IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`Udo Hartmann, Sascha Nerger
`In re Patent of:
`7,124,325 Attorney Docket No.: 24069-0004IP2
`U.S. Patent No.:
`October 17, 2006
`
`Issue Date:
`Appl. Serial No.: 10/680,782
`
`Filing Date:
`October 7, 2003
`
`Title:
`Method And Apparatus for Internally Trimming Output
`Drivers and Terminations in Semiconductor Devices
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`DECLARATION OF NICK TREDENNICK
`
`
`
`I, Nick Tredennick, declare as follows:
`
`I.
`
`Introduction
`
`1.
`
`I am making this declaration at the request of Petitioner NVIDIA
`
`Corporation in the matter of Inter Partes Review of U.S. Patent No. 7,124,325
`
`(“the ’325 patent”).
`
`2.
`
` I am being compensated for my work. My compensation does not
`
`depend on the outcome of this proceeding.
`
`
`
`1
`
`NVIDIA 1002
`
`
`
`
`Udo Hartmann, Sascha Nerger
`In re Patent of:
`7,124,325 Attorney Docket No.: 24069-0004IP2
`U.S. Patent No.:
`October 17, 2006
`
`Issue Date:
`Appl. Serial No.: 10/680,782
`
`Filing Date:
`October 7, 2003
`
`Title:
`Method And Apparatus for Internally Trimming Output
`Drivers and Terminations in Semiconductor Devices
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`DECLARATION OF NICK TREDENNICK
`
`
`
`I, Nick Tredennick, declare as follows:
`
`I.
`
`Introduction
`
`1.
`
`I am making this declaration at the request of Petitioner NVIDIA
`
`Corporation in the matter of Inter Partes Review of U.S. Patent No. 7,124,325
`
`(“the ’325 patent”).
`
`2.
`
` I am being compensated for my work. My compensation does not
`
`depend on the outcome of this proceeding.
`
`
`
`1
`
`NVIDIA 1002
`
`
`
`3.
`
` I have been asked to consider whether certain references disclose or
`
`render obvious the claims of the ’325 Patent, either alone or in combination with
`
`each other.
`
`4.
`
` I have been advised that a patent claim may be invalid as obvious if
`
`the differences between the subject matter patented and the prior art are such that
`
`the subject matter as a whole would have been obvious at the time of the invention
`
`to a person having ordinary skill in the art. I have also been advised that several
`
`factual inquiries underlie a determination of obviousness. These inquiries include
`
`the scope and content of the prior art, the level of ordinary skill in the field of the
`
`invention, the differences between the claimed invention and the prior art, and any
`
`objective evidence of non-obviousness.
`
`5.
`
` I have been advised that objective evidence of non-obviousness
`
`directly attributable to the claimed invention, known as “secondary considerations
`
`of non-obviousness,” may include commercial success, satisfaction of a long-felt
`
`but unsolved need, failure of others, copying, skepticism or disbelief before the
`
`invention, and unexpected results. I am not aware of any such objective evidence
`
`of non-obviousness that is directly attributable to the subject matter claimed in the
`
`’325 patent at this time.
`
`6.
`
` In addition, I have been advised that the law requires a “common
`
`sense” approach of examining whether the claimed invention is obvious to a person
`
`
`
`2
`
`
`
`skilled in the art. For example, I have been advised that combining familiar
`
`elements according to known methods is likely to be obvious when it does no more
`
`than yield predictable results. I have further been advised that this is especially true
`
`in instances where there are a limited numbers of possible solutions to technical
`
`problems or challenges.
`
`7.
`
` I understand claims 14, 16-18, and 20 are subject to IPR here.
`
`II. Materials Reviewed
`
`8.
`
` In forming the opinions, I express below, I considered my own
`
`knowledge of the art and at least the following references:
`
`1001
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`
`
`U.S. Patent No. 7,124,325 (“the ’325 patent”)
`
`U.S. Patent No. 6,693,450 (“Volk 450”)
`
`U.S. Patent No. 6,356,105 (“Volk 105”)
`
`Decision Denying Institution of Inter Partes Review dated
`June 23, 2017 for Case No. IPR2017-00382.
