February 20, 2013
`
`
`BY EDIS
`The Honorable Thomas B. Pender
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street SW, Room 317
`Washington, DC 20436
`
`337-TA-825: Certain Silicon Microphone Packages and Products Containing Same
`Re:
`
`
`Dear Judge Pender:
`
`I write on behalf of Complainant Knowles Electronics, LLC, in connection
`with the above-referenced investigation, to inform the Administrative Law Judge that the
`United States District Court for the Northern District of Illinois issued an opinion yesterday,
`on a motion for reconsideration, construing the claim term “attaching a plurality of package
`covers” in method claim 21 of the ‘049 Patent to mean “attaching more than one package
`cover.” See Knowles Electronics, LLC v. Analog Devices Inc., No. 11 C 6804 (N.D. Ill. Feb.
`19, 2013) (Lefkow, J.). The opinion is enclosed.
`
`
`
`Enclosure
`cc: Counsel of Record
`
`Sincerely,
`
`/s/ Robert T. Haslam
`
`Robert T. Haslam
`
`

`
`Case: 1:11-cv-06804 Document #: 238 Filed: 02/19/13 Page 1 of 12 PageID #:8932
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`No. 11 C 6804
`
`Hon. Joan H. Lefkow
`
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`
`KNOWLES ELECTRONICS, LLC ,
`
`Plaintiff,
`
` vs.
`
`ANALOG DEVICES INC.,
`
`Defendant.
`
`OPINION AND ORDER
`
`Presently before the court is Knowles Electronics, LLC’s (“Knowles”) motion for
`
`reconsideration of the court’s claim construction ruling. Knowles alleges that Analog Devices
`
`Inc. (“ADI”) infringed, inter alia, claim 21 of United States Patent Number 8,018,049 (the ’049
`
`patent). Claim 21 is directed to the method of constructing a microphone package and states that
`
`construction of the package includes “attaching a plurality of package covers.” The court
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`construed this phrase to mean “attaching a layer comprising a plurality of interconnected
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`package covers.” Dkt. 118 at 3. Knowles seeks reconsideration of that ruling and requests that
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`the court construe the phrase to mean “attaching more than one package cover.” Knowles Mot.
`
`at 13. For the following reasons, Knowles’ motion for reconsideration is granted.
`
`LEGAL STANDARD
`
`Federal Rule of Civil Procedure 54(b) states that a court may reconsider an interlocutory
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`ruling “at any time before the entry of a judgment adjudicating all the claims and all the parties’
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`rights and liabilities.” Fed. R. Civ. P. 54(b). Motions for reconsideration serve the limited
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`purpose to correct manifest errors of law or fact or to present newly discovered evidence.
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`Rothwell Cotton Co. v. Rosenthal & Co., 827 F.2d 246, 251 (7th Cir. 1987). A motion to
`
`

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`Case: 1:11-cv-06804 Document #: 238 Filed: 02/19/13 Page 2 of 12 PageID #:8933
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`reconsider serves an important function where the “court has misunderstood a party, where the
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`court has made a decision outside the adversarial issues presented to the court by the parties,
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`where the court has made an error of apprehension (not of reasoning), where a significant change
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`in the law has occurred, or where significant new facts have been discovered.” Broaddus v.
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`Shields, 665 F.3d 846, 860 (7th Cir. 2011) (citing Bank of Waunakee v. Rochester Cheese Sales,
`
`Inc., 906 F.2d 1185, 1191 (7th Cir. 1990)). The Federal Circuit has also noted that “[d]istrict
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`courts may engage in a rolling claim construction, in which the court revisits and alters its
`
`interpretation of the claim terms as its understanding of the technology evolves.” Jack Guttman,
`
`Inc. v. Kopykake Enter., Inc., 302 F.3d 1352, 1361 (Fed. Cir. 2002). Motions for reconsideration
`
`of a claim construction may be raised at any time during the proceedings. See Bone Care Int’l,
`
`LLC v. Pentech Pharm., Inc., 08-cv-1083, 2010 WL 3023423, at *1 (N.D. Ill. July 30, 2010).
`
`I.
`
`The ’049 Patent
`
`BACKGROUND
`
`Claim 21 of the ’049 patent is a method claim that teaches how to assemble the
`
`microphone package. The claim states,
`
`A method of manufacturing a silicon condenser microphone package comprising:
`
`providing a panel comprising a plurality of interconnected package substrates, where
`each of the plurality of package substrates comprises at least one layer of conductive
`material and at least one layer of non-conductive material;
`
`attaching a plurality of silicon condenser microphone dice to the plurality of package
`substrates, one die to each package substrate;
`
`attaching a plurality of package covers, each comprising at least one layer of
`conductive material, to the panel, one package cover to each of the package
`substrates, where attaching the plurality of package covers to the panel comprises
`electrically connecting the at least one layer of conductive material in the package
`
`2
`
`

