UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`INTELLECTUAL VENTURES MANAGEMENT, LLC
`Petitioner
`
`V.
`
`XILINX, INC.
`Patent Owner
`
`Case IPR2012-00018
`
`Patent 7,566,960
`
`PETITIOE‘IER’S OPPOSITION TO PATENT GWNERE’S
`
`SECOND SUBSTITUTE MOTION TO AMEND
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`INTELLECTUAL VENTURES MANAGEMENT, LLC
`Petitioner
`
`V.
`
`XILINX, INC.
`Patent Owner
`
`Case IPR2012-00018
`
`Patent 7,566,960
`
`PETITIOE‘IER’S OPPOSITION TO PATENT GWNERE’S
`
`SECOND SUBSTITUTE MOTION TO AMEND
`
`
`
`TAELE OF CONTENTS
`
`I.
`
`Statement of Relief Requested .......................................................................... 1
`
`11. Overview ........................................................................................................... 1
`
`III. Patent Owner’s Second Substitute Motion to Amend Goes Far Beyond “the
`
`Sole Purpose of Complying with the Idle Free Decision” ................................ 2
`
`IV. Substitute Claims 14-21 Should Be Rejected Under 35 U.S.C. § 112 ............. 4
`
`V. Substitute Claims 14-26 Are Unpatentable ....................................................... 5
`
`A. Alexander Discloses the New Limitations in Substitute Claims 14 and
`
`22 ................................................................................................................ 5
`
`1. Alexander Pre-Dates the ‘960 Patent ........................................................ 5
`
`2. New Matter from Proposed Claim Amendments Is Identical to Alexander
`
`6
`
`3.
`
`Ground 10: Substitute Claims 14—18, 20-24 and 26 Are Obvious Under
`
`35 § U.S.C. 103 Based on Chakravorty ‘362, Siniaguine, and Alexander ........ 7
`
`4.
`
`Ground 11: Substitute Claims 19 and 25 Are Obvious Under 35 U.S.C. §
`
`103 Based on Chakravorty ‘362, Siniaguine, Alexander, and Patel .................. 8
`
`5.
`
`Ground 12: Substitute Claims 14-18, 20-24, and 26 Are Obvious Under
`
`35 § U.S.C. 103 Based on Siniaguine, Ma, Chakravorty ‘3 62, and Alexander. 8
`
`6.
`
`Ground 13: Substitute Claims 19 and 25 Are Obvious Under 35 U.S.C. §
`
`103 Based on Siniaguine, Ma, Chakravorty ‘362, Alexander, and Patel .......... 9
`
`B. Pasco and Bellaar Disclose the New Limitations in Substitute Claims
`
`14 and 22 ................................................................................................... 10
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`1.
`
`Pasco and Bellaar Pre-Date the ‘960 Patent ............................................ 10
`
`2.
`
`Pasco and Bellaar Disclose the New Matter from the Proposed Claim
`
`Amendments ..................................................................................................... 1 0
`
`3.
`
`Ground 14: Substitute Claims 14-18, 20-24, and 26 Are Obvious Under
`
`35 U.S.C. § 103 Based on Chakravorty ‘362, Siniaguine, Pasco, and Bellaar 12
`
`4.
`
`Ground 15: Substitute Claims 19 and 25 Are Obvious Under 35 U.S.C. §
`
`103 Based on Chakravorty ‘362, Siniaguine, Pasco, Bellaar, and Patel .......... 13
`
`5.
`
`Ground 16: Substitute Claims 14-18, 20-24, and 26 Are Obvious Under
`
`35 § U.S.C. 103 Based on Siniaguine, Ma, Chakravorty ‘362, Pasco, and
`
`Bellaar .............................................................................................................. l4
`
`6.
`
`Ground 17: Substitute Claims 19 and 25 Are Obvious Under 35 U.S.C. §
`
`103 Based on Siniaguine, Ma, Chakravorty ‘362, Pasco, Bellaar, and Patel .. 15
`
`VI. Conclusion ....................................................................................................... 15
`
`ii
`
`
`
`1.
