PGR2019-00042
`Patent 10,003,553
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`FLEX LOGIX TECHNOLOGIES INC.,
`
`Petitioner
`
`V.
`
`VENKAT KONDA,
`
`Patent Owner
`
`____________
`
`Case PGR2019-00042
`
`Patent 10,003,553 B2
`
`_________
`
`MOTION TO AMEND UNDER 37 C.F.R. § 42.221
`
`Page i of 57
`
`Page 1 of 57
`
`FLEX LOGIX EXHIBIT 1041
`Flex Logix Technologies Inc. v. Venkat Konda
`PGR2019-00037
`
`
`Patent 10,003,553
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`FLEX LOGIX TECHNOLOGIES INC.,
`
`Petitioner
`
`V.
`
`VENKAT KONDA,
`
`Patent Owner
`
`____________
`
`Case PGR2019-00042
`
`Patent 10,003,553 B2
`
`_________
`
`MOTION TO AMEND UNDER 37 C.F.R. § 42.221
`
`Page i of 57
`
`Page 1 of 57
`
`FLEX LOGIX EXHIBIT 1041
`Flex Logix Technologies Inc. v. Venkat Konda
`PGR2019-00037
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`TABLE OF CONTENTS
`
`
`
`I.
`
`INTRODUCTION AND STATEMENT OF RELIEF REQUESTED ..... 1
`
`II.
`
`PATENT OWNER'S RESPONSE TO PETITIONER'S CHALLENGES
`
`3
`
`A. CHALLENGE GROUND 1 ............................................................................................. 3
`
`B. CHALLENGE GROUND 2 ............................................................................................. 5
`
`III. COMPLIANCE WITH STATUTORY AND REGULATORY
`REQUIREMENTS ........................................................................................ 8
`
`A. The Proposed Amendments Include A Reasonable Number Of Substitute Claims ... 8
`
`B. The Substitute Claims Do Not Enlarge The Scope Of The Claims Or Introduce New
`Subject Matter ................................................................................................................... 8
`
`C. The Proposed Amendments Respond To A Ground Of Unpatentability Alleged By
`The Petitioner .................................................................................................................... 9
`
`D. Explanation Of Substitute Claims And Support In The Original Disclosure And
`Earlier-Filed Disclosure .................................................................................................. 10
`
`IV. PATENTABILITY OF THE SUBSTITUTE CLAIMS ........................... 28
`
`V. CONCLUSION ............................................................................................ 29
`
`
`
`Page ii of 57
`
`
`Page 2 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`I.
`
`INTRODUCTION AND STATEMENT OF RELIEF REQUESTED
`
`Prior to filing this motion, pursuant to 37 C.F.R. § 42.221(a) Patent Owner
`
`complied with the conference call requirement with the Board on December 3,
`
`2019 (Paper 15). During the call, the Board directed the parties to the Board’s
`
`order in Lectrosonics, Inc. v. Zaxcom, Inc., Case IPR2018-01129, Paper 15 (PTAB
`
`Feb. 25, 2019) (precedential), which provides information and guidance on
`
`motions to amend, and to the Notice Regarding a New Pilot Program Concerning
`
`Motion to Amend Practice and Procedures in Trial Proceedings under the America
`
`Invents Act before the Patent Trial and Appeal Board, 84 Fed. Reg. 9497 (Mar. 15,
`
`2019). Accordingly, Patent Owner is submitting this paper by following those
`
`instructions1.
`
`Patent Owner requests that claims 1-20 of U.S. Patent No. 10,003,553 (“the
`
`‘553 Patent,” Ex. 1001) be cancelled and that new claims 21-40 be treated on a
`
`contingent basis. See Lectrosonics, Inc. v. Zaxcom, Inc., Case IPR2018-01129,
`
`(PTAB, Feb. 25, 2019) (Paper 15) (“A request to cancel claims will not be
`
`regarded as contingent. However, a request to substitute claims ordinarily will be
`
`
`1 Prior to filing this paper, in an email communication the Board approved
`
`that the page limit for Patent Owner’s motion to amend is increased to 30 pages.
`
`
`
`Page 1 of 57
`
`
`Page 3 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`treated as contingent.”). This Motion To Amend Under 37 C.F.R. § 42.221 is made
`
`on a contingent basis and is made in lieu of a response under 37 C.F.R. § 42.220.