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`Case: 1:11-cv-06804 Document #: 238 Filed: 02/19/13 Page 3 of 12 PageID #:8934
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`cover to the at least one layer of conductive material in the corresponding package
`substrate to form a shield against electromagnetic interference; and
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`separating the panel into a plurality of individual silicon condenser microphone
`packages.
`
`Col. 13 ll. 34–Col. 14 ll. 18. The ’049 patent’s abstract also details the microphone package
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`assembly: “[t]he method for manufacturing the silicon condenser microphone package involves
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`placement of a plurality of silicon condenser microphone dies on a panel of printed circuit board
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`material, placement of covers over each of the silicon condenser microphone dies, and then
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`separating the panel into individual packages.” ’049 Patent Abstract.
`
`The Detailed Description of the Invention further elucidates on the scope and the benefits
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`of the invention. First, the Detailed Description states that the invention included multiple
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`embodiments,
`
`While the invention is susceptible of embodiments in many different forms, there is
`shown in the drawings and will herein be described in detail several possible
`embodiments of the invention with the understanding that the present disclosure is
`to be considered as an exemplification of the principles of the invention and is not
`intended to limit the broad aspect of the invention to the embodiments illustrated.
`
`Col. 3 ll. 3–9.
`
`The Detailed Description also identifies the benefits of the invention in that it was capable of
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`mass production of microphone packages,
`
`The benefits of the microphone packages disclosed herein over microphone
`packaging utilizing plastic body/lead frames include the ability to process packages
`in panel form allowing more units to be formed per operation and at much lower
`cost. The typical lead frame for a similarly functioning package would contain
`between 40 and 100 devices connected together. The present disclosure would have
`approximately 14,000 devices connected together (as a panel).
`
`
`3
`
`

`
`Case: 1:11-cv-06804 Document #: 238 Filed: 02/19/13 Page 4 of 12 PageID #:8935
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`Col. 3 ll. 10–17. The specification also describes that the preferred embodiment was for mass
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`assembly of microphone packages where the bottom, side, and top portions of the package were
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`attached simultaneously,
`
`The microphone packages 92 are distributed on the panel 90 in 14 x 24 array, or 336
`microphone packages total. Fewer or more microphone packages may be disposed
`on the panel 90, or on smaller or larger panels. As described herein in connection
`with the various embodiments of the invention, the microphone packages include a
`number of layers, such as top, bottom and side portions of the housing,
`environmental barriers, adhesive layers for joining the portions, and the like. To
`assure alignment of the portions as they are brought together, each portion may be
`formed to include a plurality of alignment apertures 94. To simultaneously
`manufacture several hundred or even several thousand microphones, a bottom layer,
`such as described herein, is provided. A transducer, amplifier and components are
`secured at appropriate locations on the bottom layer corresponding to each of the
`microphones to be manufactured. An adhesive layer, such as a sheet of dry adhesive
`is positioned over the bottom layer, and a sidewall portion layer is positioned over
`the adhesive layer. An additional dry adhesive layer is positioned, followed by an
`environmental barrier layer, another dry adhesive layer and the top layer. The dry
`adhesive layers are activated, such as by the application of heat and/or pressure. The
`panel is then separated into individual microphone assemblies using known panel
`cutting and separating techniques.
`
`Col. 11 ll. 39–63.
`
`II.
`
`The Court’s Claim Construction
`
`In its claim construction ruling, the court noted that “[t]he issue is whether the term
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`‘attaching a plurality of package covers’ in claim 21 of the ’049 patent permits the construction
`
`that each package cover may be added individually to form each package rather than as a single
`
`layer that is later separated into individual package assemblies.” Dkt. 118 at 2. The court first
`
`found that the inventor stated how the benefits of the invention were directed toward mass
`
`production. The inventor stated that those benefits “include the ability to process packages in
`
`panel form allowing more units to be formed per operation and at much lower cost. . . . The
`
`4
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`

