Paper No.
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`INTELLECTUAL VENTURES MANAGEMENT, LLC
`Petitioner
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`v.
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`Patent of XILINX, INC.
`Patent Owner
`___________________
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`Case IPR2012-00018
`Patent 7,566,960
`Title: INTERPOSING STRUCTURE
`_____________________
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`PATENT OWNER’S SUBSTITUTE MOTION TO AMEND
`BY XILINX UNDER 37 C.F.R. § 42.121
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`Patent Owner’s Substitute Motion to Amend
`IPR2012-00018
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`TABLE OF CONTENTS
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`INTRODUCTION ..................................................................................................... 1
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`I. Claim Listing...................................................................................................... 1
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`II. Support in Specification for Proposed Amendments ......................................... 5
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`A. Proposed Claim 14 ........................................................................................ 5
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`B. Proposed claim 15 ......................................................................................... 7
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`C. Proposed claim 16 ......................................................................................... 7
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`D. Proposed claim 17 ......................................................................................... 7
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`E.
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`F.
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`Proposed claim 18 ......................................................................................... 8
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`Proposed claim 19 ......................................................................................... 9
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`G. Proposed claim 20 .......................................................................................10
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`H. Proposed claim 21 .......................................................................................10
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`I.
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`Proposed claims 22-26 ................................................................................11
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`III. Proposed Amendments Obviate the Grounds of Rejection ............................12
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`A. Grounds 6 & 7 .............................................................................................12
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`1. Claim 14 ...................................................................................................12
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`2. Claim 15 ...................................................................................................14
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`3. Claim 16 ...................................................................................................14
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`4. Claim 17 ...................................................................................................15
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`5. Claim 18 ...................................................................................................15
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`6. Claim 19 ...................................................................................................15
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`7. Claim 20 ...................................................................................................16
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`8. Claim 22 ...................................................................................................17
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`9. Claim 23 ...................................................................................................17
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`10. Claim 25 ...................................................................................................17
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`11. Claim 26 ...................................................................................................17
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`–ii–
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`Patent Owner’s Substitute Motion to Amend
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`12. Dependent Claims ....................................................................................18
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`B. Grounds 8 & 9 .............................................................................................18
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`1. Claim 14 ...................................................................................................18
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`2. Claim 22 ...................................................................................................19
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`3. Dependent Claims ....................................................................................19
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`IV. Conclusion ......................................................................................................20
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`–iii–
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`INTRODUCTION
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`Contingent upon a Board determination that the original patent claims 1-13
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`are unpatentable, Patent Owner Xilinx, Inc. (“Xilinx”) moves to amend the claims
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`of U.S. Patent No. 7,566,960 (“the ’960 Patent”) under 35 U.S.C. § 316(a)(9) and
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`37 C.F.R. § 42.121. A listing of the proposed amendments is provided below.
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`I.
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`Claim Listing
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`Claims 1-13 (replaced by proposed substitutes).
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`14.
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`(Proposed substitute for original claim 1) An assembly, comprising:
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`an integrated circuit die having an array of micro-bumps disposed on a
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`surface of the integrated circuit die in a first pattern;
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`an integrated circuit package having an array of landing pads disposed on an
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`inside surface of the integrated circuit package in a second pattern and an array of
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`solder balls disposed on an outside surface of the integrated circuit package,
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`wherein the first pattern and the second pattern are substantially identical
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`patterns; and
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`[[an]] a plurality of tiled interposing structure structures disposed inside the
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`integrated circuit package between the integrated circuit die and the inside surface
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`of the integrated circuit package, at least one of the interposer interposing
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`structures electrically coupling a respective first micro-bump in a first position in
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`the array of micro-bumps to a respective first landing pad located opposite to the
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`Patent Owner’s Substitute Motion to Amend
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`first position and to a second landing pad in the array of landing pads.
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`Claim 15 (Proposed substitute for original claim 2): The assembly of claim
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`[[1]] 14, wherein the interposing structures are held together using an elastomer a
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`line extending through the first micro-bump in a direction orthogonal to the surface
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`of the integrated circuit does not extend through the second landing pad of the
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`integrated circuit package.
