infringe the ’939 Patent.
`
`All bolded italics and/or highlighting are emphasis added unless noted otherwise.
`
`
`Claim 1
`
`1[Pre]
`1. A method for controlling
`data in a computer system
`when the computer system
`loses power, the computer
`system comprising a
`computing engine,
`comprising the steps of:
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`Intel makes, uses, sells, offers for sale, and imports into the United States solid state drives (SSDs)
`with power loss protection, including but not limited to the SSD DC S3500 Series; SSD DC S3700
`Series; Optane™ Memory H10 with Solid State Storage; Optane™ SSD DC D4800X Series; SSD
`D3-S4510 Series; SSD D3-S4610 Series; SSD D5-P4320 Series; SSD D5-P4326 Series; SSD D5-
`P4420 Series; SSD DC P4510 Series; SSD DC P4511 Series; SSD DC P4610 Series; SSD DC P4618
`Series; SSD 750 Series; SSD DC P3500 Series; SSD DC P3520 Series; SSD DC P3600 Series; SSD
`DC P3608 Series; SSD DC P3700 Series; SSD DC P4500 Series; SSD DC P4501 Series; SSD DC
`P4600 Series; SSD DC P4608 Series; SSD DC S3320 Series; SSD DC S3510 Series; SSD DC S3520
`Series; SSD DC S3610 Series; SSD DC S3710 Series; SSD DC S4500 Series; SSD DC S4600 Series;
`SSD E 5410s Series; and SSD E 7000s Series. These SSDs come in multiple form factors, including
`but not limited to M.2, 2.5” STA, mSATA form factors. These SSDs are designed and intended to be
`paired with other computing elements, including but not limited to a laptops, desktops, servers, etc.
`See e.g., https://www.intel.com/content/www/us/en/products/details/memory-storage.html
`
`For example, the Intel SSD DC-S37001 shown in the photo below is a solid-state drive (SSD)
`comprised of NAND flash memory. According to Intel, it “offers the next generation of data center
`SSDs combining fast consistent performance with high endurance, and strong data protection.”
`
`
`
`1 The Intel SSD DC-3700 is used herein as a representative product. All of the SSD ’939 Accused Instrumentalities operate in the same material manner.
`2
`
`
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`Claim 1
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`
`
`
`
`See e.g., Intel® SSD DC S3700 Series, at Product Images, available at https://ark.intel.com/content/
`www/us/en/ark/products/71915/intel-ssd-dc-s3700-series-400gb-2-5in-sata-6gbs-25nm-mlc.html
`
`The Intel SSD DC-S3700 comprises the computing engine, and includes a “method for controlling
`data in a computer system when the computer system loses power, the computer system comprising a
`computing engine.” Specifically, it includes a feature called Enhanced Power-Loss Data Protection,
`or alternatively known as Power Loss Imminent Technology. As described by Intel’s documentation,
`this feature “reduces potential data loss by detecting and protecting data from an unexpected system
`power loss” by, e.g., “sav[ing] all cached data in the process of being written before shutting down.”
`
`
`See e.g., Intel® SSD DC S3700 Series, Product Brief, available at
`https://www.intel.com/content/dam/support/us/en/documents/solid-state-drives/ssd-dc-s3700-brief.pdf
`
`Intel explains the benefits of Enhanced Power-Loss Data Protection a/k/a Power Loss Imminent
`Technology. This includes, but is not limited to improving data integrity during power loss events,
`help speed the data center recover after a power loss event. As explained and marketed by Intel:
`
`
`
`3
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`Claim 1
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`
`
`
`
`
`See e.g., Intel “Power Loss Imminent (PLI) Technology,” at 7.
`
`The Intel SSDs with PLP/PLI include and perform the claimed computer-implemented method for
`controlling data in a computer system, with the aforementioned components playing a role therein.
`
`The Intel SSDs with PLP/PLI method includes activating a plurality of super capacitors to supply
`power to the computing engine based upon power being removed from the computer system.