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`Case: 1:11-cv-06804 Document #: 238 Filed: 02/19/13 Page 5 of 12 PageID #:8936
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`present disclosure would have approximately 14,000 devices connected together (as a panel).”
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`Id.
`
`The court then looked to the embodiments of the microphone package,
`
`In an embodiment found at 4:4–44 and illustrated in Figures 7–10, a ‘housing is
`formed from layers of materials . . . . [T]he housing includes a top portion 48 and a
`bottom portion 50 spaced by a side portion 52 . . . . Each portion may comprise
`alternating conductive and non-conductive layers.’ (4:35–44.) The portions are
`joined by a sheet of dry adhesive. (Id.) The patent describes the lid as being formed
`in a ‘board’ format. (10:12–19.) Accompanying Table 6 (10:24–36), as well
`describes processing of the top portion in terms of layers. The patent further
`describes drilling ‘a matrix of holes into the lid board’ for the acoustic port into the
`top portion (10:19) and ‘alignment apertures’ to make sure that the panels for each
`package portion align properly. (11:47–52.)
`
`Dkt. 118 at 2. The court concluded that the specification made clear that the cover constituted a
`
`layer instead of a large number of individual covers that are placed on the substrate.
`
`The court found that the ’049 patent’s specification only described one method of
`
`forming a plurality of microphone packages. It recited that the microphone package included a
`
`number of layers, namely a top, bottom, and side portions of the housing attached by adhesive
`
`layers. The court concluded that the “‘plurality of package covers’ in claim 21 is a layer of
`
`material that, once affixed to the side and bottom portions, forms a panel that is later broken into
`
`individual microphone packages.” Dkt. 118 at 3.
`
`ANALYSIS
`
`Knowles argues for reconsideration because Federal Circuit precedent provides that a
`
`claim construction should not be solely confined to a disclosed embodiment in the specification.
`
`ADI argues that the court’s original claim construction was correct and that the ’049 patent
`
`described the claimed invention as a batch manufacturing process where a layer of covers was
`
`applied simultaneously instead of individually.
`
`5
`
`

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`Case: 1:11-cv-06804 Document #: 238 Filed: 02/19/13 Page 6 of 12 PageID #:8937
`
`I.
`
`Timeliness of Knowles’ Argument for Reconsideration
`
`Knowles additionally argues that ADI is untimely in presenting its motion for
`
`reconsideration. The court agrees that the arguments Knowles now advances in reconsideration
`
`of the court’s construction of claim 21 should have been made much earlier in this litigation.
`
`The parties and the court have already expanded significant time and resources in connection
`
`with claim construction. Still, although Knowles is late in presenting its argument, the need to
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`have claims construed correctly to save future resources in this litigation is more important than
`
`strict adherence to schedule. Although ADI may be correct that limited additional discovery will
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`be required, particularly of the expert witnesses, the expense incurred by ADI that would not
`
`have been incurred had the motion been timely, can be shifted to Knowles. The court will thus
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`reconsider its prior ruling in light of Knowles’ arguments to ensure that the construction of claim
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`21 is correct. See Broaddus, 665 F.3d at 860; Jack Guttman, Inc., 302 F.3d at 1361.
`
`II.
`
`The ’049 Patent’s Specification and Claim 21
`
`Claims are construed from the point of view of one of ordinary skill in the art at the time
`
`of filing. Trading Tech. Int’l v. eSpeed Inc., 595 F.3d 1340, 1351 (Fed. Cir. 2010). “[T]he
`
`person of ordinary skill in the art is deemed to read the claim term not only in the context of the
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`particular claim in which the disputed term appears, but in the context of the entire patent,
`
`including the specification.” ICU Med., Inc. v. Alaris Med. Sys., Inc., 558 F.3d 1368, 1374 (Fed.
`
`Cir. 2009) (internal quotation marks omitted). In construing a patent claim, the court should first
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`look to intrinsic evidence, namely the patent itself, including the claims, specification, and
`
`prosecution history. Bell Atl. Network Servs., Inc. v. Covad Comm’n Grp., Inc., 262 F.3d 1258,
`
`1267 (Fed. Cir. 2001). Claims must be read in light of the specification of which they are a part.
`
`6
`
`