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`Claim 16 (Proposed substitute for original claim 3): The assembly of claim
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`[[2]] 14, wherein the surface of the integrated circuit die is a major surface of the
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`integrated circuit die, and wherein the interposing structure has structures have a
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`collective major surface, and wherein the major surface of the integrated circuit die
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`and the collective major surface of the interposing structure structures have
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`roughly identical surface areas.
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`Claim 17 (Proposed substitute for original claim 4): The assembly of claim
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`[[3]] 14, wherein at least one of the interposing structure structures includes
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`comprises a first conductive layer corresponding to a first capacitor for a first
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`power supply and a second conductive layer corresponding to a second capacitor
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`for a second power supply different from the first power supply no transistor and
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`no PN junction.
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`Claim 18 (Proposed substitute for original claim 5): The assembly of claim
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`[[4]] 14, wherein at least one of the interposing structure includes structures
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`Patent Owner’s Substitute Motion to Amend
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`comprises a first conductive layer for a first ground and a second conductive layer
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`for a second ground different from the first ground an array of micro-bumps,
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`wherein the array of micro-bumps of the interposing structure has a pattern that is
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`substantially identical to the second pattern of the landing pads on the inside
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`surface of the integrated circuit package.
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`Claim 19 (Proposed substitute for original claim 6): The assembly of claim
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`[[5]] 14, wherein at least one of the interposing structure structures comprises an
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`AC load structure to match a characteristic impedance includes a layer comprising
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`epoxy and fiberglass.
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`Claim 20 (Proposed substitute for original claim 7): The assembly of claim
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`[[5]] 14, wherein at least one of the interposing structure structures comprises a DC
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`load structure to match a characteristic impedance includes a bypass capacitor.
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`Claim 21 (Proposed substitute for original claim 8): The assembly of claim
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`[[5]] 14, wherein the first micro-bump is coupled to the first second landing pad at
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`least in part by a conductor disposed in a corresponding interposing structure
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`selected from the interposing structure structures, wherein the conductor disposed
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`in the corresponding interposing structure extends in a direction parallel to the
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`surface of the integrated circuit.
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`Claim 22 (Proposed substitute for original claim 9): An assembly,
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`comprising:
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`Patent Owner’s Substitute Motion to Amend
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`an integrated circuit die having an array of micro-bumps disposed on a
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`surface of the integrated circuit die in a first pattern;
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`an integrated circuit package having an array of landing pads disposed on an
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`inside surface of the integrated circuit package in a second pattern and an array of
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`solder balls disposed on an outside surface of the integrated circuit package,
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`wherein the first pattern and the second pattern are substantially identical patterns;
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`and
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`a plurality of tiled means for electrically coupling the array of landing pads
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`and the array of solder balls, the plurality of means being disposed inside the
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`integrated circuit package between the integrated circuit die and the inside surface
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`of the integrated circuit package;
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`wherein at least one of the plurality of means for electrically coupling
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`couples a respective first micro-bump in a first position in the array of micro-
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`bumps to a respective first landing pad disposed opposite the first position and to a
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`second landing pad located in a different position in the array of landing pads, the
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`means being disposed inside the integrated circuit package between the integrated
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`circuit die and the inside surface of the integrated circuit package.
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`Claim 23 (Proposed substitute for original claim 10): The assembly of claim
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`[[9]] 22, wherein the plurality of means are held together using an elastomer means
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`is also for providing a bypass current to the integrated circuit die.
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`Claim 24 (Proposed substitute for original claim 11): The assembly of claim
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`[[9]] 22, wherein the surface of the integrated circuit die is a major surface of the
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`integrated circuit die, and wherein the plurality of means has a collective major
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`surface, and wherein the major surface of the integrated circuit die and the
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`collective major surface of the plurality of means have roughly identical surface
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`areas.
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`Claim 25 (Proposed substitute for original claim 12): The assembly of claim
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`[[9]] 22, wherein at least one of the plurality of means comprises a first conductive
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`layer corresponding to a first capacitor for a first power supply and a second
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`conductive layer corresponding to a second capacitor for a second power supply
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`different from the first power supply has a planar form and is less than 500 microns
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`thick.