`Patent Owner’s Preliminary Response to Petition for Inter
`Partes Review of Patent No. 7,124,325 (Case No. IPR2017-
`00382)
`U.S. Patent No. 6,201,733 (“Hiraki”)
`
`Excerpts from Microsoft Computer Dictionary, Fifth
`Edition, 2002
`Excerpts from Barron’s Dictionary of Computer and
`Internet Terms, Eighth Edition, 2003
`Excerpts from McGraw-Hill, Dictionary of Computing &
`Communications
`
`3
`
`
`
`
`III. Qualifications
`
`9.
`
` I summarize my relevant knowledge and experience below. My
`
`Curriculum Vitae contains additional information and is attached as Exhibit A.
`
`10.
`
`I have a background in electrical engineering that is primarily in the
`
`areas of logic design and microprocessor design and I have completed college
`
`work through a Ph.D. in electrical engineering. I worked in industry at Motorola
`
`and IBM designing microprocessors and at Altera in programmable logic. I taught
`
`electrical and computer engineering courses at the University of California,
`
`Berkeley and at the University of Texas, Austin. I wrote a graduate-level textbook,
`
`Microprocessor Logic Design. I spent twelve years as a member of the Army
`
`Science Board and sixteen years as an Aerospace Engineering Duty Officer for
`
`Naval Air Systems Command, Navy Reserve, studying military applications of
`
`science and technology.
`
`11.
`
`I was a senior design engineer for Motorola, where I did the logic
`
`design and microcode for the MC68000 microprocessor, which was the brains of
`
`the original Apple Macintosh computers. I was a research staff member at IBM’s
`
`T.J. Watson Research Center, where I did the logic design and microcode for the
`
`Micro/370 microprocessor. I was founder and director of engineering for Nexgen
`
`Microsystems, where I hired and managed the engineering groups that designed
`
`Nexgen’s Intel-compatible x86 processor. I founded and managed Tredennick,
`4
`
`
`
`
`
`Inc., a logic design and consulting company for a number of years. I was also
`
`chief scientist at Altera, a programmable logic company. I have nine patents from
`
`work at these companies.
`
`12. For the past three years, I have been at a startup company, Jonetix,
`
`working in the area of cryptography and online transaction security. I am a named
`
`inventor on more than a dozen patent applications and provisional applications
`
`filed for this work, one of which recently issued as U.S. Patent No. 9,635,011.
`
`IV. Person of Ordinary Skill in the Art and State of The Art
`
`13.
`
` In my opinion, a person of ordinary skill in the art as of the time of
`
`the ’325 Patent would have a Bachelor’s degree in Electrical Engineering and at
`
`least 2 years of experience working in the field of semiconductor logic design. I
`
`believe this to be a reasonable statement of the level of ordinary skill in the art for
`
`the patent and claims at issue. I also believe that I was one of ordinary skill in the
`
`art at the time the ’325 Patent was filed.
`
`14.
`
` The opinions that I provide in this declaration are consistent with the
`
`knowledge and experience of one of ordinary skill in the art at the priority date of
`
`the ’325 Patent.
`
`15.
`
` At the time of the ’325 Patent’s priority date, those of ordinary skill
`
`in the art recognized that trimming an interface device (based on a value measured
`
`on the interface device) could be done within the semiconductor device. This
`
`
`
`5
`
`
`
`technology for calibration or trimming of these values was well known in the
`
`industry and was disclosed in various references.
`
`V. Overview of the ’325 Patent
`
`16. The ’325 patent discusses calibrating or “trimming” interface devices
`
`within a semiconductor. Ex. 1001, Abstract. The patent says these interface
`
`devices include output drivers and terminations. Id., 3:18-21. Output drivers and
`
`terminations have parameters that control reading and writing from a data bus. Id.,
`
`1:36-41. As the speed of data transmission increases on a bus, for example in
`
`DRAM, the patent states that “narrower tolerances for the interface parameters” are
`
`required to “maintain the integrity of the data signals transmitted to the data bus.”
`
`Id. One such interface parameter is stated to be “the impedance of the output
`
`drivers…which a semiconductor device uses to effect a write access to the data
`
`bus.” Id., 1:42-54. If trimmed or calibrated correctly, it enables a higher data
`
`transmission rate. Id. In the case of terminations, “which terminate the data bus
`
`locally” and prevent reflections, with greater precision “a higher maximum data
`
`transmission rate is made possible.” Id., 1:55-62.