`
`Statement of Relief Requested
`
`Petitioner opposes Patent Owner’s Second Substitute Motion to Amend for
`
`the reasons set forth in its Petition (Paper 6), in its Reply to Patent Owner
`
`Response, and below.
`
`11.
`
`Overview
`
`Patent Owner attempts to circumvent the Board’s Order of July 24, 2013
`
`(“Board’s Order”; Paper 24) in the submission of its Second Substitute Motion to
`
`Amend (Paper 26). The Board permitted Patent Owner to submit the Second
`
`Substitute Motion to Amend for “the sole purpose of complying with the Idle Free
`
`decision.” Paper 24. But Patent Owner’s submission goes far beyond What was
`
`permitted by the Board’s Order.
`
`Even assuming that Patent Owner’s Second Substitute Motion to Amend did
`
`not violate the Board’s Order, the proposed amendments do not provide any
`
`patentable subject matter. Specifically, the proposed amendments include subject
`
`matter that is identical to the subject matter disclosed in the Alexander prior art
`
`reference. Additionally, the Pasco and Bellaar prior art references disclose the new
`
`matter from the substitute claims. Thus, based on at least the prior art presented in
`
`the Petition, and the art identified herein, substitute claims 14—26 are not
`
`patentable.
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`111. Patent Owner’s Second Substitute Motion to Amend Goes Far Beyend
`“the Sole Purpose of Compiying with the Idle Free Becision”
`
`Patent Owner’s original Motion to Amend lacked a claim listing, thus
`
`circumventing the page limit. See Paper 20. Patent Owner then submitted a
`
`Substitute Motion to Amend to cure this deficiency. See Paper 22. Patent Owner
`
`then sought the Board’s permission to file yet another Substitute Motion to Amend
`
`to comply with the Idle Free decision. The Board granted the Patent Owner
`
`permission to submit a Second Substitute Motion to Amend for the very limited
`
`and “sole purpose of complying with the Idle Free decision.” Paper 24. Patent
`
`Owner’s Second Substitute Motion to Amend goes far beyond what was needed to
`
`comply with the Idle Free decision. As such, the Motion should be denied.
`
`Moreover, given that the Patent Owner has had three attempts to submit a proper
`
`Motion to Amend, no further Motions or accommodations should be permitted.
`
`Rather than simply provide a second substitute motion to comply with the
`
`Idle Free decision, Patent Owner inappropriately seeks to dramatically revise and
`
`correct numerous problems with its ill-formed Substitute Motion to Amend. For
`
`example, Patent Owner impermissibly uses the Second Substitute Motion to
`
`Amend as a vehicle to correct numerous 35 U.S.C. § 112 issues present in its
`
`Substitute Motion to Amend. For example, in the claim listing from Patent
`
`Owner’s Substitute Motion to Amend, claim 19 recites “wherein at least one of the
`
`interposing structure structares comprises an AC load structure to match a
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`characteristic impedance includes a layer comprising epoxy and fiberglass.” Paper
`
`22. The meaning of this limitation is unascertainable and thus suffers from section
`
`112 written description issues. Dr. Neikirk, Patent Owner’s technical expert,
`
`confirms this. See IVM 1013, p. 41, 11. 2-11 (noting that “there’s a grammatical
`
`problem here”). The other substitute claims—claims 14-18 and 20-26—in the
`
`claim listing from Patent Owner’s Substitute Motion to Amend suffer from similar
`
`deficiencies.
`
`Additionally, the Patent Owner attempts to remove numerous limitations
`
`that were added in the Substitute Motion to Amend. For example, claim 14 of the
`
`Substitute Motion to Amend included the limitation of: “at least one of the
`
`intemoser interposing structures electrically coupling a respective first micro—bump
`
`in a first position in the array of micro-bumps to a respective first landing pad...”
