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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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`
`Intel Corporation,
`Petitioner,
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`v.
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`VLSI Technology, LLC,
`Patent Owner.
`___________________
`
`Case IPR2019-01196
`Patent No. 7,246,027
`___________________
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`
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`PATENT OWNER'S PRELIMINARY RESPONSE
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`Mail Stop "PATENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`TABLE OF CONTENTS
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`Case IPR2019-01196
`Patent No. 7,246,027
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`I.
`II.
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`Page
`INTRODUCTION ........................................................................................ 1
`THE BOARD SHOULD DENY THE PETITION UNDER 314(a)
`BECAUSE THE DISTRICT COURT ACTION IS IN AN
`ADVANCED STAGE .................................................................................. 9
`SUMMARY OF THE '027 PATENT......................................................... 12
`III.
`IV. THE PRIOR ART REFERENCES DIFFER FROM THE '027
`INVENTIONS ............................................................................................ 16
`A.
`Starr Overview ................................................................................. 16
`B.
`Bilak Overview ................................................................................. 19
`C.
`Kang Overview ................................................................................. 21
`LEVEL OF ORDINARY SKILL ............................................................... 23
`V.
`VI. CLAIM CONSTRUCTION ....................................................................... 23
`A.
`"Determining/Determine An Analog Variation Parameter" ............ 23
`1.
`Substituting "determining/determine" with
`"sensing/sense" alters the claims scope ................................. 24
`"Variation" refers to IC-to-IC variance, which variance
`may or may not occur during operation ................................. 27
`"Determining/Determine An Operational Temperature" ................. 30
`B.
`"Determining/Determine A Digital Variation Parameter" ............... 32
`C.
`VII. GROUND 1: CLAIMS 1, 2, 8, 9, 18, AND 19 ARE NOT
`RENDERED OBVIOUS BY STARR IN VIEW OF BILAK. .................. 32
`A.
`The Petition Fails To Establish That Starr Discloses
`"Determining An Adjustment Signal . . .......................................... 32
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`2.
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`B.
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`C.
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`D.
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`E.
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`Page
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`2.
`3.
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`The Petition Fails To Establish That Starr Discloses "Analog
`Variation Parameter" (All Claims). .................................................. 38
`1. Monitoring Circuit B to determine a drift in threshold
`voltage differs from determining "a parameter of an
`analog portion of the integrated circuit" ................................ 38
`Petitioner Has Not Presented Any Competent Evidence That
`Starr's Threshold Voltage Is "Representative Of An
`Integrated Circuit Fabrication Process Variance Of The
`Integrated Circuit" ............................................................................ 42
`1.
`Petitioner presents no competent evidence that Starr's
`measured threshold voltage or voltage drift relates to
`IC fabrication process variance. ............................................. 42
`Starr's threshold voltage varies due to aging. ........................ 44
`Petitioner fails to establish that threshold voltages are
`inherently "representative of the integrated circuit
`fabrication process variance of the integrated circuit" .......... 46
`The Petition Fails To Establish That Starr Discloses
`"Determining An Analog Variation Parameter" (Claims 1, 2,
`8, 9, 18, and 19). ............................................................................... 48
`The Petition Fails To Establish That Starr Discloses
`"Determining An Operational Temperature Associated With
`The Analog Variation Parameter" (Claims 1, 2, 8, 9, and 19). ........ 51
`1.
`Starr regards changes in operating temperature and
`shifts in threshold voltages as two independent
`variables and do not associate them with each other ............. 52
`Alleged Similarity In Starr's Figure 10 And The '027
`Patent's Figure 8 Does Not Establish That Starr's
`Operating Temperature Is Associated With Its
`Threshold Voltage .................................................................. 54
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`2.
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`Page
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`3.
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`F.
