A zone of uncertainty which enterprise and experimentation may enter only at the risk of infringement claims would discourage invention onlyalittle less than unequivocal foreclosure ofthe field.” United Carbon Co. v. Binney NywoNONONDNDNONONOKFFHFFFFKFKFOFOUSEFllhUEleSao~~BNOnFFWONYO|FSOoBOSNHDBADFPWONYP||CO & Smith Co., 317 U.S. 228, 236 (1942).
In opposing Siemens’s motion to dismiss, Synopsys identified the problem the patent sought to solve as “fixing design requirement violations across multiple scenarios without incurring high latency costs due to disk access.” (ECF No. 30 11:18—20.)
requirementviolations in a circuit Dispute: Is it a defining characteristic of the patent’s identified problem and solution that the multiple “scenario images” are received into memory, one at a time, from disk (or other non- volatile storage), as Synopsys previously asserted to the Court (ECF No. 30 11-12)?
Attached hereto as Exhibit A is a true and correct copy of excerpts from Defendant Siemens Industry Software Inc.’s Proposed Amended Invalidity Contentions, served April 2, 2021 in accordance with ECF No. 92 (Scheduling Order).
For example, the specification states that “a multi-scenario ECO database may only store information for objects (e.g., gates, nets, pins, etc.) that are required for analyzing the impact of Defendant’s Amended Invalidity Contentions Case No. 3:20-cv-04151-WHO Patent Owner Ex. 2017-051 Patent Owner Ex. 2017-051 ECOsin different scenarios” (655 6:7—10), which is part of the checking step, and that “the system can determine an engineering changeorderto fix one or more design requirementviolations, which can involve estimating parameter values for circuit objects in multiple scenarios using parameter values stored in the scenario image and the multi-scenario ECO database”(655 Abstract).