`
`In the Second Substitute Motion of Amend, the Patent Owner removes these added
`
`limitations, such that the element reads as: “the interposer electrically coupling a
`
`first micro-bump in a first position in the array of micro—bumps to a first landing
`
`pad ....” Removal of limitations was not necessary for the “sole purpose of
`
`complying with the Idle Free decision.” Rather than amend the claims for the “sole
`
`purpose of complying with the Idle Free decision,” Patent Owner attempts to
`
`correct poorly-constructed claim amendments that are fraught with limitations
`
`having unclear meanings and 35 U.S.C. § 112 issues.
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`Patent Owner also adds limitations in the claims from the Second Substitute
`
`Motion to Amend. For example, in the Substitute Motion to Amend, claim 14
`
`includes “a plurality of tiled interposing structure structures.” See Paper 22, p. 1. In
`
`the Second Substitute Motion to Amend, claim 14 not only includes “a plurality of
`
`tiled interposing structures” but also “the plurality of tiled interposing structures
`
`being held together using an elastomer.” See Paper 26, p. 3. Similar modifications
`
`were made to claim 22. In adding the “elastomer” limitation to claims 14 and 22,
`
`Patent Owner impermissibly takes another opportunity to amend its claims.
`
`The Board’s Order did not permit Patent Owner to make the type of claim
`
`amendments discussed above. See Paper 24. Patent Owner has been given three
`
`opportunities to file a complaint Motion to Amend. But, since each of these
`
`Motions is deficiencient, Patent Owner’s Motions to Amend should be denied.
`
`IV.
`
`Substitute Claims 14-21 Should Be Rejected Under 35 U.S.C. § 112
`
`Claim 14 from Patent Owner’s Second Substitute Motion to Amend recites:
`
`an interposing structure
`
`comprising a plurality of tiled
`
`interposing structures disposed inside the integrated circuit
`
`package between the integrated circuit die and the inside
`
`surface of the integrated circuit package, the plurality of tiled
`
`interposing structures being held together using an elastomer,
`
`the interposer electrically coupling a first micro-bump in a first
`
`position in the array of micro-bumps to a first landing pad
`
`located opposite to the first position and to a second landing
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`pads in the array of landing pads.
`
`Emphasis added.
`
`The term “the interposer” lacks antecedent basis and it is unclear what it refers
`
`to—e.g., does it refer to the “interposing structure,” the “plurality of tiled
`
`interposing structures,” or maybe one of the “plurality of tiled interposing
`
`structures?
`
`Substitute claim 14 should therefore be rejected based on at least 35 U.S.C.
`
`§ 112, second paragraph, due to indefiniteness and lack of clarity. Based on their
`
`dependencies from claim 14, substitute claims 15-21 should also be rejected.
`
`V.
`
`Substitute Clairns 14-26 Are Unpatentable
`
`IVM provides below eight new grounds of rej ection under 35 U.S.C. § 103
`
`for substitute claims 14—26. These grounds of rejections include Chakravorty ‘3 62
`
`(IVM 1009) and Siniaguine (IVM 1003) as primary references and the following
`
`secondary references: Alexander (IVM 1017), Patel (IVM 1004), Ma (IVM 1008),
`
`Pasco (IVM 1018, and Bellaar (IVM 1019).
`
`A.
`
`Alexander Biscioses the New Limitations in Substitute Claines 14 and 22
`
`1.
`
`Alexander i’re-Dates the ‘950 Patent
`
`US. Patent No. 6,891,258 to Alexander et al. was filed on December 6,
`
`2002, prior to the filing date of the ‘960 patent (“Alexander”; IVM 1016).
`
`Alexander also has a different inventive entity than the ‘960 patent. Alexander thus
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`qualifies as prior art under 35 U.S.C. § 102(e).1
`
`2.