`
`17. The manufacturing process and temperature variations during
`
`operation cause variations in the interface devices. Id., 1:63-2:5. Before the ’325
`
`patent, methods of trimming existed in the prior art to trim interface devices
`
`“before or during the initial startup…or repeatedly during [] operation.” Id. 2:6-17.
`
`
`
`6
`
`
`
`The interface devices have settable “control elements…in the form of switchable
`
`impedances whose respective value can be programmed” using a value stored in a
`
`“trimming register.” Id.
`
`18. The ’325 patent states that a typical setup in the prior art used a “test
`
`apparatus” with a current source and a voltmeter connected to the device under
`
`test. Id., 2:30-50. To start, a variable impedance in the interface device is set to a
`
`minimum value. Id. According to the ’325 patent, a “measurement current” is
`
`“impress[ed]” on the device. Id. The voltmeter measures the resulting voltage and
`
`the test device compares the measured voltage and the nominal voltage. Id. While
`
`the measured voltage is less than the nominal voltage, the impedance is
`
`incremented. Id. When the measured voltage is higher, the value corresponding to
`
`the corresponding impedance level “is stored in a suitable manner for further use.”
`
`Id. Figure 1 illustrates the prior art approach:
`
`
`
`7
`
`
`
`
`19. The “relatively low throughput of test pieces,” “the time required for
`
`evaluating measurement and trimming data,” preparing test programs for the test
`
`apparatus, and the contact resistance from contact needles are identified as
`
`drawbacks to the approach. Id., 2:51-3:9.
`
`20. The ’325 patent claims that it solves these issues by including the
`
`trimming or calibration unit “within the semiconductor device” rather than on the
`
`test device. Id., 3:53-67. The patent states that this permits more devices to “be
`
`tested and trimmed simultaneously.” Id. It also is said to lessen the difficulties
`
`associated with the test apparatus’ test programs and the contact resistance issues
`
`(because the device under test itself does the measurement). Id., 4:1-10, 54-65.
`
`
`
`8
`
`
`
`This approach, is shown in Figure 3 (below) that indicates the “trimming unit” was
`
`moved into the semiconductor device:
`
`
`21. With reference to Figure 3 above, trimming unit 5 is connected to the
`
`interface devices 10a-10d, and to trimming registers 14. Id., Fig. 3, 8:4-11.
`
`Trimming registers 14 are connected to settable impedances in the interface
`
`devices, which are the settable control elements. Id. The trimming unit compares
`
`measurement voltage (UM) with nominal voltage (US). Id., 8:12-22. If the
`
`measured voltage is less than the nominal voltage, the trimming unit increases the
`
`
`
`9
`
`
`
`value stored in trimming registers 14. Id. That value initially starts at a minimum
`
`level. Id. When they are within a “tolerable discrepancy,” the calibration or
`
`trimming is complete and the value is stored in nonvolatile memory or sent to the
`
`test device. Id., 8:12-33.
`
`22. The trimming unit is shown in Figure 4 (below). Comparator unit 56
`
`compares measured voltage (UM) with nominal voltage (US). Id., 8:39-59. Based
`
`on that comparison, logic unit 57 either increments trimming registers 14 or it
`
`stores the current trimming value in the nonvolatile memory unit 59. Id.
`
`VI. CLAIM CONSTRUCTION
`
`23.
`
`I understand that a claim subject to IPR is given its broadest
`
`reasonable construction pursuant to PTO Regulations.
`
`
`
`
`
`10
`
`
`
`24.
`
`In preparing this declaration, I reviewed the Board’s decision denying
`
`institution of NVIDIA’s previous petition for IPR on claims of this patent. In that
`
`decision, the Board construed the term “interface device,” recited in independent
`
`claim 14, as a device “associated with an interface” “‘between the semiconductor
`
`device’ and ‘another device external to the semiconductor device.’” See Ex. 1006,
`
`10. I have applied the Board’s previous construction of “interface device” in my
`
`analysis of the claims challenged in this petition and the prior art discussed herein.
`
`25.
