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2012 Exhibit: EX 2012 4 1 Prop Terms for Construction

Document IPR2021-01213, No. 2012-29 Exhibit - EX 2012 4 1 Prop Terms for Construction (P.T.A.B. Oct. 19, 2021)
Siemens also reserves the right to seek any necessary claim constructions in support of its defenses under 35 U.S.C. §§ 101 and 112 as disclosed in its Patent L.R.
Def.’s Proposed Terms for Construction Case No. 3:20-cv-04151-WHO (LB) Patent Owner Ex. 2012-004 • “ranking [the] nets in a design based on unpredictability and expected quality-of-result impact” (all asserted claims).
• “an interconnect-synthesis module for performing timing-driven topology generation, layer assignment, and global routing of the selected nets, the interconnect-synthesis Def.’s Proposed Terms for Construction Case No. 3:20-cv-04151-WHO (LB) Patent Owner Ex. 2012-007 module outputting persistent global routes having actual parasitics and delays for the selected nets” (claim 51).
On March 9, 2021, I served the foregoing document(s) described as Defendant Siemens Industry Software Inc.’s Proposed Terms for Construction Pursuant to Patent L.R.
 Federal: I declare under penalty of perjury under the laws of the United States of America, that the foregoing is true and correct, and that I am employed in the offices of Klarquist Sparkman, LLP. Kristin L. Cleveland Print Name Kristin L. Cleveland Signature Proof of Service Case No. 3:20-cv-04151-WHO (LB) Patent Owner Ex. 2012-009
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2015 Exhibit: EX 2015 E 2021 04 14 102 Joint Claim Construction and Prehearing Statement Pursuant to PLR 4 3 and Exhs

Document IPR2021-01213, No. 2015-36 Exhibit - EX 2015 E 2021 04 14 102 Joint Claim Construction and Prehearing Statement Pursuant to PLR 4 3 and Exhs (P.T.A.B. Oct. 19, 2021)
‘DUSpIAyJISULQUT ‘ATessaoau ‘TOTINASUO-) asvIygWI], ‘ON IeynosedveYMpayersosseOLIBUDOSJUSLINSoY)IOAOMOP]UONPIOIAJUoUalnbDalUsISapBXIfO}3JVoMOUEBYJIMayeBQoRldalACUIUlaISASoy],‘ayes Sq}‘pajejsSSIMIayjOSsajun“alMSOposIpSiu}Uy,, [edIoAjalospaseq,sueour0paseq,aseiy aqABULQOS2[qe}UlUMOYSUONPULIOJUL3UJ, Zo0uaplagpueuoronysuosdsksdouXg uOT}ON.
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2017 Exhibit: EX 2017 A 2021 05 24 114 Defendant Siemens Claim Construction Brief and Exs

Document IPR2021-01213, No. 2017-38 Exhibit - EX 2017 A 2021 05 24 114 Defendant Siemens Claim Construction Brief and Exs (P.T.A.B. Oct. 19, 2021)
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).
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2017 Exhibit: EX 2017 B 2021 05 24 114 Defendant Siemens Claim Construction Brief and Exs

Document IPR2021-01213, No. 2017-39 Exhibit - EX 2017 B 2021 05 24 114 Defendant Siemens Claim Construction Brief and Exs (P.T.A.B. Oct. 19, 2021)
In one timing estimates), and the placementandthe routing typically example according to this aspect, the first placement infor- runsfaster because asit has been reduced from onevery large probleminto a series of simpler problems.
Based on accurate wire delay estimations obtained using methodsofvarious embodi- ment of the present invention, optimizations can be per- formed to improve logic synthesis accuracy.
The placement and synthesis optimization may also involve retiming by movingflip-flops over logic and poten- tially over sequential elements to balance timing slack on the input and output sides of the flip-flops.
A data processing system as in claim 15, wherein the exact routing information is back annotated from a timing analysis based on placing androuting ofat least the portion of the path.
A data processing system as in claim 22, wherein the exact routing information is back annotated from a timing analysis based on placing androutingofat least the portion of the path.
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2016 Exhibit: EX 2016 2021 05 11 113 Synopsys Corrected Opening Claim Construction Brief and Exs