`
`New Matter from Froposed Claim Amendments Is Identical to
`Alexander
`
`a)
`
`Alexander Discloses “a Plurality of Tiled interposing Structures”
`
`In support of the “interposing structure comprising a plurality of tiled
`
`interposing structures disposed inside the integrated circuit package between the
`
`integrated circuit die and the inside surface of the integrated circuit package”
`
`limitation, Patent Owner points to paragraphs [0081] and [0082] from the
`
`originally-filed ‘960 patent specification and FIG. 8. See Paper 26, pp. 7-8.
`
`Paragraphs [0081] and [(7082] are identical to column 8, lines 12-27 in Alexander.
`
`1 Alexander is assigned to Xilinx, lists a common inventor as the ‘968
`
`patent, and has the term “interposer” in its title. See IVM 1020. Thus, Patent
`
`Owner’s allegation that it “is not aware of any circuit die assembly prior art that
`
`discloses an interposer comprising ‘a plurality of tiled interposing structures,’ nor
`
`is the Patent Owner aware of any circuit die assembly prior art that discloses a
`
`‘plurality of tiled interposing structures being held together using an
`
`elastomer”’(Paper 24, pp. 14-15) fails to satisfy Idle Free because it does not
`
`include a representation about the “specific technical disclosure” of Alexander, and
`
`further because it is an unsupported, conclusory allegation. Idle Free Systems, Inc.
`
`v. Bergstrom, Inc., Case IPR2012-00027, Paper 26 (June 11, 2013), p. 7.
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`FIG. 8 from the ‘960 patent is also identical to FIG. 8 from Alexander. Indeed, Dr.
`
`Neikirk confirms that “looking at the ‘960 [patent], there is a Figure 8, and it is
`
`certainly very similar, if not the same [as Figure 8 from Alexander].” IVM 1013, p.
`
`32, 11. 22-24. Alexander therefore discloses the “plurality of tiled interposer
`
`structures” limitation.
`
`b)
`
`Alexander Discloses “the Plurality of Tiled Interposing Structures Being
`Held Together Using an Elastomer”
`
`In support of the “plurality of tiled interposing structures being held together
`
`using an elastomer” limitation, Patent Owner points to paragraph [0082] from the
`
`originally-filed ‘960 patent specification. See Paper 26, pp. 8-9. Paragraph [0082]
`
`is identical to column 8, lines 19-27 in Alexander. Indeed, in reference to the
`
`elastomer disclosure in Alexander, Dr. Neikirk confirms that the elastomer from
`
`Alexander “seem[s] to be the added elements” from Patent Owner’s claim
`
`amendments. IVM 1013, p. 35, 11. 6-7.
`
`3.
`
`Ground 10: Substitute CEaims 14-18, 28-24 and 26 Are {)bvious Under
`35 § U.S.C. 103 Based on Cfiakravorty ‘362, Siniaguine, and Alexander
`
`For similar reasons set forth in the Petition and Petitioner’s Reply to Patent
`
`Owner Response, Chakravorty ‘362 and Siniaguine disclose each and every
`
`limitation of substitute claims 14—18, 20—24, and 26. See Paper 6, pp. 28-36. To the
`
`extent that Chakravorty ‘362 or Siniaguine do not disclose an “interposing
`
`structure comprising a plurality of tiled interposing structures disposed inside the
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`integrated circuit package between the integrated circuit die and the inside surface
`
`of the integrated circuit package” or a “plurality of tiled interposing structures
`
`being held together using an elastomer,” Alexander discloses these limitations—as
`
`discussed above.
`
`A person of ordinary skill in the art would combine the teachings of
`
`Chakravorty ‘362, Siniaguine, and Alexander. See IVM 1012, W 21-25. For
`
`example, interposer 310 in FIG. 3 of Chakravorty ‘3 62 can be modified to have a
`
`plurality of tiled interposing structures—like FIG. 8 of Alexander—to mitigate for
`
`the effects of thermal expansion and/or contraction in interposer 310. See id The
`
`tiled interposing structures can be held together using an elastomer. See id. This
`
`modification would have been nothing more than a mere design choice that would
`
`yield predictable results. See id.