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`Case: 1:11-cv-06804 Document #: 238 Filed: 02/19/13 Page 7 of 12 PageID #:8938
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`Phillips v. AWH Corp., 415 F.3d 1303, 1315 (Fed. Cir. 2005) (en banc). The Federal Circuit has
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`recognized a “fine line between reading a claim in light of the specification, and importing a
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`limitation from the specification into the claim.” Arlington Indus., Inc. v. Bridgeport Fittings,
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`Inc., 632 F.3d 1246, 1255 (Fed. Cir. 2011). As such, the court should focus on how a person of
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`ordinary skill would understand the claim “after reading the entire patent.” ICU Med., Inc.,
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`558 F.3d at 1375 (internal quotation marks omitted).
`
`A.
`
`Claim 21
`
`The first step in construing the disputed claim is to start with the language of the claim
`
`itself. Claim 21 delineates the method by which the package is constructed. The inventor
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`describes that the bottom portion of the package comprises a “plurality of interconnected
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`package substrates.” Col. 13 ll. 36–37. The inventor next describes attaching the microphone
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`dice to the substrate “one die to each package substrate,” a process that claims attaching one die
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`at a time. Col. 14 ll. 5–6. The inventor next describes the connection of the cover over the
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`microphone die. The inventor states in part that the next step involves attaching “a plurality of
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`package covers, each comprising at least one layer of conductive material, to the panel, one
`
`package cover to each of the package substrates.” Col. 14 ll. 7–9. Notably, unlike the bottom
`
`layer, the inventor did not describe the package cover as interconnected. Rather, similarly to the
`
`step for placing individual microphone dice on the substrate, the inventor describes attaching “a
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`plurality of package covers . . . to the panel, one package cover to each of the package
`
`substrates.” Col. 14 ll. 8–9. Last, the inventor describes how after forming a panel of
`
`microphone packages the next step was to separate the panel into individual microphone
`
`packages. Col. 14 ll. 17–18.
`
`7
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`

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`Case: 1:11-cv-06804 Document #: 238 Filed: 02/19/13 Page 8 of 12 PageID #:8939
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`B.
`
`The Specification
`
`The next step in construing the disputed term is to look to the specification. The written
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`description of the specification describes an embodiment directed toward mass production of
`
`microphone packages. Column three details that the “present disclosure would have
`
`approximately 14,000 devices connected together (as a panel).” Col. 3 ll. 17–18. As a means by
`
`which to mass produce the microphone packages, the written description further details an
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`assembly where the various components of the package are attached together using various
`
`adhesives.
`
`Column three also describes three embodiments of the microphone package. The
`
`inventor describes the microphone package as including a “substrate 14, a back volume or air
`
`cavity 18, which provides a pressure reference for the transducer 12, and a cover 20.” Col. 3 ll.
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`40–43. The embodiments in column three further detail that the “substrate 14 may be formed of
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`FR-4 material allowing processing in circuit board panel form, thus taking advantage of
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`economies of scale in manufacturing.” Col. 3 ll. 43–45. The embodiments in column 3 do not
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`describe the cover of the package as being a panel, see Col. 3 ll. 63–64, neither do they elucidate
`
`whether the cover is attached as an interconnected layer or one at a time.
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`Other parts of the specification indicate that the top portion of the package comprises a
`
`series of interconnected covers. Column 10 details the construction of the multi-layer “top
`
`portion” describing the top layer constituting the cover as a “lid board” and that a “matrix of
`
`holes is drilled into the lid board.” Col. 10 ll. 15–20. Column 11 describes a process to
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`“simultaneously manufacture several hundred or even several thousand microphones.” Col. 11
`
`ll. 49–50. Column 11 details how the package consists of various layers, including “a top,
`
`8
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`