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`Claim 26 (Proposed substitute for original claim 13): The assembly of claim
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`[[9]] 22, wherein at least one of the plurality of means comprises an AC load
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`structure to match a characteristic impedance the integrated circuit die is an
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`application specific integrated circuit (ASIC).
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`II.
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`Support in Specification for Proposed Amendments
`A.
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`Proposed Claim 14
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`Where claim 1 recites a single interposing structure, proposed claim 14
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`recites “a plurality of tiled interposing structures,” where “tiled interposing
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`structures” refers to a regular pattern of side by side interposing structures.
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`(XLNX-2008, ¶ 13.) Support for this amendment can be found in Fig. 8
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`accompanied by this description, which describes creating a larger single
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`interposing structure from a plurality of smaller tiled interposing structures:
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`In some embodiments, several smaller interposers are used to
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`mount a larger packaged IC to a PCB. When several smaller
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`interposers are used, they can individually expand and/or
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`contract over several smaller areas, rather than experiencing a
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`larger expansion and/or contraction over a single larger area.
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`Thus,
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`the structure can withstand greater variations
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`in
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`temperature without failure.
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`FIG. 8 shows one such embodiment. In
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`the pictured
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`embodiment, the smaller interposers ("tiles") are separately
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`soldered to the packaged IC and to the lands of the PCB. In
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`other embodiments (not shown), the tiles are combined together
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`to form a single
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`interposer device prior
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`to mounting.
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`(IVM-1001 at 9:61-10:5; see also XLNX-2008, ¶¶ 14-17.)
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`B.
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`Proposed claim 15
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`Proposed claim 15 replaces original claim 2. In addition to referring to the
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`plural “interposing structures” of claim 14 as discussed above, proposed claim 15
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`replaces the orientation limitations with a requirement that “the interposing
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`structures are held together using an elastomer.” Support for this additional
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`amendment can be found in the specification:
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`In one embodiment, an elastomer is used to hold the tiles
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`together, thus forming the single interposer device. The
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`elastomer also serves to absorb mechanical stresses from
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`thermal expansion and/or contraction.
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`(IVM-1001 at 10:6-9.)
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`C.
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`Proposed claim 16
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`Proposed claim 16 replaces original claim 3. In addition to referring to the
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`plural “interposing structures” of claim 14 as discussed above, proposed claim 16
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`now depends from proposed claim 14 and requires a collective major surface for
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`the interposing structures. Accordingly, proposed claim 16 is supported for at least
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`the same reasons as proposed claim 14.
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`D.
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`Proposed claim 17
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`Proposed claim 17 replaces original claim 4. In addition to referring to the
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`plural “interposing structures” of claim 14 as discussed above, proposed claim 17
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`now depends from proposed claim 14 and replaces the “no transistor and no PN
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`Patent Owner’s Substitute Motion to Amend
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`junction” limitations with a requirement that “at least one of the interposing
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`structures comprises a first conductive layer corresponding to a first capacitor for a
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`first power supply and a second conductive layer corresponding to a second
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`capacitor for a second power supply different from the first power supply.”
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`Support for this additional amendment can be found in the specification:
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`ICs are often manufactured using more than one power
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`supply and/or more than one ground. For example, an IC can
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`use a different power supply (VCC) for each quadrant of the
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`device. Therefore, it can be useful to divide the conductive
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`layers of the interposer to correspond to the power supply
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`divisions on the device, thereby providing two or more separate
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`capacitors using different regions of the same conductive
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`layers.
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`. . .
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`In some embodiments, some power supplies share the same
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`conductive layers, while some power supplies have separate
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`unified conductive layers.
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`(IVM-1001 at 10:10-33; see also id. at 8:6-7 (“Some ICs have
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`more than two power supplies and might require at least one
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`conductive layer for each power supply.”).)
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`E.
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`Proposed claim 18
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`Proposed claim 18 replaces original claim 5. In addition to referring to the
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`plural “interposing structures” of claim 14 as discussed above, proposed claim 18
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`now depends from proposed claim 14 and replaces the micro bumps of an
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`interposing structure limitations with a requirement that “at least one of the
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`interposing structures comprises a first conductive layer for a first ground and a
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`second conductive layer for a second ground different from the first ground.”