`
`4.
`
`Ground 11: SuEstétuEe Claims 19 and 25 Are Obvious Under 35 U.S.C. §
`103 Based on Chakravorty ‘362, Siniaguine, Alexander, and Patel
`
`For similar reasons set forth in the Petition, Patel discloses the limitations in
`
`substitute claims 19 and 25. See Paper 6, pp. 36—37. For similar reasons set forth in
`
`the Petition, a person of ordinary skill in the art would combine the teachings of
`
`Chakravorty ‘362, Siniaguine, Alexander and Patel. See IVM 1012, {I 44.
`
`5.
`
`Grouaed 12: Substitute Claims 14-18, 20-24, and 26 Are Obvious Under
`
`35 § ELSE. 103 Based on Siniaguine, ’ a, Chakravorty ‘362, and
`Alexander
`
`For similar reasons set forth in the Petition and Petitioner’s Reply to Patent
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`Owner Response, Siniaguine, Ma and Chakravorty ‘362 disclose each and every
`
`limitation of substitute claims 14-18, 20—24, and 26. See Paper 6, pp. 38-49. To the
`
`extent that Siniaguine, Ma or Chakravorty ‘362 do not disclose an “interposing
`
`structure comprising a plurality of tiled interposing structures disposed inside the
`
`integrated circuit package between the integrated circuit die and the inside surface
`
`of the integrated circuit package” or a “plurality of tiled interposing structures
`
`being held together using an elastomer,” Alexander discloses these limitations—as
`
`discussed above.
`
`A person of ordinary skill in the art would combine the teachings of
`
`Siniaguine, Ma, Chakravorty ‘362, and Alexander. See IVM 1012, {If 30-33. For
`
`example, IC 320 in FIG. 4 of Siniaguine can be modified to have a plurality of
`
`tiled interposing structures—like FIG. 8 of Alexander—to mitigate for the effects
`
`of thermal expansion and/or contraction in interposer 310. See id. The tiled
`
`interposing structures can be held together using an elastomer. See id. This
`
`modification would have been nothing more than a mere design choice that would
`
`yield predictable results. See id.
`
`6.
`
`Ground 13: Substitute Claims 19 and 25 Are {)bvious Under 35 USE. §
`103 Based 0:1 Siniaguine, Ma, Chakravorty ‘362, Alexander, and Patel
`
`For similar reasons set forth in the Petition, Patel discloses the limitations in
`
`substitute claims 19 and 25. See Paper 6, pp. 50-51. Also, for similar reasons set
`
`forth in the Petition, a person of ordinary skill in the art would combine the
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`teachings of Siniaguine, Ma, Chakravorty ‘3 62, Alexander, and Patel. See IVM
`
`1012, fi 45.
`
`B.
`
`Pasco and Bellaar Disclose the New Limitations in Substitute Ciaims 14
`
`and 22
`
`1.
`
`Pasco and Bellaar Pre-Date the ‘960 Patefit
`
`U.S. Patent No. 6,319,829 to Pasco et al. was issued on November 20, 2001,
`
`well over one year prior to the filing date of the ‘960 patent (“Pasco”; IVM 1017).
`
`U.S. Patent No. 6,002,168 to Bellaar et al., titled “Microelectronic Component
`
`with Rigid Interposer,” was issued on December 14, 1999, well over one year prior
`
`to the filing date of the ‘960 patent (“‘Bellaar”; IVM 1018). Both Pasco and Bellaar
`
`qualify as prior art under at least 35 U.S.C. § 102(b).
`
`2.