`
`This Motion satisfies the requirements for a motion to amend. Claims 1-20
`
`are the challenged claims in this proceeding. Accordingly substitute claims are
`
`presented for challenged claims 1-202 in Appendix. This constitutes a “reasonable
`
`number of substitute claims.” 35 U.S.C. § 326(d)(1)(B). Additionally, the
`
`substitute claims: (1) do not “enlarge the scope of the claims;” (2) do not
`
`“introduce new [subject] matter;” and (3) “respond to [the] ground[s] of
`
`unpatentability involved in the trial.” 35 U.S.C. § 326(d)(3); 37 C.F.R. §
`
`42.221(a)(2)(i), (ii). Patent Owner has therefore satisfied his burden of production.
`
`Patent Owner respectfully requests preliminary guidance from the Board
`
`concerning this Motion, in accordance with the New Pilot Program Concerning
`
`Motion to Amend Practice. See 84 Fed. Reg. 9,497 (Mar. 15, 2019).
`
`
`2 In addition to this PGR, the Board instituted another PGR2019-00037 filed
`
`by the same Petitioner concurrently on the ‘553 Patent. During the conference call
`
`with the Board on December 3, 2019, Patent Owner indicated to the Board that he
`
`intends to move for the same amendments to the claims in both proceedings.
`
`Accordingly, the same amended claims are submitted in both the proceedings, i.e.
`
`PGR2019-00042 and PGR2019-00037.
`
`
`
`Page 2 of 57
`
`
`Page 4 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`Because Patent Owner changed the language of the substitute independent
`
`claims 21 and 31, it is necessary to amend the three unchallenged dependent claims
`
`28, 36, and 40 to provide appropriate antecedent basis in them. Furthermore since
`
`the Board instituted another PGR2019-00037 by the same Petitioner concurrently
`
`and all the claims 1-20 are challenged in PGR2019-00037, all the claims 1-20 are
`
`amended with substitute claims 21-40 in the motion to Amend for PGR2019-00037
`
`filed concurrently. Accordingly Patent Owner is filing this motion to amend for
`
`both the PGR2019-00037 and PGR2019-00042, and submitting the same substitute
`
`amended claims for the both the PGR2019-00037 and PGR2019-00042.
`
`II. PATENT OWNER'S RESPONSE TO PETITIONER'S CHALLENGES
`
`A. CHALLENGE GROUND 1
`
`Petitioner’s challenge Ground 1 is that Claims 1-7, 9-15, and 17-19 are
`
`unpatentable under AIA 35 U.S.C. § 102(a)(1) as being anticipated by Published
`
`PCT Application No. WO 2008/109756 (“Konda ’756 PCT”) (Ex. 1009).
`
`Subject matter of substitute independent claim 21 is distinguishable over
`
`Konda ‘756 PCT because switch of size
`
` in a stage comprising
`
` inputs and
`
` outputs with
`
` as disclosed in FIG. 2E of the ‘553 patent. In contrast
`
`Konda ‘756 PCT shows switch of size
`
` in a stage comprising
`
` inputs and
`
`
`
`Page 3 of 57
`
`
`d
`i
`
`d
`
`o
`
`d i
`
`0d
`
`id
`
`0d
`
`d i
`
`0d
`
`id
`
`Page 5 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
` outputs with only
`
`. Therefore Konda ‘756 PCT does not anticipate the
`
`subject matter of the substitute claim 21 under AIA 35 U.S.C. § 102(a)(1).
`
`Subject matter of substitute independent claim 21 is distinguishable over
`
`Konda ‘756 PCT because at least one input of said
`
` inputs of said switch of a
`
`first stage of said plurality of stages of said ring of a first partial multi-stage
`
`hierarchical network of said plurality of partial multi-stage hierarchical networks
`
`connected from one output of said
`
` outputs of said switch of a second stage of
`
`said plurality of stages of said ring of said first partial multi-stage hierarchical
`
`network or a second partial multi-stage hierarchical network of said plurality of
`
`partial multi-stage hierarchical networks, as disclosed in FIG. 2E of the ‘553
`
`patent. In contrast Konda ‘756 PCT does not disclose this capability. Therefore
`
`Konda ‘756 PCT does not anticipate the subject matter of the substitute claim 21
`
`under AIA 35 U.S.C. § 102(a)(1).