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`Petitioner presents no basis for equating Starr's
`threshold voltage to Tsividis' threshold value. ...................... 57
`The Petition Fails To Establish That A POSA Would
`Combine Starr and Bilak (All Claims). ............................................ 59
`VIII. GROUND 2: CLAIMS 3, 5, 6, 7, 10, 11, 12, AND 20 ARE NOT
`RENDERED OBVIOUS BY STARR IN VIEW OF BILAK AND
`KANG ......................................................................................................... 63
`IX. CONCLUSION ........................................................................................... 66
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`TABLE OF AUTHORITIES
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`Case IPR2019-01196
`Patent No. 7,246,027
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` Page(s)
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`Cases
`Arendi S.A.R.L. v. Apple Inc.,
`832 F.3d 1355 (Fed. Cir. 2016) .......................................................................... 65
`DSS Technology Management, Inc. v. Apple Inc.,
`885 F.3d. 1367 (Fed. Cir. 2018) ......................................................................... 65
`E-One, Inc. v. Oshkosh Corp.,
`No. IPR2019-00161 (PTAB May 15, 2019) ....................................................... 10
`Int'l Rectifier Corp. v. IXYS Corp.,
`361 F.3d 1363 (Fed. Cir. 2004) .................................................................... 27, 31
`Kara Tech. Inc. v. Stamps.com, Inc.,
`582 F.3d 1341 (Fed. Cir. 2009) .......................................................................... 27
`NHK Spring Co., Ltd. v. Intri-Plextechnologies, Inc.,
`IPR2018-00752, Paper No. 8 (PTAB Sep. 12, 2018) ........................................... 9
`Omega Eng'g, Inc. v. Raytek Corp.,
`334 F.3d 1314 (Fed. Cir.2003) ........................................................................... 25
`Paice LLC v. Ford Motor Co.,
`881 F.3d 894 (Fed. Cir. 2018) ............................................................................ 26
`Phillips v. AWH Corp.,
`415 F.3d 1303 (Fed. Cir. 2005) .......................................................................... 27
`Tokai Corp. v. Easton Enters., Inc.,
`632 F.3d 1358 (Fed. Cir. 2011) .......................................................................... 62
`Univ. of Md. Biotechnology Inst. v. Presens Precision Sensing Gmbh,
`711 Fed. App'x. 1007 (Fed. Cir. 2017) ............................................................... 62
`ZTE (USA), Inc. v. Fractus S.A.,
`IPR2018-01461, Paper 10, 17 (PTAB Feb. 28, 2019) ........................................ 10
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`Case IPR2018-00215
`Patent No. 7,246,027
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`Page(s)
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`Statutes
`35 U.S.C. § 314(a) ..................................................................................................... 8
`Regulations
`37 C.F.R. § 42.1(b) .................................................................................................. 11
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`EXHIBIT LIST
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`Declaration of Professor Engin Ipek in Support of Patent
`Owner's Preliminary Response
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`Declaration of Dr. Thomas M. Conte in Support of Patent
`Owner's Opening Claim Construction Brief in VLSI
`Technology LLC v. Intel Corp., No. 1:18-cv-00966-CFC (D.
`Del., May 31, 2019), filed as Document No. 229-2, pp. 216-
`256 on Aug. 19, 2019
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`Declaration of Dr. Thomas M. Conte in Support of Patent
`Owner's Reply Claim Construction Brief in VLSI Technology
`LLC v. Intel Corp., No. 1:18-cv-00966-CFC (D. Del., July
`19, 2019), filed as Document No. 229-2, pp. 258-294 on
`Aug. 19, 2019
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`Excerpt of Joint Claim Construction Brief in VLSI
`Technology LLC v. Intel Corp., No. 1:18-cv-00966-CFC (D.
`Del., August 19, 2019), filed as Document No. 228
`
`Complaint in VLSI Technology LLC v. Intel Corp., No. 1:18-
`cv-00966-CFC (D. Del., June 28, 2018)
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`Scheduling Order in VLSI Technology LLC v. Intel Corp.,
`No. 1:18-cv-00966-CFC (D. Del., November 1, 2018), filed
`as Document 40
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`Petitioner Intel Corporation's Amended Identification of
`Prior Art Combinations in VLSI Technology LLC v. Intel
`Corp., No. 1:18-cv-00966-CFC, served on June 24, 2019
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`Excerpt of Merriam-Webster's Collegiate Dictionary, 10th
`Ed. (1999), p. 997
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`Excerpt of Cambridge International Dictionary of English by
`Cambridge University Press (1996), p. 1211
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`Excerpt of Cassell's English Dictionary by Cassell & Co.
`(1998), pp. 1063-64.