`
`I also reviewed the Patent Owner’s preliminary response filed in the
`
`earlier IPR in preparing this declaration. In its response, the Patent Owner argued
`
`that “trimming” means “adjusting.” Ex. 1007, 20. The Patent Owner also
`
`previously proposed that “settable control element” should mean “a circuit
`
`element, the impedance of which can be programmed, adjusted, or set.” Id. at 23.
`
`Patent Owner previously argued that this “settable control element” must be “part
`
`of an ‘interface device.’” Id. at 21. Although I believe that explicit construction of
`
`these terms is not necessary as a person of skill in the art would reasonably
`
`understand and be able to apply these terms without construction, I have
`
`nonetheless applied the constructions proposed by the Patent Owner in my analysis
`
`of the challenged claims and the prior art discussed herein.
`
`
`
`
`
`
`
`11
`
`
`
`VII. Application of prior art to challenged claims
`
` GROUND 1: Claims 14 and 16-18 are anticipated by Volk 450
`
`under 35 U.S.C. § 102
`
`Overview of Volk 450
`
`26. Volk 450 describes a semiconductor device that includes an on-chip
`
`trimming unit for adjusting the impedance of an interface device. This
`
`semiconductor device can be seen in Figure 3:
`
`
`
`
`
`12
`
`
`
`27. As shown in Figure 3, the semiconductor device of Volk 450 includes
`
`3 major components: (1) a driver 52 which drives data off the device to a receiver,
`
`(2) a tuner 72 that senses the voltage signal and adjusts the impedance of the driver
`
`52, and (3) an RCOMP controller 64 that programs the initial impedance of the
`
`drivers and provides a reference voltage. See Ex. 1004, 2:22-25 (“FIG. 3 shows a
`
`driver system 50 configured to transmit data on bus line 58 to a receiver with pull-
`
`up impedance, such as receiver 18 shown in FIG. 1a.”); id., 3:31-34 (“Tuner 72
`
`includes a comparator 90, which receives the feedback voltage 60 as one input and
`
`the regulated VSWING voltage 84 as another input.”); id., 3:16-17 (“RCOMP
`
`controller 64 initially sets pull-down driving element 82 impedance”).
`
`28. A transmitting semiconductor device from Volk 450 transmits data
`
`over a data line or “bus” to a receiving semiconductor device, as shown below:
`
`
`
`13
`
`
`
`
`
`
`
`See also Ex. 1004, 1:47-50 (“FIG. la and lb are diagrams showing typical parallel
`
`interfaces. In parallel interface 10 shown in FIG. la, a driver 12 in a sending circuit
`
`14 transmits data along a bus line 16 to a receiver 18 in a receiving circuit 20.”).
`
`29. Volk 450’s driver 52 and tuner 72 are designed such that the
`
`“impedance of the driver element is dynamically adjustable.” Id., Abstract. To
`
`adjust the impedance, the voltage on the data line is fed back to tuner 72. Id., 3:30-
`
`31. Tuner 72 has a comparator that compares the voltage on the data line (“voltage
`
`60”) with a reference voltage (“VSWING”) provided by the “RCOMP Controller.”
`
`Id., 3:31-34. The comparator and these connections are shown in Figure 3 below:
`14
`
`
`
`
`
`
`
`
`
`30. Based on these inputs, the comparator determines which of the data
`
`line and reference voltage “is higher, and produces an error signal 92.” Id., 3:35-
`
`44. The signal is sent to the tuner controller, which uses the signal to determine
`
`whether the adder should be updated. Id., 3:45-52. Adjusting the value in the
`
`adder results in an adjustment to the impedance of the interface device. See id.
`
`This in turn adjusts the voltage on the data line, and the process repeats until the
`
`
`
`15
`
`
`
`tuner adjusts the data line voltage to match the reference voltage as close as
`
`possible. Ex. 1004, 3:56-59.
`
`Application of Prior Art to Challenged Claims
`
`[14.0]: A semiconductor device comprising:
`
`31.
`
`In my opinion, Volk 450 discloses the claimed semiconductor device.