`
`Subject matter of substitute independent claim 31 is distinguishable over
`
`Konda ‘756 PCT because switch of size
`
` in a stage comprising
`
` inputs and
`
` outputs with
`
` as disclosed in FIG. 2E of the ‘553 patent. In contrast
`
`Konda ‘756 PCT shows switch of size
`
` in a stage comprising
`
` inputs and
`
` outputs with only
`
`. Therefore Konda ‘756 PCT does not anticipate the
`
`subject matter of the substitute claim 31 under AIA 35 U.S.C. § 102(a)(1).
`
`
`
`Page 4 of 57
`
`
`d
`i
`
`d
`
`o
`
`d
`i
`
`d
`
`o
`
`d
`i
`
`d
`
`o
`
`0d
`
`id
`
`0d
`
`d i
`
`0d
`
`id
`
`0d
`
`d i
`
`0d
`
`id
`
`0d
`
`Page 6 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`Subject matter of substitute independent claim 31 is distinguishable over
`
`Konda ‘756 PCT because at least one input of said
`
` inputs of said switch of a
`
`first stage of said plurality of stages of a first ring of said at least one ring of a first
`
`partial multi-stage hierarchical network of said plurality of partial multi-stage
`
`hierarchical networks connected from one output of said
`
` outputs of said switch
`
`of a second stage of said plurality of stages of said first ring or a second ring of
`
`said at least one ring of said first partial multi-stage hierarchical network or a
`
`second partial multi-stage hierarchical network of said plurality of partial multi-
`
`stage hierarchical networks, as disclosed in FIG. 2E of the ‘553 patent. In contrast
`
`Konda ‘756 PCT does not disclose this capability. Therefore Konda ‘756 PCT does
`
`not anticipate the subject matter of the substitute claim 31 under AIA 35 U.S.C. §
`
`102(a)(1).
`
`B. CHALLENGE GROUND 2
`
`Petitioner’s challenge Ground 2 is that Claims 1-7, 9-15, and 17-19 are
`
`unpatentable under AIA 35 U.S.C. § 103 as obvious over Konda ’756 PCT in view
`
`of U.S. Patent No. 6,940,308 to Wong (“Wong”) (Ex. 1008).
`
`Subject matter of substitute independent claim 21 is distinguishable over
`
`Konda ‘756 PCT in view of Wong because switch of size
`
` in a stage
`
`
`
`Page 5 of 57
`
`
`id
`
`0d
`
`d i
`
`0d
`
`Page 7 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`comprising
`
` inputs and
`
` outputs with
`
` as disclosed in FIG. 2E of the
`
`‘553 patent. In contrast Konda ‘756 PCT in view of Wong shows switch of size
`
` in a stage comprising
`
` inputs and
`
` outputs with only
`
`. Therefore
`
`Konda ‘756 PCT in view of Wong does not cure the deficiency that
`
`and so
`
`does not render the subject matter of the substitute claim 21 as obvious under AIA
`
`35 U.S.C. § 103.
`
`Subject matter of substitute independent claim 21 is distinguishable over
`
`Konda ‘756 PCT in view of Wong because at least one input of said
`
` inputs of
`
`said switch of a first stage of said plurality of stages of said ring of a first partial
`
`multi-stage hierarchical network of said plurality of partial multi-stage hierarchical
`
`networks connected from one output of said
`
` outputs of said switch of a second
`
`stage of said plurality of stages of said ring of said first partial multi-stage
`
`hierarchical network or a second partial multi-stage hierarchical network of said
`
`plurality of partial multi-stage hierarchical networks, as disclosed in FIG. 2E of the
`
`‘553 patent. In contrast Konda ‘756 PCT in view of Wong does not disclose this
`
`capability. Therefore Konda ‘756 PCT in view of Wong does not render the subject
`
`matter of the substitute claim 21 as obvious under AIA 35 U.S.C. § 103.
`
`Subject matter of substitute independent claim 31 is distinguishable over
`
`Konda ‘756 PCT in view of Wong because switch of size
`
` in a stage
`
`
`
`Page 6 of 57
`
`
`d
`i
`
`d
`
`o
`
`d
`i
`
`d
`
`o
`
`d
`i
`
`d
`
`o
`
`id
`
`0d
`
`d i
`
`0d
`
`id
`
`0d
`
`id
`
`0d
`
`d i
`
`0d
`
`Page 8 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`comprising
`
` inputs and
`
` outputs with
`
` as disclosed in FIG. 2E of the
`
`‘553 patent. In contrast Konda ‘756 PCT in view of Wong shows switch of size
`
` in a stage comprising
`
` inputs and
`
` outputs with only
`
`. Therefore
`
`Konda ‘756 PCT in view of Wong does not cure the deficiency that
`
`and so
`
`does not render the subject matter of the substitute claim 31 as obvious under AIA
`
`35 U.S.C. § 103.