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`Ex. 2001
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`Ex. 2002
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`Ex. 2003
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`Ex. 2004
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`Ex. 2005
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`Ex. 2006
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`Ex. 2007
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`Ex. 2008
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`Ex. 2009
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`Ex. 2010
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`Patent 7,075,585
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`Excerpt of The New Oxford American Dictionary by Oxford
`University Press (2001), p. 1451
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`Excerpt of Operation and Modeling of The MOS Transistor
`by Yannis Tsividis by WCB/McGraw-Hill, 2nd Ed. (1999)
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`Ex. 2011
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`Ex. 2012
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`STATEMENT OF MATERIAL FACTS IN DISPUTE
`Petitioners did not submit a statement of material facts in this Petition.
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`Accordingly, no response is due pursuant to 37 C.F.R. § 42.23(a), and no facts are
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`admitted.
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`I.
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`INTRODUCTION
`Petitioner asks the Board to invalidate claims 1-3, 5-12 and 18-20 of the
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`U.S. Patent No. 7,246,027 ("the '027 patent") on two grounds. Pet. 5. The Board
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`should deny the petition under 314(a) because a trial will conclude at the district
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`court months before a final written decision is due based on the same art and
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`argument and involving the same claim construction issues. See Section II.
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`The Board should also deny institution on the merits. The Petition relies
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`primarily on Starr with supplementation from Bilak for limitations related to power
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`supply optimization and Kang for limitations related to "digital variation
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`parameter." Pet. 25-30, 48-51, 58-70. Starr involves a differential measurement
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`method that adjusts a supply voltage to a sensitive circuit to counter aging-induced
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`shifts in threshold voltages of these sensitive circuits. Ex. 1002, Abstract, 1:31-41,
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`1:55-2:10, 7:52-62. The adjustment may be made in accordance with Equation 1.
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`Id., 8:40-48.
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`In the above equation, VCC(nominal) is the initial VCC, ΔVtp and ΔVtn are
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`threshold voltage shifts for PMOS and NMOS transistors. Ex. 1002, 5:57-60,
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`7:52-62, 9:34-36; Ex. 1005, ¶¶ 56-59.
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`The differential measurement method compares the measured threshold
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`voltage of a continuously-biased transistor circuit (whose threshold voltage drifts
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`over time) with the measured threshold voltage of a baseline intermittently-biased
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`transistor circuit (whose threshold voltage is relatively stable over time). Id.
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`The adjustment of the supply voltage may further take into consideration a
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`separate and independent correction factor, f(T), "that is used to offset transistor
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`performance degradation due to elevated temperatures." Id., 9:31-38. This is
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`illustrated by Starr's Equation 2 (id.):
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`Starr does not disclose the elements that Petitioner contends it discloses
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`Starr's approach is markedly different from that of the '027 patent and
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`Petitioner fails to present any competent evidence that Starr actually discloses the
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`elements Petitioner contends it discloses. The challenged claims, for example,
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`require "determining/determine an adjustment signal for a power supply voltage
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`level of the integrated circuit based on [an] analog variation parameter with respect
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`to the operational temperature." Ex. 1001, claims 1, 8, 19 (emphasis added). The
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`claims therefore contemplate an interrelationship between the analog variation
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`parameter (which Petitioner maps to Starr's threshold voltage of circuit B) and an
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`operational temperature and an adjustment that is to be determined in light of this
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`interrelationship. Ex. 1001, 12:33-53; Ex. 2001, ¶¶ 16-19. But a comparison of
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`Starr's equations 1 and 2 shows that when determining the adjustment in the supply
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`voltage (Vcc'), Starr treats an adjustment based on the threshold voltage as
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`completely independent from an adjustment based on the temperature factor. Ex.
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`1002, 9:31-40; Ex. 1005, ¶¶ 56-59; Ex. 2001, ¶¶ 19, 45; Section VII.A. That is,
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`there is no determination of the Vcc' adjustment based on the threshold voltage or
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`threshold voltage change of a relevant circuit "with respect to" an associated
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`operational temperature. See also Section VII.E (explaining why the combination
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`does not disclose "determining/determine an operational temperature" that is
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`"associated with the analog variation parameter"); Ex. 2001, ¶¶ 38-41, 43-44.