`
`Specifically, the semiconductor device shown in Figure 3 above (which shows “a
`
`block diagram of a driver system”) maps to the claimed semiconductor device. See
`
`Ex. 1004, 1:31-32. A person of skill in the art would understand that the driver
`
`system disclosed by Volk is a semiconductor device because it is described as
`
`including “a pull-up driver element 80 and a pull-down driver element 82.” An
`
`example driver element 82 is shown in Figure 4. Id., 4:8-11 (“FIG. 4 is a diagram
`
`of an exemplary programmable pull-down driver element 82.”). Figure 4 is
`
`described as including a “set of n-channel metal oxide semiconductor field effect
`
`transistors (MOSFETs) 106 are arrayed in parallel between terminals 102 and
`
`104.” Id., 4:9-12.
`
`32. The MOSFET semiconductors of Volk 450 are shown below:
`
`
`
`16
`
`
`
`
`
`33. Additionally, the driver system of Volk 450 includes Predriver and
`
`Logic 54, tuner 72 (including Tuner Controller 100 with memory 96), and RCOMP
`
`Controller 64 (which receives a clock signal 94) – all of which are semiconductors
`
`and further confirm that the driver system 50 of Volk 450 is a “semiconductor
`
`device.” These elements are each shown below in Figure 3:
`
`
`
`17
`
`
`
`
`
`
`
` [14.1]: at least one interface device having a settable control element;
`
`34.
`
`In my opinion, the driver 56 of Volk 450 teaches the claimed interface
`
`device that has a settable control element.
`
`
`
`18
`
`
`
`35. As noted above, I reviewed the PTAB’s prior construction of
`
`“interface device.” In my opinion, the driver elements 56 meet the PTAB’s prior
`
`construction because the driver 56 of Volk 450 is associated with an interface. In
`
`particular, the drivers in Volk 450 are associated with a “typical parallel interface,”
`
`such as parallel interface 10 shown in Figure 1A (reproduced below).
`
`
`As illustrated above, the parallel interface 10 includes a driver 12 in a sending
`
`circuit 14 which “transmits data along a bus line 16 to a receiver 18.” Ex. 1004,
`
`1:46-50. As such, the interface in Volk 450 comprises a driver and a bus line that
`
`connects to a receiver.” Volk 450 explains that driver system 50 (including drivers
`
`56) can be used with a parallel interface like that shown in Figure 1a, explaining
`
`that “FIG. 3 shows a driver system 50 configured to transmit data on bus line 58 to
`
`a receiver with pull-up impedance, such as receiver 18 shown in FIG. 1a.” Id.,
`
`2:22-25.
`
`
`
`19
`
`
`
`36. The bus line 58 and its connection to driver 56 can be seen in Figure
`
`3:
`
`
`Accordingly, in my view, the drivers 56 are associated with the interface as the
`
`Board’s construction requires.
`
`37. Moreover, the driver 56 (the interface device) is associated with an
`
`interface that is between the semiconductor device housing the interface device and
`
`another device external to the semiconductor device, as required by the Board’s
`
`construction. In particular, Volk 450 discloses a “device comprising a driver
`
`
`
`20
`
`
`
`configured to transmit a signal on a bus line” to another device that acts as the
`
`receiver of the data. Id., Abstract; 1:47-50 (“FIG. la and lb are diagrams showing
`
`typical parallel interfaces. In parallel interface 10 shown in FIG. la, a driver 12 in a
`
`sending circuit 14 transmits data along a bus line 16 to a receiver 18 in a receiving
`
`circuit 20.”); claims 1, 5, and 9; Figs. 1A and 1B:
`
`transmitting
`devices with
`a “Driver”
`
`
`
`“Receiver”
`devices with
`a termination
`
`
`38. As I noted previously, Volk 450 specifically states that the driver
`
`system 50 is “configured to transmit data on bus line 58 to a receiver … such as
`
`receiver 18 as shown in FIG. 1a.” Ex. 1004, 2:22-25. As can be clearly seen, the
`
`receiver 18 is external from the driver 12 shown in Figure 1a and connected via the
`
`
`
`21
`
`
`
`bus line 16. When, as Volk 450 explicitly describes, driver system 50 (and thus
`
`driver 56) is used to transmit data over bus line 58 to receiver 18, it is undeniably
`
`sending data over the interface to a receiver that is external to the driver system 50.