`
`Subject matter of substitute independent claim 31 is distinguishable over
`
`Konda ‘756 PCT in view of Wong because at least one input of said
`
` inputs of
`
`said switch of a first stage of said plurality of stages of a first ring of said at least
`
`one ring of a first partial multi-stage hierarchical network of said plurality of
`
`partial multi-stage hierarchical networks connected from one output of said
`
`
`
`outputs of said switch of a second stage of said plurality of stages of said first ring
`
`or a second ring of said at least one ring of said first partial multi-stage hierarchical
`
`network or a second partial multi-stage hierarchical network of said plurality of
`
`partial multi-stage hierarchical networks, as disclosed in FIG. 2E of the ‘553
`
`patent. In contrast Konda ‘756 PCT in view of Wong does not disclose this
`
`capability. Therefore Konda ‘756 PCT in view of Wong does not render the subject
`
`matter of the substitute claim 31 as obvious under AIA 35 U.S.C. § 103.
`
`
`
`
`
`Page 7 of 57
`
`
`d
`i
`
`d
`
`o
`
`d
`i
`
`d
`
`o
`
`d
`i
`
`d
`
`o
`
`id
`
`0d
`
`d i
`
`0d
`
`id
`
`0d
`
`id
`
`0d
`
`Page 9 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`III. COMPLIANCE WITH STATUTORY AND REGULATORY
`REQUIREMENTS
`
`A. The Proposed Amendments Include A Reasonable Number Of Substitute
`Claims
`
`The proposed amendments are presented in the Appendix attached hereto,
`
`pursuant to 37 C.F.R. § 42.221(b). Patent Owner cancels claims 1-20 and proposes
`
`substitute claims, claim 21-40. Because the challenged claims have been cancelled
`
`and substitute claims are proposed, this constitutes a “reasonable number of
`
`substitute claims.” 37 C.F.R. § 42.221(a)(3). As shown in the Appendix, claims 21-
`
`40 include all of the limitations of original claims 1-20. Changes in claims 1-20 are
`
`shown by underlining for additions and brackets for deletions.
`
`B. The Substitute Claims Do Not Enlarge The Scope Of The Claims Or
`Introduce New Subject Matter
`
`Substitute claims 21-30 are based on cancelled claims 1-20, but further
`
`include narrowing amendments. Substitute claims 21-40 are narrower than original
`
`claims 1 – 20 because the “network” in Claims 1 – 20 is substituted with “multi-
`
`stage hierarchical network” in claims 21 – 40. Term “a ring” in claims 21 and 27-
`
`28 and term “at least one ring” introduced in claims 31, 36, and 40 narrows claims
`
`21, 27, 28, 31, 36, and 40. Usage of term “entry stage” in claim 21 and 31 and
`
`usage of term “last stage” in claims 21 and 31, for example “each inlet link of
`
`said... is connected to... said switch of size
`
` of [a] either said entry stage or
`
`
`
`Page 8 of 57
`
`
`d i
`
`0d
`
`Page 10 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`said last stage of said plurality of stages” narrows both of the independent claims
`
`since each inlet and each outlet are connected to either entry stage or last stage of
`
`said plurality of stages, which in turn narrows all of the dependent claims as well.
`
`Definition of term “a plurality of multiplexers of size
`
`” and referring to them
`
`in claims 21 and 31 narrows both of the independent claims, which in turn narrows
`
`all of the dependent claims as well.
`
`Phrase “said switch comprising at least one input connected from one of the
`
`outputs of said switch of a second stage of said plurality of stages of said ring of
`
`one partial multi-stage hierarchical network of said plurality of partial multi-stage
`
`hierarchical networks” in claims 21 and 31 narrows both of the independent
`
`claims, which in turn narrows all of the dependent claims as well.
`
`Because substitute claims 21-40 narrow the scope of claims 1-20, the
`
`substitute claims do not expand the scope of the patent and thus comply with the
`
`requirements of 37 C.F.R. § 42.221(a)(2)(ii).