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`As a second example, all challenged claims require "determining an analog
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`variation parameter representative of an integrated circuit fabrication process
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`variance of the integrated circuit." Petitioner maps the term "analog variation
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`parameter" to threshold voltage of a sensitive Circuit B that may contain analog
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`circuits. Pet. 31 (citing Ex. 1001, 4:63-66). The parties agree that "an analog
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`variation parameter" is at a minimum "a parameter of an analog portion of the
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`integrate circuit . . . ." Pet. 12. But Petitioner at most shows that Circuit B may
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`contain analog circuits, and fails to show that the measured threshold voltage or
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`changes in threshold voltage is that "of an analog portion of the integrated circuit"
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`as opposed to that of a digital portion or a that of a mixture of digital and analog
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`portions of the IC. See Section VII.B; Ex. 2001, ¶ 54. Petitioner also does not
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`contend, and certainly has not presented any evidence, that monitoring threshold
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`voltages of a digital portion or a mixture of digital and analog portions of the IC
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`could lead to determining a threshold voltage of an analog portion of the IC. See
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`Section VII.B.
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`The claims also require that the determined analog variation parameter be
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`one "representative of an integrated circuit fabrication process variance of the
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`integrated circuit." Ex. 1001, claims 1, 8, 18. Starr, however, only discloses that
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`its threshold voltage changes due to aging, but does not state that the threshold
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`voltage is one that varies due to fabrication process variance of the IC. Ex. 1002,
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`1:31-41, 3:65-4:7, 4:21-29; Sections VII.C.1-VII.C.2; Ex. 2001, ¶¶ 30-32.
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`Petitioner also fails to present competent evidence that Starr's threshold voltage
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`inherently varies due to fabrication process variance of the IC. See
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`Section VII.C.3; Ex. 2001, ¶¶ 57-60.
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`Furthermore, while Petitioner maps "an analog variation parameter" to a
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`threshold voltage of sensitive Circuit B, the citations used to demonstrate that such
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`a threshold voltage is "determin[ed]" relate either to determining a change in
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`threshold voltage over time or to measuring a threshold voltage of circuit 122, a
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`replica of Circuit B. Pet. 32-34. "Determining" a change in threshold voltage
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`differs from determining an absolute value of a threshold voltage, and the threshold
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`voltage of a replica circuit 122 generally differs from that of the regular working
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`Circuit B. See Section VII.D; Ex. 2001, ¶¶ 33, 51-53.
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`In sum, Starr does not disclose "determining" a threshold voltage that is "of
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`an analog portion of the IC" and "representative of an integrated circuit fabrication
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`process variance of the integrated circuit." Starr also does not disclose
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`"determining/determine an operational temperature associated with the analog
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`variation parameter" or "determining/determine an adjustment signal for a power
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`supply voltage level of the integrated circuit based on [an] analog variation
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`parameter with respect to the operational temperature."
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`Petitioner has not shown that a POSA would have combined Starr and
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`Bilak to arrive at the '027 inventions with a reasonable expectation of success.
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`A POSA would not have had a reason to combine Starr and Bilak or had a
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`reasonable expectation of success to incorporate Bilak's trial-and-error
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`optimization method in Starr to obtain a minimum Vcc' during operation.
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`Ex. 2001, ¶¶ 22, 55, 63-65. First, Petitioner's first reason for combining the
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`references—that a POSA would have been motivated to "further reduce power
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`consumption by determining an optimized supply voltage of a circuit (Vcc) during
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`manufacture" (Pet. 27, emphasis in original)—is irrelevant to the challenged
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`claims that are directed to optimization during operation. Ex. 2001, ¶ 22. For
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`example, the claims recite adjustment based in part on an "operational"
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`temperature, which a POSA would understand is a temperature measured during
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`operation. Id. A POSA would also understand that adjustment based on a
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`parameter measured during operation would take place during operation. Id.
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`Hence, what a POSA may or may not do during manufacture is irrelevant to
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`whether they would have modified Starr to arrive at the inventions, i.e., whether
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`they would have had a reason to incorporate Bilak's alleged power optimization
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`method into Starr for power supply optimization during operation. See Section
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`VII.F.
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`Second, contrary to Petitioner's assertion (Pet. 28-30, 50-51), a POSA also
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`would not have been motivated to modify Starr to find a minimum Vcc' in light of
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`Bilak during operation. Ex. 2001, ¶¶ 63-65. This is because Bilak's method
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`requires multiple trial-and-error tests to locate the optimal value. See Ex. 1003,
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`Figs. 7a, 7b, 8a, 8b. But Starr's differential measurement mechanism is not
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`suitable for frequent threshold voltage measurements. Ex. 2001, ¶¶ 64, 55; Ex.