`
`39. Volk 450 provides additional detail regarding the operation of drivers
`
`that further show that the drivers 56 transmit to a device external to the driving
`
`system 50, which I detail below. In particular, Volk 450 explains that “[a] driver is
`
`a digital electronic circuit for holding a binary value, and communicating it to
`
`other circuits to which it is connected. The binary value is represented by a
`
`voltage level. It is common to connect a driver to a data bus for communicating
`
`the binary value to a receiving circuit by ‘driving’ the bus to a desired voltage
`
`level.” Id., 1:7-12.
`
`40.
`
`In my opinion, the interface device of Volk 450 also satisfies the
`
`“settable control element.” In particular, according to Volk 450, “[d]river elements
`
`56 comprise a pull-up driver element 80 and a pull-down driver element 82.” Id.,
`
`2:29-40. The pull-down driver element 82 is annotated in the version of Figure 3
`
`shown below:
`
`
`
`22
`
`
`
`41. Volk 450 explains that “[t]he impedance of pull-up driver element 80
`
`and the impedance of pull-down driver element 82 are programmable… To
`
`facilitate the dynamic adjustment of the output impedance of driver system 50,
`
`the impedance of pull-up driver element 80 and the impedance of pull-down driver
`
`
`
`
`
`23
`
`
`
`element 82 are electronically adjustable.” Id., 2:29-40 (emphasis added); see also
`
`Fig. 5. This “adjustable” and “programmable” impedance maps to the “settable
`
`control element” recited in the ’325 patent.
`
`42. The “Pull-Down Driver Element” (illustrated in Figure 3, shown
`
`above) includes “[a] set of n-channel metal oxide semiconductor field-effect
`
`transistors (MOSFETs) 106 [that] are arrayed in parallel between terminals 102
`
`and 104. Terminal 102 is connected to output bus line 58, and terminal 104 is
`
`connected to circuit ground 32.” Id., 4:9-13.
`
`43. Fig. 4 shows this in action:
`
`driver element
`with MOSFETS
`
`
`Specifically, by selectively enabling the MOSFETs, the impedance of the output
`
`driver can be made “adjustable” and “programmable.” Id., 4:9-16 (“The number
`24
`
`
`
`
`
`and values of MOSFETs 106 that are turned on when pull-down driver element
`
`100 is enabled determines the impedance between terminals 102 and 104.”)
`
`(emphasis added).
`
`44.
`
`In my opinion, Volk 450’s driver elements with “adjustable,”
`
`“programmable” output impedances satisfy the PO’s previously asserted
`
`construction of “settable control element.” Volk 450 is clear that the driver
`
`element’s impedance may be programmed and adjusted. See Ex. 1004, 2:30-40
`
`(“The impedance of pull-up driver element 80 and the impedance of pull-down
`
`driver element 82 are programmable… To facilitate the dynamic adjustment of
`
`the output impedance of driver system 50, the impedance of pull-up driver
`
`element 80 and the impedance of pull-down driver element 82 are electronically
`
`adjustable.”) (emphasis added).
`
`45.
`
`In fact, the driver elements 56 disclosed by Volk 450 are the same
`
`type of “output driver” recited by the ’325 patent as one of two exemplary
`
`“interface devices.” Ex. 1001, 3:18-20 (“a method for trimming interface devices
`
`such as output drivers and terminations in semiconductor devices”). The “output
`
`impedance” of the driver discussed above for Volk 450 is the same parameter
`
`disclosed by the ’325 patent as the “settable control element” of the interface
`
`device: “[a] first such interface parameter is the impedance of the output drivers
`
`
`
`25
`
`
`
`(OCD-off chip driver), which a semiconductor device uses to effect a write access
`
`to the data bus, or to output data signals to the data bus.” Id., 1:42-45.
`
`[14.2]: a trimming register connected to said control element; and
`
`46.
`
`In my opinion, Volk 450 discloses a trimming register connected to
`
`the control element.
`
`47. A register is a circuit “with memory elements that can store from a
`
`few to millions of bits of coded information…” See Ex. 1011, definition of
`
`“register circuit.” As the ’325 patent explains, the “value in the trimming register
`
`14 is taken as a basis for altering the control elements 12, 17, for example, by
`
`increasing an impedance in stages.” Ex. 1001, 7:34-37. The ’325 patent does not
`
`provide any structure for the trimming register 14 other than its ability to store the
`
`value that will be used to trim the impedance, so a person of skill would
`
`understand that the claimed register refers to a generic register circuit used to
`
`perform the function of storing impedance values.