`
`For example, the Intel SSD DC-S3700’s Power-Loss Data Protection, also known as the Power Loss
`Imminent (PLI) Technology” includes a capacitor bank, which is the equivalent of the claimed super
`capacitors. As described by Intel, “SSDs with PLI technology contain energy storing capacitors. The
`energy storing capacitors provide enough energy (power) to complete any commands in progress and
`to make sure that any data in the temporary buffers is committed to the non-volatile NAND Flash
`media. These capacitors act as backup batteries for the drive.” As further illustrated by Intel:
`
`
`1[a]
`(a) activating a plurality of
`super capacitors to supply
`power to the computing
`engine based upon power
`being removed from the
`computer system;
`
`4
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`Claim 1
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`
`Intel, “Power Loss Imminent (PLI) Technology,” at 2, available at
`https://www.intel.com/content/dam/www/public/us/en/documents/technology-briefs/ssd-power-loss-
`imminent-technology-brief.pdf
`
`This capacitor can be comprised of one or more capacitors, as shown in the teardown below.
`
`
`
`
`
`Storage Review, “Intel SSD DC S3700 Series Enterprise SSD Review”, available at
`https://www.storagereview.com/review/intel-ssd-dc-s3700-series-enterprise-ssd-review
`
`
`
`5
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`Claim 1
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`Intel’s product documentation describes and illustrates the architecture of the PLI technology. For
`example, the figure below “shows an operational architectural diagram depicting the key PLI
`components, the SSD voltage detector, the charge storing capacitor bank, and the SMART (Self-
`Monitoring Analysis and Monitoring Technology) attribute extraction module.”
`
`
`
`
`Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`
`As Intel explains, “[t]he SSD voltage detector circuit constantly monitors the drive’s supply voltage.
`If the voltage falls below a predefined level, indicating a power loss event is imminent, the SSD will
`use the backup energy supply from the capacitor bank to write any data in temporary buffers to the
`NAND Flash media. After the power is restored, the PLI capacitors will be charged up again and
`ready for a future power loss event.” Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`To the extent necessary, the capacitors in the Intel SSDs with PLP/PLI are equivalent to the claimed
`super capacitors insofar as the perform substantially the same function in substantially the same way
`to obtain the same results, namely providing power to computing engine in the event of a power loss.
`
`The Intel SSDs with PLP/PLI method includes reconfiguring the data in the computing engine.
`
`As Intel explains in its documentation, SSDs with PLP/PLI monitor the voltage level of the RAM of
`the SSD. During normal system operation, power is supplied from the external source (AC) power.
`6
`
`1[b]
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`Claim 1
`(b) reconfiguring the data
`in the computing engine;
`and
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`However, if the voltage drops below a predefined level due to a power failure or brief power outage,
`the PLP/PLI technology flushes the data from the volatile memory to the non-volatile NAND flash.
`
`Intel’s documentation explains this further. For example, the figure below “illustrates the switching
`sequence that engages the PLI capacitors to the SSD controller during a power loss event. As shown,
`switch 1 (SW1) is closed, connecting the capacitor energy to the SSD ASIC Controller, and switch 2
`(SW2) is opened, disengaging the host power supply source. The energy stored in the PLI capacitors
`will be used to finish transferring any data in the buffer to the non-volatile NAND Flash media. When
`power is restored the PLI capacitors will be charged up again and ready for a future power loss event.”
`
`
`Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`As further illustrated by Intel:
`
`
`
`
`7
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`Claim 1
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`
`
`
`Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`The Intel SSDs with PLP/PLI method includes deactivating the plurality of super capacitors to cut off
`power to the computing engine based upon the plurality of super capacitors discharging to a
`predetermined level.
`
`Intel’s product documentation describes and illustrates the architecture of the PLI technology. For
`example, the figure below “shows an operational architectural diagram depicting the key PLI
`components, the SSD voltage detector, the charge storing capacitor bank, and the SMART (Self-
`Monitoring Analysis and Monitoring Technology) attribute extraction module.”
`
`
`1[c]
`(c) deactivating the
`plurality of super
`capacitors to cut off power
`to the computing engine
`based upon the plurality of
`super capacitors
`discharging to a
`predetermined level.