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`Support for this additional amendment can be found in the specification:
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`Similarly, some ICs have more than one ground, e.g., a digital
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`ground and an analog ground, or an input/output ground and a
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`ground used only for the internal core of the IC. Thus, an
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`interposer according to the invention can include more than one
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`ground and can require at least one conductive layer for each
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`ground.
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`(IVM-1001 at 8:13-18.)
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`F.
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`Proposed claim 19
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`Proposed claim 19 replaces original claim 6. In addition to referring to the
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`plural “interposing structures” of claim 14 as discussed above, proposed claim 19
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`now depends from proposed claim 14 and replaces the epoxy and fiberglass
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`limitations with a requirement that “at least one of the interposing structures
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`comprises an AC load structure to match a characteristic impedance.” Support for
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`this additional amendment can be found in the specification:
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`FIG. 21 is an expanded cross-sectional diagram of caposer 1018
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`illustrating another embodiment used to match the characteristic
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`impedance of a trace on a printed circuit board. FIG. 21 shows
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`caposer 1018 with an AC load structure 1074 used to match the
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`characteristic impedance of a transmission line such as a trace
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`on a printed circuit board.
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`(IVM-1001 at 16:57-62; see also id.at Fig. 21.)
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`G.
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`Proposed claim 20
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`Proposed claim 20 replaces original claim 7. In addition to referring to the
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`plural “interposing structures” of claim 14 as discussed above, proposed claim 20
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`now depends from proposed claim 14 and replaces the bypass capacitor limitation
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`with a requirement that “at least one of the interposing structures comprises a DC
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`load structure to match a characteristic impedance.” Support for this additional
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`amendment can be found in the specification:
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`In another example, a DC load structure is provided within the
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`caposer. The DC load structure adds to the impedance of the
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`circuitry such that the sum of the impedance of the circuitry and
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`the intervening impedance is substantially identical to the
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`characteristic impedance of the trace.
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`(IVM-1001 at 5:12-17.)
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`H.
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`Proposed claim 21
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`Proposed claim 21 replaces original claim 8 and clarifies that the first micro-
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`bump is coupled to the second landing pad. Support for this amendment includes
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`Fig. 24, which illustrates coupling a first micro-bump (above 1103) to a second
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`landing pad (below 1105) through a conductor (1106 between 1108 and 1107) that
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`extends in a direction parallel to the surface of the integrated circuit (1083).
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`Proposed claim 21 also includes amendments to refer to the plural
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`Patent Owner’s Substitute Motion to Amend
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`“interposing structures” of claim 14. Support for these changes is discussed above
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`regarding claim 14.
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`I.
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`Proposed claims 22-26
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`Proposed claim 22 replaces original claim 9 and similar to proposed claim
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`14 recites “a plurality of tiled means for electrically coupling” rather than a single
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`“means for electrically coupling.” As with proposed claim 14, support for
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`proposed claim 22 can be found in Fig. 8 and the description from column 9, line
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`61 through column 10, line 9 of the ’960 Patent. (XLNX-2008, ¶¶ 27-28.)
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`Proposed claim 23 replaces original claim 10, and in addition to referring to
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`the plural “means for electrically coupling” of claim 22 as discussed above,
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`proposed claim 23 replaces the bypass current limitation with the requirement that
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`“the plurality of means are held together using an elastomer.” This amendment is
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`similar to the amendment found in proposed claim 15 and is supported for the
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`same reasons.
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`Proposed claim 24 replaces original claim 11 and includes corresponding
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`amendments which refer to the “plurality of means for electrically coupling” of
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`proposed claim 22. This amendment is similar to the amendment found in
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`proposed claim 16 and is supported for the same reasons.
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`Proposed claim 25 replaces original claim 12, and in addition to referring to
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`the plural “means for electrically coupling” of claim 22 as discussed above,
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`Patent Owner’s Substitute Motion to Amend
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`proposed claim 25 replaces the ASIC limitation with the requirement that “at least
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`one of the plurality of means comprises a first conductive layer corresponding to a
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`first capacitor for a first power supply and a second conductive layer
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`corresponding to a second capacitor for a second power supply different from the
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`first power supply.” This amendment is similar to the amendment found in
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`proposed claim 17 and is supported for the same reasons.