`
`48. Volk 450 describes an Adder 98 that is connected to the “Pull-Down
`
`Driver Element” (control element). Id., Figure 3. In particular, Adder 98 (shown
`
`below) is described as being configured to “digitally increase or decrease digital
`
`pull-down control signal 70, thereby increasing or decreasing the impedance of
`
`pull-down driver element 82.” Id., 3:48-52. “Tuner controller 100 can make
`
`adjustments in large or small increments with adder 98.” Id.
`
`
`
`26
`
`
`
`
`49. The adder provides a “digital pull-down control signal 70” (depicted
`
`above), and Adder 98’s value is set based on information from the trimming unit
`
`portion of “tuner controller 100.” Id., 3:48-52. To store that information, the
`
`adder 98 either is or includes a register that stores a value that is used to trim or
`
`adjust the impedance of the driver element. Id. The value stored in the adder is
`
`based on the input received from the trimming unit, which I will discuss below
`
`with reference to element 14.3.
`
`
`
`27
`
`
`
`[14.3]: a trimming unit for writing to said trimming register based on a
`
`measured variable detected on said interface device;
`
`50. Volk 450 also discloses a tuner 72 in the semiconductor device for
`
`writing to the trimming register based on a measured variable detected on the
`
`interface device. First, as I discussed above, the tuner controller 100 within the
`
`tuner 72 is configured to program (which a person of skill would understand to
`
`mean “write to”) the adder 98 when it determines a need to adjust the impedance of
`
`the driver 56. Ex. 1004, 3:47-62 (noting that the “tuner controller 100 includes an
`
`adder 98 to digitally increase or decrease the impedance of pull-down driver
`
`element 82.”).
`
`51. The remaining portion of the tuner 72 is described as making the
`
`adjustments to the impedance (via the adder 98) based on a measured variable
`
`detected on the interface device. In particular, Volk 450 “presents a method of
`
`electronically adjusting the impedance of the driver element to regulate the swing
`
`voltage on the bus line.” Id., Abstract (emphasis added); see also id., 1:5-6 (“This
`
`invention relates to dynamic output impedance adjustment.”); 2:7-9 (“If signal
`
`reflections are minimized, the swing voltage can be safely regulated by
`
`dynamically adjusting the output impedance of the driver.”). Volk 450 describes
`
`that this “adjusting” or trimming is needed “[t]o compensate for shifts in the swing
`
`voltage” that occur when the “terminating impedance” (the impedance of the
`
`
`
`28
`
`
`
`receiving device) is “different from the expected value,” or due to impedance
`
`changes from “loading at the receiver, heating or other factors.” Id., 3:21-29.
`
`52. To achieve the desired compensation, the Tuner 72 “dynamically
`
`adjust[s]” “the impedance of pull-down driver element 82.” Id., 2:44-47. To
`
`perform this adjustment, the voltage on the data line is fed back to tuner 72. Id.,
`
`3:30-31 (“Dynamic compensation is accomplished by feeding back the voltage 60
`
`transmitted on bus line 58 to tuner 72.”);
`
`53. This is shown in Fig. 3 (annotated) below:
`
`
`
`29
`
`
`
`
`
`54. The tuner includes a comparator, which is part of the trimming unit.
`
`The comparator compares the voltage on the data line (“voltage 60”) with a
`
`reference voltage (“VSWING”) provided by the “RCOMP Controller.” Id., 3:31-
`
`34 (“Tuner 72 includes a comparator 90, which receives the feedback voltage 60 as
`
`one input and the regulated VSWING voltage 84 as another input.”). The “voltage
`
`60” is the recited “measured variable detected on [the] interface device” of claim
`
`14. The interface device includes driver elements 56, and the measured variable is
`
`measured right from the data line that connects to the driver elements.
`
`55.