`
`8
`
`
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`
`
`
`Claim 1
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`For example, when all the data in the SSD DRAM (volatile memory) has been transferred and/or
`when the PLI capacitors are at or near depletion state, the SSD with PLP/PLI deactivates the PLI
`capacitors to cut off power to the computing engine, in effect reversing the switches below.
`
`
`Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`
`
`
`
`
`9
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`
`
`
`Claim 2
`
`2
`The method of claim 1
`wherein the computing
`engine comprises a least
`one volatile memory and at
`least one non-volatile
`memory.
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`See claim 1. The Intel SSDs with PLP/PLI include a least one volatile memory and at least one non-
`volatile memory.
`
`The Intel SSDs with PLP/PLI buffers (volatile memory) and SSD media (non-volatile memory).
`
`
`Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`
`
`
`
`
`10
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`
`
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`The Intel SSDs with PLP/PLI method includes allowing all data to be transferred from the at least one
`volatile memory to the at least one non-volatile memory.
`
`See claim 1, 2.
`
`
`
`
`Claim 3
`
`3
`The method of claim 2
`wherein the reconfiguring
`step (b) further comprises:
`(b1) allowing all data to be
`transferred from the at least
`one volatile memory to the
`at least one non-volatile
`memory.
`
`
`
`11
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`Claim 6
`
`6[Pre]
`The method of claim 3
`wherein the activating step
`(a) further comprises:
`
`6[a]
`(a1) reversing the flow of
`current between the
`computing engine and the
`plurality of super
`capacitors; and
`
`6[b]
`(a2) discharging current
`from the plurality of super
`capacitors to the
`computing engine.
`
`
`
`
`
`
`
`
`
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`See claim 1, 2, 3.
`
`The claimed method of the Intel SSDs with PLP/PLI includes reversing the flow of current between
`the computing engine and the plurality of super capacitors.
`
`See claim 1[a].
`
`The claimed method of the Intel SSDs with PLP/PLI includes discharging current from the plurality of
`super capacitors to the computing engine.
`
`See claim 1[a].
`
`12
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`Claim 10
`
`10[Pre]
`A system for controlling
`data in a computer system
`when the computer system
`loses power, the computer
`system comprising a
`computer engine,
`comprising:
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`Intel makes, uses, sells, offers for sale, and imports into the United States solid state drives (SSDs)
`with power loss protection, including but not limited to the SSD DC S3500 Series; SSD DC S3700
`Series; Optane™ Memory H10 with Solid State Storage; Optane™ SSD DC D4800X Series; SSD
`D3-S4510 Series; SSD D3-S4610 Series; SSD D5-P4320 Series; SSD D5-P4326 Series; SSD D5-
`P4420 Series; SSD DC P4510 Series; SSD DC P4511 Series; SSD DC P4610 Series; SSD DC P4618
`Series; SSD 750 Series; SSD DC P3500 Series; SSD DC P3520 Series; SSD DC P3600 Series; SSD
`DC P3608 Series; SSD DC P3700 Series; SSD DC P4500 Series; SSD DC P4501 Series; SSD DC
`P4600 Series; SSD DC P4608 Series; SSD DC S3320 Series; SSD DC S3510 Series; SSD DC S3520
`Series; SSD DC S3610 Series; SSD DC S3710 Series; SSD DC S4500 Series; SSD DC S4600 Series;
`SSD E 5410s Series; and SSD E 7000s Series. These SSDs come in multiple form factors, including
`but not limited to M.2, 2.5” STA, mSATA form factors. These SSDs are designed and intended to be
`paired with other computing elements, including but not limited to a laptops, desktops, servers, etc.
`See e.g., https://www.intel.com/content/www/us/en/products/details/memory-storage.html
`
`For example, the Intel SSD DC-S37002 shown in the photo below is a solid-state drive (SSD)
`comprised of NAND flash memory. According to Intel, it “offers the next generation of data center
`SSDs combining fast consistent performance with high endurance, and strong data protection.”
`
`
`
`
`
`
`
`2 The Intel SSD DC-3700 is used herein as a representative product. All of the SSD ’939 Accused Instrumentalities operate in the same material manner.