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`1002, 1:65-2:1, 7:52-62, 10:5-10, 10:40-57. This is because Starr's method
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`depends on the relative stability of the threshold voltage of baseline intermittently-
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`biased circuit, which in turn requires a relatively low testing frequency and
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`attendant exposure to bias voltage. See Ex. 1002, 1:65-2:3, 7:52-59, 10:5-10; Ex.
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`2001, ¶¶ 46-49, 55, 64. Otherwise, the baseline intermittently-biased circuit would
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`be subject to too much bias and its threshold voltage would start to drift
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`significantly. Id. Multiple trial-and-error tests would increase the frequency at
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`which the intermittently-biased circuit would be subject to bias voltage and would
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`cause a larger shift in baseline threshold voltage. Ex. 2001, ¶¶ 64, 55. The larger
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`shift in baseline threshold voltage in turn would decrease the accuracy in Starr's
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`measurement of threshold voltage shifts and the attendant adjustment. Id. A
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`POSA thus would not have had a reason to make such a modification that would
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`lead to increased error rate over time or had a reasonable expectation of success in
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`incorporating such a method into Starr and having the Starr method still work. See
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`Section VII.F.
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`Moreover, to the extent that Petitioner argues that the Vcc' optimization may
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`done without repeating the threshold voltage measurement (and Petitioner has not
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`articulated how this could be done), then such an optimization would not be based
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`on an adjustment signal that is in turn "based on the analog variation parameter."1
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`E.g., claim 1 ("determining an adjustment signal . . . based on the analog variation
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`parameter with respect to the operational temperature" and "adjusting a regulation
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`signal . . . based on the adjustment signal to optimize power consumption of the
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`integrated circuit"); Ex. 2001, ¶¶ 62, 65. That is, if Petitioner contends that the
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`Vcc' optimization may done without repeating the threshold voltage measurements,
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`the resulting process is not one covered by the '027 claims. As such, whether a
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`1 Unless indicated otherwise, all text emphases and highlighting in
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`quotations and snapshots are Patent Owner's additions.
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`POSA would have been motivated to arrive at those different inventions sheds no
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`light on whether they would have been motivated to arrive at the '027 inventions.
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`Petitioner fails to show a likelihood of success for Ground 2 claims
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`because it has not provided a cogent reason for determining both an analog
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`variation parameter and a digital variation parameter.
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`Ground 2 claims require determining both an analog variance parameter and
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`a digital variance parameter. See Ex. 1001, claims 3, 10, 20. Concerning these
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`claims, Petitioner fails to show that a POSA would have been motivated to
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`measure a parameter "of an analog portion of" the IC and separately one "of a
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`digital portion of" the IC and then adjust the supply voltage based on these two
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`individual parameters. See Section VIII. None of the references even alludes to
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`the need for this dual determination, and certainly not to any of inventors' insights
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`associated with the inventions (see Ex. 1001, 2:16-30). Without answering this
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`basic question, Petitioner has failed to present competent evidence that a POSA
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`would have been motivated to modify Starr to monitor both a parameter of an
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`analog portion of the IC and a parameter of a digital portion of the IC.
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`For these and reasons stated below, the Board should deny the petition.
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`The discussions below begin with why the Board should deny the petition
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`under 35 U.S.C. § 314(a). This discussion is then followed by technical
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`discussions that include an introduction of the '026 patent and the prior art
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`references, proposed construction for disputed terms and reasons why the Petition
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`has failed to establish a likelihood of success in showing that Starr, Bilak and/or
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`Kang render obvious any of the challenged claims.
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`II. THE BOARD SHOULD DENY THE PETITION UNDER 314(a)
`BECAUSE THE DISTRICT COURT ACTION IS IN AN ADVANCED
`STAGE
`Patent Owner asserted the '027 patent against Petitioner on June 28, 2018.
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`Ex. 2005 [Complaint] at 1, 47, 136-137. Petitioner waited until June 27, 2019—
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`the day before the 315(b) deadline—to file its Petition. Pet. 82. As of the date of
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`this filing, the district court case has advanced significantly. The parties have
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`completed their Markman briefing. Ex. 2004 [Joint CC Br.]; Ex. 2006 [Dkt. 40] at
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`5 (claim construction schedule). The fact discovery is set to close on November
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`21, 2019 and trial is scheduled for November 2, 2020. Ex. 2006 [Dkt. 40] at 2, 9.