`
`Pasco and Bellaar Disclose the
`Amendments
`
`ew Matter from the Proposed Claim
`
`a)
`
`Pasco Biscloses “a Pluralit'y of Tiled Iéterposing Structures”
`
`In reference to FIG. 4 (reproduced below), Pasco discloses a segmented
`
`interposer 48 with a plurality of equal—sized interposers 20 arranged in a planar
`
`manner above a printed circuit board (PCB) 50. See IVM 1012, fi 37. Segmented
`
`interposer 48 provides interconnections between a substrate 44 (e. g., part of a
`
`multichip module 40) and PCB 50 using solder balls 46. See id. Segmented
`
`interposer 48 mitigates stresses on solder balls 46 due to the effects of different
`
`thermal coefficients of expansion (TCE). See id. Interposers 20 can be considered
`
`“tiled interposing structures” since they are the same structure (e. g., as understood
`
`10
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`by the common nomenclature “20” used for each of the three structures) that can
`
`be arranged in a side-by-side pattern (as illustrated in FIG. 4). This is consistent
`
`with Dr. Neikirk’s interpretation of the term “tiled interposing structures.” See
`
`XLNX 2008, p. 6 (“One of ordinary skill in the art would interpret ‘tiled
`
`interposing structures’ to refer to a regular pattern of side by side interposing
`
`structures”).
`
`
`
`FIG. 4 of Pasco
`
`b)
`
`Bellaar Discloses Interposing Structures “Being Held Together Using an
`Elasfomer”
`
`Bellaar discloses that a plurality of interposing structures can be held
`
`together using an elastomer. See IVM 1012, ‘l 38. For example, Bellaar discloses
`
`an elastomer that can be used to control spacing/separation between interposers.
`
`See id. Bellaar uses the elastomer to create a compliant layer, or compliant spacer,
`
`between a rigid interposer and a flexible interposer. See id. The elastomer can be
`
`used to compensate for mismatches in the coefficient of thermal expansion
`
`between a chip and the rigid interposer and/or between the rigid interposer and the
`
`flexible interposer. See id.
`
`11
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`c)
`
`Combination of Pasco and Bellaar Is Proper
`
`A person of ordinary skill in the art would combine the teachings of Pasco
`
`and Bellaar. See IVM 1012, '11 39. For example, the elastomer of Bellaar can be
`
`used to hold together interposers 20 in segmented interposer 48 of Pasco. See id. In
`
`referring to FIG. 4 of Pasco, substrate 44 and PCB 50 can be manufactured from
`
`materials different from interposers 20, thus having a different coefficient of
`
`thermal expansion than interposers 20. See id. The elastomer of Bellaar can be
`
`used to control the spacing/separation between interposers 20—e.g., lateral shifts
`
`in solder balls 46—relative to substrate 44 and PCB 50 under various thermal
`
`conditions. See id. For ease of explanation, the combination of the segmented
`
`interposer of Pasco with the elastomer of Bellaar (holding interposers 20 together)
`
`will be referred to herein as “the modified segmented interposer of Pasco/Bellaar.”
`
`This modification would have been nothing more than a mere design choice that
`
`would yield predictable results. See id.
`
`3.
`
`Ground 14: Substitute Claims 14-18, 20-24, and 26 AFC vaious Under
`
`35 U.S.C. § 163 Based on Chakravorty ‘362, Siniaguine, Pasco, and
`Bellaar
`
`For similar reasons set forth in the Petition and Petitioner’s Reply to Patent
`
`Owner Response, Chakravorty ‘362 and Siniaguine disclose each and every
`
`limitation of substitute claims 14-18, 20—24, and 26. See Paper 6, pp. 28—36. To the
`
`extent that Chakravorty ‘362 or Siniaguine do not disclose an “interposing
`
`12
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`structure comprising a plurality of tiled interposing structures disposed inside the
`
`integrated circuit package between the integrated circuit die and the inside surface
`
`of the integrated circuit package” or a “plurality of tiled interposing structures
`
`being held together using an elastomer,” the modified segmented interposer of
`
`Pasco/Bellaar discloses these limitations—as discussed above.