`
`C. The Proposed Amendments Respond To A Ground Of Unpatentability
`Alleged By The Petitioner
`
`The proposed substitute claims respond to an asserted ground of
`
`unpatentability. The substitute claims respond to Petitioner’s argument that claims
`
`1-20 are unpatentable under AIA 35 U.S.C. § 112(b) as failing to particularly point
`
`out and distinctly claim the subject matter (ground 1), unpatentable under AIA 35
`
`
`
`Page 9 of 57
`
`
`2d
`
`Page 11 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`U.S.C. § 112(a) as failing to satisfy the written description requirement (ground 2),
`
`and Claims 1-20 are unpatentable under AIA 35 U.S.C. § 112(a) as failing to
`
`satisfy the enablement requirement (ground 3).
`
`D. Explanation Of Substitute Claims And Support In The Original Disclosure
`And Earlier-Filed Disclosure
`
`Support for the proposed substitute claims is found in “the original disclosure of
`
`the patent.” See 37 C.F.R. § 42.221(b)(1)-(2). The ‘553 patent is a continuation
`
`application to patent application No. 14/199,168, filed on March 6, 2014 (“the ‘168
`
`application”, Ex. 1005), which was granted as U.S. Patent No. 9,374,322 (“the
`
`‘322 patent”, Ex. 1035) which in turn is a continuation application to PCT
`
`Application No. PCT/US12/53814 (the ’814 PCT application, Ex. 1006), filed
`
`September 6, 2012 which in turn is continuation-in-part and claims priority to U.S.
`
`Provisional Patent Application Serial No. 61/531,615, filed September 7, 2011
`
`(“the ‘615 provisional application”, Ex. 1007).
`
`Exemplary support for the proposed substitute claims is provided in the following
`
`table with reference to the above-identified patent applications and/or patents
`
`(bracketed language for the deletions is not shown in the following table to save
`
`space, but is shown in the substitute claims in the Appendix).
`
`
`
`
`
`Page 10 of 57
`
`
`Page 12 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`Claim 21. (Proposed substitute for original claim 1):
`
`Exemplary
`
`Support
`
`21. A multi-stage hierarchical network implemented in a non-
`
`transitory medium comprising a plurality of partial multi-stage
`
`Ex. 1001
`
`hierarchical networks and a plurality of inlet links and a plurality of
`
`8:57- 9:3,
`
`outlet links,
`
`said plurality of partial multi-stage hierarchical networks arranged in a
`
`two-dimensional grid of a plurality of rows and a plurality of columns;
`
`and
`
`each partial multi-stage hierarchical network of said plurality of partial
`
`multi-stage hierarchical networks comprising a ring and said ring
`
`comprising a plurality of stages; and
`
`one of said plurality of stages comprising an entry stage and one of said
`
`plurality of stages comprising a last stage; and
`
`each stage of said plurality of stages comprising a switch of size
`
`,
`
`where
`
` and
`
`and said switch of size
`
` having
`
` inputs
`
`and
`
` outputs; and said switch of size
`
` further comprising a
`
`plurality of multiplexers of size
`
` with each multiplexer of said
`
`9:27-61
`
`
`
`
`
`Ex. 1001
`
` 5:1-3,
`
`8:57- 9:3,
`
`11:33-37,
`
`9:62-10:9,
`
`18:44-19:2,
`
`19:2-19-5,
`
`17:16-22,
`
`20:37-41,
`
`20:42-22:53,
`
`
`
`Page 11 of 57
`
`
`d i
`
`0d
`
`2id
`
`2od
`
`d i
`
`0d
`
`id
`
`0d
`
`d i
`
`0d
`
`2d
`
`Page 13 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`plurality of multiplexers of size
`
` comprising
`
` inputs and an
`
`22:37-53,
`
`output; and
`
`said
`
` inputs of said switch of size
`
`, and said
`
` outputs of said
`
`switch of size
`
`, connected to a plurality of internal connections or
`
`24:48-60,
`
`47:27-29
`
`
`
`a plurality of external hop wires; and
`
`said switch of size
`
` where
`
` or at least one input of said
`
`
`
`inputs of said switch of a first stage of said plurality of stages of said
`
`ring of a first partial multi-stage hierarchical network of said plurality
`
`of partial multi-stage hierarchical networks connected from one output
`
`of said
`
` outputs of said switch of a second stage of said plurality of
`
`stages of said ring of said first partial multi-stage hierarchical network
`
`or a second partial multi-stage hierarchical network of said plurality of
`
`partial multi-stage hierarchical networks, and
`
`each inlet link of said plurality of inlet links is connected to one or