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`Case: 1:11-cv-06804 Document #: 238 Filed: 02/19/13 Page 9 of 12 PageID #:8940
`
`bottom, and side portions of the housing, environmental barriers, adhesive layers for joining the
`
`portions, and the like.” Col. 11 ll. 45–47. In addition, column 11 provides a means for aligning
`
`the bottom, side, and top portions together, which indicates that the inventor envisioned that the
`
`various portions would be connected at the same time. Specifically, column 11 states that “each
`
`portion may be formed to include a plurality of alignment apertures” in order to “assure
`
`alignment of the portions as they are brought together.” Col. 11 ll. 47–49. This further supports
`
`the notion that the top portion was a series of interconnected covers attached at the same time.
`
`The preferred embodiment in the specification thus discloses mass production where the layers
`
`comprising the microphone package are panels connected to each other and then separated to
`
`form individual microphone packages. The benefit of the invention regarding mass production
`
`of the microphone package further supports this finding that the preferred embodiment describes
`
`panels of materials that are later broken into individual parts.
`
`C.
`
`Construing Claim 21
`
`Claim 21 includes language indicating that the inventor claimed a method where the
`
`covers of the microphone packages could be placed individually one at a time. The preferred
`
`embodiment in the specification, however, describes the method as directed toward mass
`
`production and indicates that the bottom and top portions of the package are layers connected to
`
`one another. As the court already found, the preferred embodiment describes the top portion of
`
`the package as “a layer of material that, once affixed to the side and bottom portions, forms a
`
`panel that is later broken into individual microphone packages.” Dkt. 118 at 3. The preferred
`
`embodiment thus describes a process that is not present in claim 21; namely, configuring the
`
`9
`
`

`
`Case: 1:11-cv-06804 Document #: 238 Filed: 02/19/13 Page 10 of 12 PageID #:8941
`
`microphone package with a preconstructed top layer that is attached to a substrate of
`
`interconnected panels.
`
`Thus, the next step is to determine how a person of ordinary skill in the art would view
`
`the specification’s preferred embodiment in light of the language of claim 21 for a method where
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`the cover of the package is a single layer attached at one time. The Federal Circuit has noted the
`
`difficulty in determining the scope of a claim that is broader than the preferred embodiment in
`
`the specification. Compare Woodrow Woods v. DeAngelo Marine Exhaust, Inc., 692 F.3d 1272,
`
`1283 (Fed. Cir. 2012) (“[W]here the specification makes clear that the invention does not include
`
`a particular feature, that feature is deemed to be outside . . . the patent, even though the language
`
`of the claims, read without reference to the specification, might be considered broad enough to
`
`encompass the feature in question.”) (internal quotation marks omitted) with Liebel-Flarsheim
`
`Co. v. Medrad, Inc., 358 F.3d 898, 906 (Fed. Cir. 2004) (“Even when the specification describes
`
`only a single embodiment, the claims of the patent will not be read restrictively unless the
`
`patentee has demonstrated a clear intention to limit the claim scope using words or expressions
`
`of manifest exclusion or restriction.”) (internal quotation marks omitted).
`
`The Federal Circuit has held that limitations in the specification not otherwise present in
`
`the disputed claim limit that claim term “when a patentee sets out a definition and acts as his
`
`own lexicographer, or when the patentee disavows the full scope of the claim term either in the
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`specification or during prosecution.” Woodrow Woods, 692 F.3d at 1283 (internal quotation
`
`marks omitted). There is no indication that the patentee acted as his own lexicographer giving
`
`the disputed phrase “attaching a plurality of package covers” a meaning that would support
`
`construing the cover of the package as an interconnected layer.
`
`10
`
`