`
`A person of ordinary skill in the art would combine the teachings of
`
`Chakravorty ‘362, Siniaguine, Pasco, and Bellaar. See IVM 1012, W 40-41. For
`
`example, interposer 310 in FIG. 3 of Chakravorty ‘362 can be modified to
`
`implement the features of the modified segmented interposer of Pasco/Bellaar to
`
`mitigate the stress on solder balls 301 and 311 due to the effects of different
`
`thermal coefficients of expansion. See id. For example, the modified segmented
`
`interposer of Pasco/Bellaar can compensate for mismatches in the coefficient of
`
`thermal expansion between IC die 300 and the modified segmented interposer and
`
`between the modified segmented interposer and primary substrate 320. See id. This
`
`modification would have been nothing more than a mere design choice that would
`
`yield predictable results. See id.
`
`4.
`
`Ground 15: Substitute Claims 19 and 25 Are vaious Under 35 U.S.C. §
`103 Based on Chakravorty ‘362, Siniaguine, Pascg, Bellaar, and Patel
`
`For similar reasons set forth in the Petition, Patel discloses the limitations in
`
`substitute claims 19 and 25. See Paper 6, pp. 36-3 7. Also, for similar reasons set
`
`forth in the Petition, a person of ordinary skill in the art would combine the
`
`13
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`teachings of Chakravorty ‘362, Siniaguine, Pasco, Bellaar, and Patel. See IVM
`
`1012, f 44.
`
`5.
`
`Ground 16: Subsiitute Claims 14-18, 20-24, and 26 Are {)bvious Under
`
`35 § U.S.C. 103 Based on Siniaguine, Ma, Chakravorty ‘362, Pasco, and
`Bellaar
`
`For similar reasons set forth in the Petition and Petitioner’s Reply to Patent
`
`Owner Response, Siniaguine, Ma, and Chakravorty ‘362 disclose each and every
`
`limitation of substitute claims 14-18, 20-24, and 26. See Paper 6, pp. 38—49. To the
`
`extent that Siniaguine, Ma or Chakravorty ‘362 do not disclose an “interposing
`
`structure comprising a plurality of tiled interposing structures disposed inside the
`
`integrated circuit package between the integrated circuit die and the inside surface
`
`of the integrated circuit package” or a “plurality of tiled interposing structures
`
`being held together using an elastomer,” the modified segmented interposer of
`
`Pasco/Bellaar discloses these limitations—as discussed above.
`
`A person of ordinary skill in the art would combine the teachings of
`
`Siniaguine, Ma, Chakravorty ‘3 62, Pasco, and Bellaar. See IVM 1012, W 42-43.
`
`For example, IC 320 in FIG. 4 of Siniaguine can be modified to have a plurality of
`
`tiled interposing structures—like FIG. 8 of Alexander—to implement the features
`
`of the modified segmented interposer of Pasco/Bellaar to compensate for
`
`mismatches in the coefficient of thermal expansion between IC 310 and the
`
`modified segmented interposer and between the modified segmented interposer
`
`14
`
`
`
`IPR2012-00018
`
`Patent 7,566,960
`
`and wiring substrate 330. See id. This modification would have been nothing more
`
`than a mere design choice that would yield predictable results. See id.
`
`6.
`
`Ground 17: Substitute Claims 19 and 25 Are Obvious Under 35 U.S.C. §
`103 Based on Siniaguine, Ma, Chakravorty ‘362, Pasco, BeEEaar, arid
`Patel
`
`For similar reasons set forth in the Petition, Patel discloses the limitations in
`
`substitute claims 19 and 25. See Paper 6, pp. 50-51. Also, for similar reasons set
`
`forth in the Petition, a person of ordinary skill in the art would combine the
`
`teachings of Siniaguine, Ma, Chakravorty ‘362, Pasco, Bellaar and Patel. See IVM
`
`1012,1145.
`
`V1. Conclusion
`
`For the reasons set forth above, Patent Owner’s Motions to Amend should
`
`be denied.