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`In contrast, the Board's Final Written Decision is not due until about January 11,
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`2021, more than two months after the district court's trial.
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`The Board routinely exercises its discretion to deny institution when it
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`would be inefficient to proceed in light of the corresponding district court litigation
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`schedule. See NHK Spring Co., Ltd. v. Intri-Plextechnologies, Inc., IPR2018-
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`00752, Paper No. 8 at 20 (PTAB Sep. 12, 2018) (precedential) (denying institution
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`in part because "[t]he district court proceeding, in which Petitioner asserts the same
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`prior art and arguments, is nearing its final stages, with expert discovery ending on
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`[a date 1.5 months away], and a 5-day jury trial set to begin on [a date about six
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`months away]" while the Board's FWD would not be due for another year).
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`More recently, in E-One, Inc. v. Oshkosh Corp., the Board denied institution
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`under § 314(a) when a district court trial is scheduled eleven months away. See
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`No. IPR2019-00161, Paper 16 (PTAB May 15, 2019) (referencing §314(a) as a
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`"threshold issue"). Similarly, in ZTE (USA), Inc. v. Fractus S.A., IPR2018-01461,
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`Paper 10, 17 (PTAB Feb. 28, 2019), the Board denied institution despite the fact
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`that a final trial date had not yet been, but was expected to be set "before a final
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`decision is reached . . . ." As in E-One, the Board emphasized the fact that
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`Petitioner relied on "substantially the same" prior art, arguments, and expert
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`testimony in the IPR and in the district court; and that the district court issued
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`claim construction order "which covers virtually all of the claim terms" at issue in
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`the IPR under the same claim construction standard.
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`The instant Petition presents an equally compelling case for denial under
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`Section 314(a). As Petitioner acknowledges, the same claim construction disputes
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`are present both here and at the district court case, to be construed under the same
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`Philips claim construction standard. See Pet. 12-13. A Markman hearing on the
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`terms under dispute is scheduled for November 5, 2019. Petitioner relies on the
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`same prior art and arguments in the district court action. Ex. 2007 [2019-06-24
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`Amended Prior Art List] at 4. Trial at the district court is expected to conclude
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`more than two months before the final written decision. Ex. 2006 [Dkt. 40] at 9.
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`Case IPR2019-01196
`Patent No. 7,246,027
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`Institution under this circumstance would contravene the AIA's objective of
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`"provid[ing] an effective and efficient alternative to district court litigation,"
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`because the Board would then have to expend resources on the very same issues.
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`Gen. Plastic, Paper 19, 16–17; see also 37 C.F.R. § 42.1(b) (the trial practice
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`procedures "shall be construed to secure the just, speedy, and inexpensive
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`resolution of every proceeding").
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`Discretionary denial is also appropriate to prevent Petitioner from
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`circumventing the statutory estoppel in the America Invents Act or taking two bites
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`at the same apple. Specifically, by delaying this Petition until just before the
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`statutory deadline, Petitioner has ensured that, if the Board institutes a review, the
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`Board's final written decision will not issue until after the district court trial
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`decision and Petitioner will not be estopped from attacking invalidity at the district
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`court trial. That way, Petitioner can have two shots to invalidate the patents, once
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`at the district court level and a second time before the PTAB. That gamesmanship
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`again results in a waste of the PTAB and the judicial resources.
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`Therefore, the Board should exercise its discretion to deny the Petition in its
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`entirety. July 2019 Update To Trial Practice Guide at 25 (discretionary denial may
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`take into consideration "events in other proceedings related to the same patent . . .
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`in district cour[t]," in particular "where, due to petitioner's delay, the Board likely
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`would not have been able to rule on patentability until after the district court
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`Case IPR2019-01196
`Patent No. 7,246,027
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`trial date").
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`III. SUMMARY OF THE '027 PATENT
`U.S. Patent No. 7,246,027, entitled "Power Optimization of a Mixed-Signal
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`System on an Integrated Circuit" (the "'027 patent"), was filed on March 11, 2005.