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`Proposed claim 26 replaces original claim 13, and in addition to referring to
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`the plural “means for electrically coupling” of claim 22 as discussed above,
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`proposed claim 26 replaces the planar form and thickness limitations with the
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`requirement that “at least one of the plurality of means comprises an AC load
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`structure to match a characteristic impedance.” This amendment is similar to the
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`amendment found in proposed claim 19 and is supported for the same reasons.
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`III. Proposed Amendments Obviate the Grounds of Rejection
`A. Grounds 6 & 7
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`Grounds 6 and 7 are obviousness rejections that rely on U.S. Patent No.
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`6,970,362 (“Chakravorty ’362”) as a primary reference and U.S. Patent No.
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`6,730,540 (“Siniaguine”) as a secondary reference.
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`1.
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`Claim 14
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`Proposed claim 14 is patentably distinct over Chakravorty ’362, Siniaguine
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`and the other obviousness references. XLNX-2008, ¶ 30. Petitioner IVM cited
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`Chakravorty ’362’s Fig. 3 and its interposer 310 as teaching the interposing
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`Patent Owner’s Substitute Motion to Amend
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`structure of claim 1. Proposed claim 14 recites a “plurality of tiled interposing
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`structures.” Chakravorty ’362 teaches using only a single interposer to mount an
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`integrated circuit die to a substrate. (See IVM-1007 at Fig. 3.) There is no
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`teaching or suggestion in Chakravorty ’362 of using more than one interposing
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`structure. (XLNX-2008, ¶¶ 18-19.) And while Siniaguine teaches that “several
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`interposers are provided, with different parts of a clock distribution network on
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`different interposers,” there is no express teaching in Siniaguine regarding the
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`orientation of the several interposers or whether they are even used with the same
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`integrated circuit die. (See IVM-1004 at 2:59-61; 4:55-58; XLNX-2008, ¶ 20.) At
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`best, Siniaguine teaches that “multiple circuits 310 can be bonded side by side to
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`the top surface of interposer 320.” (See IVM-1004 at 4:54-55; Fig. 3; XLNX-
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`2008, ¶¶ 21-22.) Thus, Siniaguine does not remedy the deficiencies of
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`Chakravorty ’362.
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`The ’960 Patent describes potential drawbacks to packaging an integrated
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`circuit using a single interposing structure, such as physical stress induced by
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`differing thermal coefficients of expansion. (See IVM-1001 at 9:40–67; XLNX-
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`2008, ¶ 23.) The prior art of Grounds 6 and 7do not discuss, or even appear to be
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`aware of the need to reduce thermal stresses between the integrated circuit die,
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`interposer, and integrated circuit package. (See, e.g., IVM-1004 at 6:21-48
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`(recognizing thermal stress only in the context of metal layers in a trench); XLNX-
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`Patent Owner’s Substitute Motion to Amend
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`2008, ¶ 24.) Additionally, one of ordinary skill in the art would not have been
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`motivated to adopt a plurality of tiled interposing structures due to the added
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`manufacturing steps and the issues associated with aligning each of the tiled
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`interposing structures. (XLNX-2008, ¶¶ 25-26.) The references do not teach or
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`suggest the inventive solution of using a “plurality of tiled interposing structures.”
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`(XLNX-2008, ¶ 30.) Thus, proposed claim 14 obviates Grounds 6 and 7.
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`2.
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`Claim 15
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`Proposed claim 15 is patentably distinct over Chakravorty ’362, Siniaguine
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`and the other obviousness references for at least the same reasons as proposed
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`claim 14 from which it depends.
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`The additional limitations of claim 15 further distinguish over the prior art of
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`Grounds 6 and 7 as none of the asserted references disclose holding interposing
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`structures together using an elastomer.
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`3.
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`Claim 16
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`Proposed claim 16 is patentably distinct over Chakravorty ’362, Siniaguine
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`and the other obviousness references for at least the same reasons as proposed
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`claim 14 from which it depends.
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`To the extent that the “several interposers” of Siniaguine could be said to
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`teach the tiling of claim 14, the additional limitations of claim 16 further
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`distinguish over Figure 3 of Siniaguine, which shows the interposer 320 of a
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`different size and offset relative to the integrated circuit 310. (See IVM-1004 at
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`Fig. 3; 4:54-58.)