Document IPR2021-01213, No. 2016-37 Exhibit - EX 2016 2021 05 11 113 Synopsys Corrected Opening Claim Construction Brief and Exs (P.T.A.B. Oct. 19, 2021)
Relying on descriptions of preferred embodiments and ignoring the full context and teachings of the asserted patents, Siemens arrives at erroneous claim constructions that do not comport with the intrinsic and extrinsic evidentiary record.
Siemens’ expert opines that a POSITA would be confused about the meaning because: (1) the 567 Patent doesn’t define the term; and (2) LEF and DEF (EDA file formats) have parameters named SITE and COVER.
However, to minimize the resulting performance penalty, the 614 Patent also teaches two techniques to reduce the number of conflicts that arise in the first place: (1) adjusting the size of the window and (2) a pre-processing step to geographically diversify the global nets across the chip surface.
In 1991, I joined the Department of Electrical and Computer Engineering at the University of Rochester, where I am a Distinguished Professor and the Director of the High Performance VLSI (very large-scale integration)/IC Design and Analysis Laboratory.
Under my technical leadership, my academic research program has developed many related technologies in this area of clock tree synthesis, many of which have been adopted by the premier semiconductor companies in the world.
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2015 Exhibit: EX 2015 A 2021 04 14 102 Joint Claim Construction and Prehearing Statement Pursuant to PLR 4 3 and Exhs

Document IPR2021-01213, No. 2015-32 Exhibit - EX 2015 A 2021 04 14 102 Joint Claim Construction and Prehearing Statement Pursuant to PLR 4 3 and Exhs (P.T.A.B. Oct. 19, 2021)
“wherein using commonly-shared clock paths in the clock-tree to provide clock signals to the timing critical register pairs improves timing performance of the IC chip by reducing the impact of on-chip- variationsin creating clock skew between Joint Claim Construction and Prehearing Statement Case No. 3:20-cv-04151-WHO (LB) Patent Owner Ex. 2015-006 Patent Owner Ex. 2015-006 Siemens Construction Synopsys Construction registers in timing critical register pairs” (claims 11, 23) “wherein the on-chip- variations can include: process variations; voltage variations; and temperature variations” The entire wherein clause recites merely an optional feature and has no patentable weight.
A POSAin 2007 would have known that the LEF / DEF formats also have a keyword parameter called COVERfor denoting a circuit device — like a logic gate or register — that cannot be movedatall.
Joint Claim Construction and Prehearing Statement Case No. 3:20-cv-04151-WHO (LB) Patent Owner Ex. 2015-027 Patent Owner Ex. 2015-027 71.|The POSA would be confused as to whether these claim terms alone or in CoOeSNNWNAFFWONY combination exclude the following embodiment: “In one embodiment, there is no special protection for the persistent nets during detailed routing or the subsequent post-routing circuit optimization steps (and their associated incremental re-routings), in order to avoid any limitations on the effectiveness of these steps.” (915 11:40—-44.)
|APOSA would be confused as to whether “unpredictability” excludes other possible proxies, such as delay, “criticality,” capacitive coupling and wirelength, and whether ranking based on any of these additional parameters falls within the scope of “ranking” or “re-ranking” nets “based on unpredictability.” (915 claim 1.)
For example, the specification states that “a multi-scenario ECO database mayonly store information for objects(e.g., gates, nets, pins, etc.) that are required for analyzing the impact of ECOsin different scenarios” (’655 6:7—10), analyzing the impact being part of the checkingstep, and that “the system can determine an engineering changeorder to fix one or more design Joint Claim Construction and Prehearing Statement Case No. 3:20-cv-04151-WHO (LB) Patent Owner Ex. 2015-034 Patent Owner Ex. 2015-034
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2015 Exhibit: EX 2015 C 2021 04 14 102 Joint Claim Construction and Prehearing Statement Pursuant to PLR 4 3 and Exhs

Document IPR2021-01213, No. 2015-34 Exhibit - EX 2015 C 2021 04 14 102 Joint Claim Construction and Prehearing Statement Pursuant to PLR 4 3 and Exhs (P.T.A.B. Oct. 19, 2021)
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2017 Exhibit: EX 2017 B 2021 05 24 114 Defendant Siemens Claim Construction Brief and Exs