`
`Respectfiilly submitted,
`
`Date: August 27, 2013
`
`K
`
`By-W
`
`Michael D. Specht, Lead Counsel (Reg. No. 54,463)
`Robert Greene Sterne, Backup Counsel
`
`STERNE, KESSLER, GOLDSTEIN 8; Fox P.L.L.C.
`1 100 New York Avenue, NW
`Washington, DC. 20005
`(202) 371-2600
`
`Attorneys for Petitioner
`Intellectual Ventures Alanagement, LLC
`
`15
`
`
`
`EXHiBIT LIST
`
`
`|
`
`Intellectual
`
`Ventures
`
`DESCRIPTION
`
`Management,
`
`
`
`1001
`US. Patent No. 7,566,960 to Conn
`
`1002
`
`Declaration of Morgan T. Johnson in Support of Petition for
`Inter Partes Review of U.S. Patent No. 7,566,960
`
`
`
`1003
`US. Patent No. 6,61 1,419 to Chakravorty
`
`
`
`1004
`US. Patent No. 6,730,540 to Siniaguine
`
`
`1005
`US. Patent No. 6,469,908 to Patel et a1.
`
`
`1006
`US. Patent No. 6,680,218 to Chung et al.
`
`
`1007
`US. Patent No. 6,970,362 to Chakravorty
`
`
`1008
`US. Patent No. 6,423,570 to Ma et a1.
`
`
`1009
`US. Patent Appl. Pub. No. 2002/0053728 to Isaak et a1.
`
`1010
`
`Curriculum Vitae of Morgan T. Johnson
`
`1011
`
`Declaration of Morgan T. Johnson in Support of Petitioner’s
`Reply to Patent Owner Response to Petition
`
`Declaration of Morgan T. Johnson in Support of Petitioner’s
`1012
`Opposition to Patth Owner’s Second Substitute Motion to
`
`Amend
`
`
`1013
`Deposition Transcript of Dr. Dean Neikirk
`
`
`
`
`
`
`
`1014
`
`Lau et al., Chip Scale Package: Design, Materials, Process,
`Reliability, and Applications, 19, McGraw—Hill, 1999
`
`
`The American Heritage Dictionary, 484, Houghton Mifflin
`Company, 1985 (1982)
`1015
`
`
`1016
`
`1017
`
`US. Patent No. 6,891,258 to Alexander et a1.
`
`
`US. Patent No. 6,319,829 to Pasco et al.
`
`
`1018
`US. Patent No. 6,602,168 to Bellaar et al.
`
`1019
`
`1020
`
`US. Patent and Trademark Office Assignment Record for US.
`Patent No. 6,891,258 to Alexander et a1.
`
`Updated Curriculum Vitae of Morgan T. Johnson
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 27th day of August 2013, a true and correct copy
`
`of the foregoing PETITIONER’S OPPOSITION TO PATENT OWNER’S
`
`SECOND SUBSTITUTE MOTION TO AMEND was served upon the following
`
`counsel for Patent Owner, Xilinx Inc.:
`
`David L. McCombs, Lead Counsel
`ATTN: IP DOCKETING
`
`HAYNES AND BOONE, LLP
`
`2323 Victory Avenue, Suite 700
`Dallas, TX 75219
`
`
`david.mccombs@haynesboone.com
`
`Thomas B. King
`HAYNES AND BOONE, LLP
`
`18100 Von Karman, Suite 750
`
`Irvine, CA 92612
`
`
`thomas.king@haynesboone.com
`
`mil/Ow
`
`
`
`Michael D. Specht, Lead Counsel (Reg. No. 54,463)
`
`STERNE, KESSLER, GOLDSTE‘IN & Fox P.L.L.C.
`
`1 100 New York Avenue, NW
`Washington, DC. 20005
`(202) 371-2600
`
`Attorney for Petitioner
`Intellectual Ventures Management LLC
`
`
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