`
`In operations, the comparator of the trimming unit compares its inputs
`
`to determine which of the data line and reference voltage “is higher, and produces
`
`an error signal 92.” Id., 3:35-44 (“Comparator 90 compares the two input voltages
`
`60 and 84 and determines which of the two is higher, and produces an error signal
`
`92. The polarity of comparator 90 shown in FIG. 3 is arbitrary, but for illustrative
`
`purposes VSWING voltage 84 is applied to the noninverting input. Consequently,
`
`when the voltage 60 transmitted on bus line 58 is the higher of the two voltages,
`
`comparator 90 generates a voltage LOW error signal, and when the regulated
`
`VSWING voltage 84 is higher, comparator 90 generates a voltage HIGH error
`
`signal 92.”).
`
`56. This error signal is sent to the tuner controller, which includes “adder
`
`98.” The tuner controller 100 writes to the adder 98 by incrementing or
`
`
`
`30
`
`
`
`decrementing it as appropriate based on the error signal. In other words, based on
`
`whether the data line voltage is higher or lower than the reference voltage.
`
`Because adder 98 is connected to the pull-down driver element, and because it
`
`controls the impedance of that element, adjusting the adder results in an adjustment
`
`to the impedance of the interface device. See id., 3:45-51. This in turn adjusts the
`
`voltage on the data line, and the process repeats until the tuner adjusts the data line
`
`voltage to match the reference voltage as close as possible. Ex. 1004, 3:56-59
`
`(“By repeatedly increasing or decreasing the impedance, tuner 72 ‘homes in’ on
`
`the impedance of pull-down driver element 82 that produces a voltage LOW signal
`
`as close to VSWING 84 as possible.”).
`
`57. Figure 5 shows the steps used to perform this process:
`
`
`
`31
`
`
`
`
`
`
`
`58. As shown above, in step 122 the voltage on the data bus, which also
`
`connects to the driver (interface device) is measured. Id. If the data bus voltage is
`
`too low, then the tuner will calculate an impedance adjustment (if an adjustment is
`
`not pending) and will then adjust the impedance. The voltage on the data bus is
`
`
`
`32
`
`
`
`then measured again, and the process repeats, adjusting the impedance as needed if
`
`the voltage is too high or too low based on the comparison with the reference
`
`voltage.
`
` [14.4]: said trimming unit connected to said interface device and said trimming
`
`register.
`
`59.
`
`I incorporate by reference my discussion above with respect to
`
`elements [14.0]- [14.3].
`
`60. The trimming unit of Volk 450 is connected to the trimming register
`
`(adder 98) and the interface device (driver elements 56, including pull-down driver
`
`
`
`33
`
`
`
`element 82), as shown in Figure 3:
`
`the trimming unit
`(red) is connected to
`the interface device
`(blue) and the
`trimming register
`(green)
`
`
`
`[16]: The semiconductor device according to claim 14, wherein said trimming
`
`unit includes a reference voltage device and a voltage divider for producing a
`
`nominal voltage.
`
`61. As I discuss above with reference to that claim, Volk 450 discloses a
`
`semiconductor device according to claim 14.
`
`
`
`34
`
`
`
`62.
`
`In my opinion, Volk additionally teaches the added elements of claim
`
`16, namely that “reference voltage device” and the “voltage divider for producing a
`
`nominal voltage.”
`
`63. Specifically, Volk 450 discloses that the “RCOMP controller” forms a
`
`voltage divider that is used to produce VSWING. Ex. 1004, 3:6-15 (“A voltage
`
`divider is formed by resistor 86 and a copy 65 of pull-up driving element 80 in
`
`RCOMP controller 64 coupled to RCOMP line 88. The voltage divider produces
`
`an RCOMP input voltage 88 that is equal to VSWING voltage 84 when the
`
`impedance of the pull-up driving element 65 is at a desired value. The target
`
`impedance of the pull-down driving element 82 is set in a similar manner, using a
`
`copy (not shown) of driving element 82 and another voltage divider (not shown) in
`
`RCOMP controller 64.”). As I mentioned above (element 14.3), “VSWING” is the
`
`reference voltage or “nominal voltage” that the trimming unit compares with the
`
`data bus voltage.
`
`[17.0]: The semiconductor device according to claim 14, wherein: said trimming
`
`unit has a comparator unit for providing an output signal obtained by comparing
`
`a nominal voltage with a measurement voltage produced in said interface device;
`
`and
`
`64. As I discuss above with reference to
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