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`Ex. 1001 at 1. The patent describes technology that relates generally to optimizing
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`power consumption for individual ICs, and in particular those used in portable
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`electronic equipment. See id., 1:7-8, 58-59. Traditionally, "the power reducing
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`techniques were under a worst-case assumption and not individually optimized on
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`a chip-by-chip basis" such that "integrated circuit circuits would be consuming
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`more power than needed." Id., 2:9-15.
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`Another difficulty in optimizing IC power consumption in portable devices
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`is that these ICs generally have both digital and analog components with vastly
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`different "power consumption considerations." Id., 2:16-30. For example, lower
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`operational temperatures are "favorable for digital component operation" but may
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`be detrimental to the operation of analog components. Id., 2:23-26.
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`The '027 patent provides a solution "for conserving power of a system-on-a-
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`chip having analog circuitry." Id., 2:40-41. With methods described in the '027
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`patent, "power consumption is optimized on an IC-by-IC basis, as well as over
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`time." Id., 3:1-2. For example, the '027 patent teaches a "power conserving circuit
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`250 [shown below that] has a component addressing digital circuitry power
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`Case IPR2019-01196
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`optimization-power conserving circuit 92 [dashed-line box in green], and a second
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`component addressing analog circuitry power optimization-analog power
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`conservation circuit 209 [dashed-line box in red]. Each optimization circuit
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`provides respective inputs [tan, pink] to the comparator 260. The comparator
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`provides an adjust supply voltage signal 252." Id., 14:32-39. More specifically,
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`the supply voltage signal is adjusted based on "the greater of the input values
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`provided" by digital adjust voltage 217 and the analog AVDD adjust signal 218. Id.,
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`14:39-40.
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`Id., Fig. 11 (annotated by Patent Owner).
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`In the above embodiment, independent variation compensation
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`Case IPR2019-01196
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`considerations are applied to analog circuitry and digital circuitry. For example,
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`the analog power conserving circuit 209 includes a process sense module 208
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`(blue) that measures the analog variation parameter. Id., 12:23-24. One example
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`of an analog variation parameter is the threshold voltage of the analog circuit. See
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`id., 10:63-64.
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`The analog power conserving circuit 209 includes an operational
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`temperature sensor (red) that monitors the operational temperature. The output of
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`the process sense module 208, i.e., analog variation parameter signal 215 (green),
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`and the output of the operational temperature sensor, i.e., temperature signal 216
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`(brown), are fed to the AVDD look-up table 214 (orange). See id., Fig. 8.
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`Pet. 9 (citing Ex. 1001, Fig. 8 (annotated by Petitioner)).
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`As stated in the '027 patent, "the absolute value of the threshold voltage |Vt|
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`[red] trends downward as the as the operational temperature T [blue] increases.
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`The opposite effect results as the operational temperature T decreases, causing the
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`absolute value of the threshold voltage |Vt| to increase. Thus, for low temperature,
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`a higher threshold voltage |Vt| results, leaving less capacity for headroom
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`voltage."2 Id., 12:10-16. "[I]nformation regarding the analog circuitry headroom
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`can be used to in determining an adjust VDD signal . . . ." Id., 11:11-13.
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`
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`Id., Fig. 7b (annotated by Petitioner).
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`More specifically, in one preferred embodiment, an AVDD look-up table 214
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`is provided and "contains information and data representing the threshold voltage
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`2 In the context of the '027 patent, "the term 'headroom voltage' is
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`understood to be the available signal swing in analog circuitry before a
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`performance loss becomes unacceptable. . . ." Ex. 1001, 11:13-16.
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`curve, the operational temperature curve, and voltage VDD curve with respect to the
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`Case IPR2019-01196
`Patent No. 7,246,027
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`headroom voltage plot shown in FIG. 7b." Id., 12:44-50. This AVDD look-up table
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`then generates an AVDD adjust signal 218 "responsive to the analog variations
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`parameter signal 215, based on the operational temperature signal 216." Id., 12:50-
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`53.
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`As for digital circuitry, the '027 patent teaches that in the digital power
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`conserving circuit 92 of one embodiment, "[t]he comparator 116 compares the
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`measured processing speed 110 with a critical processing speed 112 to determine
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`whether the supply voltage can be adjusted 114 and by how much." Id., 9:28-31.
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`"If the measured processing time is less than the critical processing time, the
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`supply voltage may be decreased, which slows the processing speed of the portion
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`of the IC 100 but also reduces po
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