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`4.
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`Claim 17
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`Proposed claim 17 is patentably distinct over Chakravorty ’362, Siniaguine
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`and the other obviousness references for at least the same reasons as proposed
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`claim 14 from which it depends.
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`The additional limitations of claim 17 further distinguish over the prior art of
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`Grounds 6 and 7 as none of the asserted references disclose two conductive layers
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`for capacitors associated with different power supplies. (See e.g., IVM-1007 at
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`8:32 (using the term “power supply voltages,” but referring merely to the single
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`power and ground voltages).)
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`5.
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`Claim 18
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`Proposed claim 18 is patentably distinct over Chakravorty ’362, Siniaguine
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`and the other obviousness references for at least the same reasons as proposed
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`claim 14 from which it depends.
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`The additional limitations of claim 18 further distinguish over the prior art of
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`Grounds 6 and 7 as none of the asserted references disclose two conductive layers
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`with different grounds.
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`6.
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`Claim 19
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`Proposed claim 19 is patentably distinct over Chakravorty ’362, Siniaguine
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`and the other obviousness references for at least the same reasons as proposed
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`claim 14 from which it depends.
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`The additional limitations of claim 19 further distinguish over the prior art of
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`Grounds 6 and 7. Even though the references suggest that other components may
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`be included in an interposing structure, none of the asserted references disclose a
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`DC load structure to match a characteristic impedance. (See, e.g., IVM-1004 at 5-
`
`19-26; 6:1-3 (disclosing only the possibility of capacitors and resistors in the
`
`interposing structure);IVM-1005 at 2:27-30 (disclosing the possibility of other
`
`discrete components).)
`
`7.
`
`Claim 20
`
`Proposed claim 15 is patentably distinct over Chakravorty ’362, Siniaguine
`
`and the other obviousness references for at least the same reasons as proposed
`
`claim 14 from which it depends.
`
`The additional limitations of claim 20 further distinguish over the prior art of
`
`Grounds 6 and 7. Even though the references suggest that other components may
`
`be included in an interposing structure, none of the asserted references disclose an
`
`AC load structure to match a characteristic impedance. (See, e.g., IVM-1004 at 5-
`
`19-26; 6:1-3 (disclosing only the possibility of capacitors and resistors in the
`
`interposing structure); IVM-1005 at 2:27-30 (disclosing the possibility of other
`
`discrete components).)
`
`
`
`–16–
`
`

`

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`
`
`8.
`
`Claim 22
`
`
`
`Patent Owner’s Substitute Motion to Amend
`IPR2012-00018
`
`Proposed claim 22 is an independent claim that recites similar limitations
`
`regarding “a plurality of tiled means for electrically coupling” as claim 14.
`
`Accordingly, claim 22 distinguishes over the prior art in Grounds 6 and 7 for the
`
`reasons discussed above regarding claim 14. (See also XLNX-2008, ¶¶ 27-30.)
`
`9.
`
`Claim 23
`
`Proposed claim 23 is an independent claim that recites similar limitations
`
`regarding plural “means for electrically coupling” as claim 22 and an elastomer as
`
`claim 15. Accordingly, claim 23 distinguishes over the prior art in Grounds 6 and
`
`7 for the reasons discussed above regarding claims 22 and 15.
`
`10. Claim 25
`
`Proposed claim 25 is an independent claim that recites similar limitations
`
`regarding plural “means for electrically coupling” as claim 22 and two conductive
`
`layers for capacitors associated with different power supplies as claim 17.
`
`Accordingly, claim 25 distinguishes over the prior art in Grounds 6 and 7 for the
`
`reasons discussed above regarding claims 22 and 17.
`
`11. Claim 26
`
`Proposed claim 26 is an independent claim that recites similar limitations
`
`regarding plural “means for electrically coupling” as claim 22 and an AC load
`
`structure as claim 19. Accordingly, claim 26 distinguishes over the prior art in
`
`
`
`–17–
`
`

`

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`Patent Owner’s Substitute Motion to Amend
`IPR2012-00018
`
`Grounds 6 and 7 for the reasons discussed above regarding claims 22 and 19.