`13
`
`
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`Claim 10
`
`
`
`
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`See e.g., Intel® SSD DC S3700 Series, at Product Images, available at https://ark.intel.com/content/
`www/us/en/ark/products/71915/intel-ssd-dc-s3700-series-400gb-2-5in-sata-6gbs-25nm-mlc.html
`
`The Intel SSD DC-S3700 comprises the computing engine, and includes a “method for controlling
`data in a computer system when the computer system loses power, the computer system comprising a
`computing engine.” Specifically, it includes a feature called Enhanced Power-Loss Data Protection,
`or alternatively known as Power Loss Imminent Technology. As described by Intel’s documentation,
`this feature “reduces potential data loss by detecting and protecting data from an unexpected system
`power loss” by, e.g., “sav[ing] all cached data in the process of being written before shutting down.”
`
`
`See e.g., Intel® SSD DC S3700 Series, Product Brief, available at
`https://www.intel.com/content/dam/support/us/en/documents/solid-state-drives/ssd-dc-s3700-brief.pdf
`
`Intel explains the benefits of Enhanced Power-Loss Data Protection a/k/a Power Loss Imminent
`Technology. This includes, but is not limited to improving data integrity during power loss events,
`help speed the data center recover after a power loss event. As explained and marketed by Intel:
`
`
`
`
`14
`
`
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`Claim 10
`
`10[a]
`means for activating a
`plurality of super
`capacitors to supply power
`to the computing engine
`based upon power being
`removed from the
`computer system;
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`See e.g., Intel “Power Loss Imminent (PLI) Technology,” at 7.
`
`The Intel SSDs with PLP/PLI include and perform the claimed computer-implemented method for
`controlling data in a computer system, with the aforementioned components playing a role therein.
`
`
`
`
`The Intel SSDs with PLP/PLI system includes means for activating a plurality of super capacitors to
`supply power to the computing engine based upon power being removed from the computer system.
`
`For example, the Intel SSD DC-S3700’s Power-Loss Data Protection, also known as the Power Loss
`Imminent (PLI) Technology” includes a capacitor bank, which is the equivalent of the claimed super
`capacitors. As described by Intel, “SSDs with PLI technology contain energy storing capacitors. The
`energy storing capacitors provide enough energy (power) to complete any commands in progress and
`to make sure that any data in the temporary buffers is committed to the non-volatile NAND Flash
`media. These capacitors act as backup batteries for the drive.” As further illustrated by Intel:
`
`
`Intel, “Power Loss Imminent (PLI) Technology,” at 2, available at
`https://www.intel.com/content/dam/www/public/us/en/documents/technology-briefs/ssd-power-loss-
`imminent-technology-brief.pdf
`
`
`
`
`15
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`Claim 10
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`This capacitor can be comprised of one or more capacitors, as shown in the teardown below.
`
`
`
`Storage Review, “Intel SSD DC S3700 Series Enterprise SSD Review”, available at
`https://www.storagereview.com/review/intel-ssd-dc-s3700-series-enterprise-ssd-review
`
`
`Intel’s product documentation describes and illustrates the architecture of the PLI technology. For
`example, the figure below “shows an operational architectural diagram depicting the key PLI
`components, the SSD voltage detector, the charge storing capacitor bank, and the SMART (Self-
`Monitoring Analysis and Monitoring Technology) attribute extraction module.”
`
`
`16
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`Claim 10
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`
`
`
`Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`
`As Intel explains, “[t]he SSD voltage detector circuit constantly monitors the drive’s supply voltage.
`If the voltage falls below a predefined level, indicating a power loss event is imminent, the SSD will
`use the backup energy supply from the capacitor bank to write any data in temporary buffers to the
`NAND Flash media. After the power is restored, the PLI capacitors will be charged up again and
`ready for a future power loss event.” Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`To the extent necessary, the capacitors in the Intel SSDs with PLP/PLI are equivalent to the claimed
`super capacitors insofar as the perform substantially the same function in substantially the same way
`to obtain the same results, namely providing power to computing engine in the event of a power loss.
`
`
`
`
`The Intel SSDs with PLP/PLI system includes means for activating a plurality of super capacitors to
`supply power to the computing engine based upon power being removed from the computer system.