`
`Case: 1:11-cv-06804 Document #: 238 Filed: 02/19/13 Page 11 of 12 PageID #:8942
`
`While the preferred embodiment describes a method of mass manufacture, that claim 21
`
`does not describe the top layer as a series of interconnected covers demonstrates that the inventor
`
`did not intend to limit the claim to the preferred embodiment. Indeed, the first paragraph of the
`
`written description provides in part that although there were several written embodiments of the
`
`invention, the “present disclosure is to be considered as an exemplification of the principles of
`
`the invention and is not intended to limit the broad aspect of the invention to the embodiments
`
`illustrated.” Col. 3 ll. 6–9.1 Nor does the specification indicate that the inventor intended to
`
`limit claim 21 to the preferred embodiment described in Column 11 by disclaiming a method
`
`where the package covers could be attached individually instead of simultaneously as an
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`interconnected layer. See Thorner v. Sony Computer Entm’t Am., LLC, 669 F.3d 1362, 1366–67
`
`(Fed. Cir. 2012) (“To constitute disclaimer, there must be a clear and unmistakable disclaimer.”);
`
`Retractable Techs., Inc. v. Becton, Dickinson & Co., 653 F.3d 1296, 1306 (Fed. Cir. 2011) (“To
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`disavow claim scope, the specification must contain expressions of manifest exclusion or
`
`restriction, representing a clear disavowal of claim scope.”) (internal quotation marks omitted).
`
`In addition, the abstract details that the method for manufacturing the microphone
`
`package includes placing microphone dies on a panel, placing covers over the microphone dies,
`
`and then separating the panel into individual packages. Unlike the bottom portion of the
`
`package, the abstract does not describe the covers as a panel, which indicates that the covers
`
`could be both attached as interconnected layer and individually. See Hill-Rom Co. v. Kinetic
`
`Concepts, Inc., 209 F.3d 1337, 1341 n.* (Fed. Cir. 2009) (“We have frequently looked to the
`
`1 This language was incorporated into the first paragraph of the specification for all the patents in
`the ’049 patent family.
`
`11
`
`

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`Case: 1:11-cv-06804 Document #: 238 Filed: 02/19/13 Page 12 of 12 PageID #:8943
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`abstract to determine the scope of the invention, and we are aware of no legal principle that
`
`would require us to disregard that potentially helpful source of intrinsic evidence as to the
`
`meaning of claims.”) (citations omitted). A person of ordinary skill in the art reading the ’049
`
`patent could find that claim 21 encompassed attaching covers individually to the package
`
`substrate although the preferred embodiment was for mass manufacture where the package
`
`covers were attached simultaneously. The court thus declines to limit claim 21’s scope to an
`
`embodiment directed toward mass production when the language of claim 21 indicates that a
`
`person of ordinary skill in the art would recognize that the inventor additionally claimed
`
`individual placement of the package covers.
`
`CONCLUSION AND ORDER
`
`Knowles’ motion for reconsideration is granted as stated herein. This case will be called
`
`for a status hearing on March 19, 2013 at 8:30 a.m. and to discuss settlement and/or alternative
`
`dispute resolution.
`
`Dated: February 19, 2013
`
`
`
`Enter: _____________________________
` JOAN HUMPHREY LEFKOW
` United States District Judge
`
`12
`
`

`
`In the Matter of Certain Silicon Microphone
`Packages and Products Containing Same
`
`
`
`CERTIFICATE OF SERVICE
`
`Inv. No.: 337-TA-825
`
`
`
`
`
`
`
`I, Melissa Sackin, certify that on February 20, 2013, copies of the foregoing LETTER
`TO ALJ PENDER ENCLOSING OPINION were delivered, pursuant to U. S. International
`Trade Commission regulations, to the following interested parties as indicated:
`
`The Honorable Lisa Barton
`Acting Secretary to the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW
`Washington, DC 20436
`
`The Honorable Thomas B. Pender
`Administrative Law Judge
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW
`Washington, DC 20436
`
`Steven M. Bauer
`PROSKAUER ROSE LLP
`One International Place
`Boston, MA 02110
`
`Sten Jensen
`Jordan L. Coyle
`ORRICK, HERRINGTON & SUTCLIFFE, LLP
`1152 15th Street, NW
`Washington, DC 20005
`
`
`Via EDIS
`
`Via email and via overnight delivery:
`Gregory.Moldafsky@usitc.gov
`Rebecca.Barbisch@usitc.gov
`
`Counsel for Respondents Analog Devices,
`Inc., Amkor Technology Inc. and Avnet Inc.
`
`Via email:
`Analog-825@orrick.com
`
`
`/s/ Melissa Sackin
`Melissa Sackin
`Senior IP Litigation Specialist
`COVINGTON & BURLING LLP
`1201 Pennsylvania Ave., NW
`Washington, DC 20004-2401
`msackin@cov.com
`202.662.6677
`
`Certificate of Service Page 1 of 1