`
`12. Dependent Claims
`
`Proposed dependent claims 16, 21, and 24 are distinguished over Grounds 6
`
`and 7 for at least the reason that they depend from and further limit independent
`
`claims 14 or 22.
`
`B. Grounds 8 & 9
`
`Grounds 8 and 9 are obviousness rejections that rely on Siniaguine as a
`
`primary reference and US 6,423,570 (“Ma”) and Chakravorty ’362 as secondary
`
`references.
`
`1.
`
`Claim 14
`
`Petitioner IVM cited Siniaguine’s integrated circuit 320 as teaching the
`
`interposing structure of claim 1. Petitioner IVM also cited Chakravorty ’362’s
`
`interposer 310 as further teaching of the claimed interposing structure. (See
`
`Petition at 42.)
`
`Proposed claim 14 recites a “plurality of tiled interposing structures.” For
`
`the reasons discussed above with respect to Grounds 6 and 7, neither Siniaguine
`
`nor Chakravorty ’362 teach or suggest using a plurality of tiled interposing
`
`structures between a single integrated circuit die and a single integrated circuit
`
`package. Ma is not able to remedy the deficiencies of Siniaguine and Chakravorty
`
`’362 as Ma teaches only a single interposing structure. (See IVM-1008 at Figs. 1,
`
`
`
`–18–
`
`

`

`
`
`
`
`18; XLNX-2008, ¶ 18.)
`
`
`
`Patent Owner’s Substitute Motion to Amend
`IPR2012-00018
`
`As noted above regarding Grounds 6 and 7, Siniaguine and Chakravorty
`
`’362 do not even acknowledge awareness of the potential drawbacks to using a
`
`single interposing structure. Similarly, Ma only recognizes thermal stress issues
`
`in the context of heat sinks. (See IVM-1008 at 6:35-45; XLNX-2008, ¶ 24.)
`
`Accordingly, the prior art references do not teach or suggest the inventive solution
`
`of employing a “plurality of tiled interposing structures” as recited in proposed
`
`claim 14.
`
`2.
`
`Claim 22
`
`Proposed claim 22 is an independent claim that recites similar limitations
`
`regarding “a plurality of tiled means for electrically coupling” as claim 20.
`
`Accordingly, claim 22 distinguishes over the prior art in Grounds 8 and 9 for the
`
`reasons discussed above regarding claim 14. (See also XLNX-2008, ¶¶ 27-30.)
`
`3.
`
`Dependent Claims
`
`Proposed dependent claims 15-21, and 23-25 are distinguished over Grounds
`
`8 and 9 for at least the reason that they depend from and further limit independent
`
`claims 14 or 22 as well as the additional reasons discussed above for claims 15-21
`
`and 23-25 with respect to Grounds 6 and 7. To the extent that Ma provides any
`
`additional teaching or suggestion beyond Siniaguine, Chakravorty ’362, and Patel,
`
`these teachings are not material to the patentability of any additional limitations in
`
`
`
`–19–
`
`

`

`
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`
`
`
`Patent Owner’s Substitute Motion to Amend
`IPR2012-00018
`
`proposed dependent claims 15-21 and 23-25.
`
`IV. Conclusion
`
`The proposed amendments represent a reasonable number of substitute
`
`claims, are fully supported by the specification of the ’960 Patent, do not broaden
`
`the scope of the ’960 Patent, and obviate the grounds of rejection that led to this
`
`trial. Accordingly, Xilinx requests that the proposed amendments be entered if the
`
`Board determines that the original claims 1-13 are unpatentable.
`
`Xilinx thanks the Board for granting a five page extension for this motion.
`
`(Paper 20 at 2.)
`
`
`
`
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`
`
`Respectfully submitted,
`
`/David L. McCombs/
`David L. McCombs
`Registration No. 32,271
`
`HAYNES AND BOONE, LLP
`Customer No. 27683
`Telephone: 214/651-5116
`Facsimile: 214/200-0808
`Attorney Docket No.: 42299.44
`
`
`
`
`Dated: May 14, 2013
`
`R_329446_2
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`
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`
`
`–20–
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`

`

`UNITED STA