Document IPR2021-01213, No. 2017-39 Exhibit - EX 2017 B 2021 05 24 114 Defendant Siemens Claim Construction Brief and Exs (P.T.A.B. Oct. 19, 2021)
In one timing estimates), and the placementandthe routing typically example according to this aspect, the first placement infor- runsfaster because asit has been reduced from onevery large probleminto a series of simpler problems.
Based on accurate wire delay estimations obtained using methodsofvarious embodi- ment of the present invention, optimizations can be per- formed to improve logic synthesis accuracy.
The placement and synthesis optimization may also involve retiming by movingflip-flops over logic and poten- tially over sequential elements to balance timing slack on the input and output sides of the flip-flops.
A data processing system as in claim 15, wherein the exact routing information is back annotated from a timing analysis based on placing androuting ofat least the portion of the path.
A data processing system as in claim 22, wherein the exact routing information is back annotated from a timing analysis based on placing androutingofat least the portion of the path.
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2017 Exhibit: EX 2017 B 2021 05 24 114 Defendant Siemens Claim Construction Brief and Exs

Document IPR2021-01213, No. 2017-39 Exhibit - EX 2017 B 2021 05 24 114 Defendant Siemens Claim Construction Brief and Exs (P.T.A.B. Oct. 19, 2021)
In one timing estimates), and the placementandthe routing typically example according to this aspect, the first placement infor- runsfaster because asit has been reduced from onevery large probleminto a series of simpler problems.
Based on accurate wire delay estimations obtained using methodsofvarious embodi- ment of the present invention, optimizations can be per- formed to improve logic synthesis accuracy.
The placement and synthesis optimization may also involve retiming by movingflip-flops over logic and poten- tially over sequential elements to balance timing slack on the input and output sides of the flip-flops.
A data processing system as in claim 15, wherein the exact routing information is back annotated from a timing analysis based on placing androuting ofat least the portion of the path.
A data processing system as in claim 22, wherein the exact routing information is back annotated from a timing analysis based on placing androutingofat least the portion of the path.
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2015 Exhibit: EX 2015 D 2021 04 14 102 Joint Claim Construction and Prehearing S...

Document IPR2021-01213, No. 2015-35 Exhibit - EX 2015 D 2021 04 14 102 Joint Claim Construction and Prehearing Statement Pursuant to PLR 4 3 and Exhs (P.T.A.B. Oct. 19, 2021)

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2017 Exhibit: EX 2017 C 2021 05 24 114 Defendant Siemens Claim Construction B...

Document IPR2021-01213, No. 2017-40 Exhibit - EX 2017 C 2021 05 24 114 Defendant Siemens Claim Construction Brief and Exs (P.T.A.B. Oct. 19, 2021)

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2018 Exhibit: EX 2018 2021 05 31 118 Synopsys Reply ISO its Claim Construction ...

Document IPR2021-01213, No. 2018-41 Exhibit - EX 2018 2021 05 31 118 Synopsys Reply ISO its Claim Construction Brief (P.T.A.B. Oct. 19, 2021)

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2015 Exhibit: EX 2015 D 2021 04 14 102 Joint Claim Construction and Prehearing S...

Document IPR2021-01213, No. 2015-35 Exhibit - EX 2015 D 2021 04 14 102 Joint Claim Construction and Prehearing Statement Pursuant to PLR 4 3 and Exhs (P.T.A.B. Oct. 19, 2021)

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2014 Exhibit: EX 2014 PLR 4 2 Cover Doc and Exhibits

Document IPR2021-01213, No. 2014-31 Exhibit - EX 2014 PLR 4 2 Cover Doc and Exhibits (P.T.A.B. Oct. 19, 2021)

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2013 Exhibit: EX 2013 2021 03 30 Synopsys PLR 4 2 Preliminary Claim w Construc...

Document IPR2021-01213, No. 2013-30 Exhibit - EX 2013 2021 03 30 Synopsys PLR 4 2 Preliminary Claim w Constructions and Extrinsic Evidence (P.T.A.B. Oct. 19, 2021)

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