`
`As Intel explains in its documentation, SSDs with PLP/PLI monitor the voltage level of the RAM of
`the SSD. During normal system operation, power is supplied from the external source (AC) power.
`
`17
`
`10[b]
`means for reconfiguring
`the data in the computing
`engine; and
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`Claim 10
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`However, if the voltage drops below a predefined level due to a power failure or brief power outage,
`the PLP/PLI technology flushes the data from the volatile memory to the non-volatile NAND flash.
`
`Intel’s documentation explains this further. For example, the figure below “illustrates the switching
`sequence that engages the PLI capacitors to the SSD controller during a power loss event. As shown,
`switch 1 (SW1) is closed, connecting the capacitor energy to the SSD ASIC Controller, and switch 2
`(SW2) is opened, disengaging the host power supply source. The energy stored in the PLI capacitors
`will be used to finish transferring any data in the buffer to the non-volatile NAND Flash media. When
`power is restored the PLI capacitors will be charged up again and ready for a future power loss event.”
`
`
`Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`As further illustrated by Intel:
`
`
`
`
`18
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`Claim 10
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`
`
`
`Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`
`The Intel SSDs with PLP/PLI system includes means for deactivating the plurality of super capacitors
`to cut off power to the computing engine based upon the plurality of super capacitors discharging to a
`predetermined level.
`
`Intel’s product documentation describes and illustrates the architecture of the PLI technology. For
`example, the figure below “shows an operational architectural diagram depicting the key PLI
`components, the SSD voltage detector, the charge storing capacitor bank, and the SMART (Self-
`Monitoring Analysis and Monitoring Technology) attribute extraction module.”
`
`
`10[c]
`means for deactivating the
`plurality of super
`capacitors to cut off power
`to the computing engine
`based upon the plurality of
`super capacitors
`discharging to a
`predetermined level.
`
`19
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`Claim 10
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`
`Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`For example, when all the data in the SSD DRAM (volatile memory) has been transferred and/or
`when the PLI capacitors are at or near depletion state, the SSD with PLP/PLI deactivates the PLI
`capacitors to cut off power to the computing engine, in effect reversing the switches below.
`
`
`
`
`Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`
`20
`
`
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`
`
`
`
`
`Claim 11
`
`11
`The system of claim 10
`wherein the computing
`engine comprises a least
`one volatile memory and at
`least one non-volatile
`memory.
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`The Intel SSDs with PLP/PLI system includes a least one volatile memory and at least one non-
`volatile memory.
`
`The Intel SSDs with PLP/PLI buffers (volatile memory) and SSD media (non-volatile memory).
`
`
`Intel, “Power Loss Imminent (PLI) Technology,” at 2.
`
`
`
`
`
`
`21
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`Claim 12
`
`12
`The system of claim 11
`wherein the reconfiguring
`means further comprises:
`means for allowing all data
`to be transferred from the
`at least one volatile
`memory to the at least one
`non-volatile memory.
`
`
`
`
`
`
`
`
`
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`The Intel SSDs with PLP/PLI system includes means for allowing all data to be transferred from the at
`least one volatile memory to the at least one non-volatile memory.
`
`See claim 10, 11.
`
`22
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`

`

`
`
`
`
`
`
`Claim 15
`
`15[Pre]
`The system of claim 12
`wherein the activating
`means further comprises:
`
`15[a]
`means for reversing the
`flow of current between the
`computing engine and the
`plurality of super
`capacitors; and
`
`15[b]
`means for discharging
`current from the plurality
`of super capacitors to the
`computing engine.
`
`Exemplary Infringement by Intel SSDs with Power Loss Protection (PLP)
`See claim 12.
`
`The Intel SSDs with PLP/PLI system includes means for reversing the flow of current between the
`computing engine and the plurality of super capacitors.
`
`See claim 10[a].
`
`The Intel SSDs with PLP/PLI system includes means for discharging current from the plurality of
`super capacitors to the computing engine.
`
`See claim 10[a].
`
`23
`
`Petitioner Intel Corp., Ex. 1009
`IPR2023-00783
`
`