`
`more of Said
`
` inputs of said switch of size
`
` of either said entry
`
`stage or said last stage of said plurality of stages of one partial multi-
`
`stage hierarchical network of said plurality of partial multi-stage
`
`hierarchical networks, and each outlet link of said plurality of outlet
`
`
`
`Page 12 of 57
`
`
`Ex. 1001
`
`17:34-41
`
`2d
`
`d
`
`id
`
`d i
`
`0d
`
`0d
`
`d i
`
`0d
`
`d
`i
`
`d
`
`o
`
`id
`
`d i
`
`0d
`
`d i
`
`0d
`
`id
`
`0d
`
`Page 14 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`links is connected to one of said
`
` outputs of said switch of size
`
`
`
`of either said entry stage or said last stage of said plurality of stages of
`
`one partial multi-stage hierarchical network of said plurality of partial
`
`multi-stage hierarchical networks; and
`
`said ring of a first partial multi-stage hierarchical network of said
`
`plurality of partial multi-stage hierarchical networks comprising the
`
`same or different number of said plurality of stages as said ring of a
`
`second partial multi-stage hierarchical network of said plurality of
`
`partial multi-stage hierarchical networks; a first stage of said plurality
`
`of stages comprising said switch comprising the same or different
`
`number of said plurality of multiplexers as a second stage of said
`
`Ex. 1001
`
`20:1-16,
`
`19:6-19,
`
`17:22-33
`
`plurality of stages; a first multiplexer in said plurality of multiplexers of
`
`size
`
` is the same or different size as a second multiplexer in said
`
`plurality of multiplexers of size
`
`; and
`
`each internal connection of said plurality of internal connections
`
`connected from the output of a first multiplexer of said plurality of
`
`Ex. 1001
`
`multiplexers of size
`
` of said switch of a first stage of said plurality
`
`10:36-42
`
`of stages of said ring of a first partial multi-stage hierarchical network
`
`
`
`Page 13 of 57
`
`
`0d
`
`d i
`
`0d
`
`2d
`
`2d
`
`2d
`
`Page 15 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`of said plurality of partial multi-stage hierarchical networks to one
`
`input of said
`
` inputs of a second multiplexer of said plurality of
`
`multiplexers of size
`
` of said switch of a second stage either
`
`succeeding or preceding to said first stage of said plurality of stages of
`
`said ring of said first partial multi-stage hierarchical network of said
`
`plurality of partial multi-stage hierarchical networks; and
`
`each external hop wire of said plurality of external hop wires connected
`
`from said output of one multiplexer of said plurality of multiplexers of
`
`size
`
` of said switch of a first two successive stages of said plurality
`
`of stages of said ring of a first partial multi-stage hierarchical network
`
`of said plurality of partial multi-stage hierarchical networks to one or
`
`more inputs of said
`
` inputs of one or more multiplexers of said
`
`plurality of multiplexers
`
` of said switch of said first two successive
`
`stages or a second two successive stages of said plurality of stages of
`
`said ring of a second partial multi-stage hierarchical network different
`
`from said first partial multi-stage hierarchical network of said plurality
`
`of partial multi-stage hierarchical networks.
`
`Ex. 1001
`
`20:37-41,
`
`20:42-22:53,
`
`29:3-33:25,
`
`Claim 22. (Proposed substitute for original claim 2):
`
`
`
`
`
`Page 14 of 57
`
`
`d
`
`2d
`
`2d
`
`d
`
`2d
`
`Page 16 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`22. The multi-stage hierarchical network implemented in the non-
`
`transitory medium of claim 21 wherein said plurality of external hop
`
`wires are connected as either vertical links (hereinafter “plurality of
`
`vertical external hop wires”) only, or horizontal links (hereinafter
`
`Ex. 1001
`
`22:37-22:63
`
`“plurality of horizontal external hop wires”) only.
`
`Claim 23. (Proposed substitute for original claim 3):
`
`
`
`23. The multi-stage hierarchical network implemented in the non-
`
`transitory medium of claim 22 wherein each partial multi-stage
`
`hierarchical network of said plurality of partial multi-stage hierarchical
`
`networks is replicated in either said plurality of rows or said plurality of
`
`columns of the two-dimensional grid, or
`
`each partial multi-stage hierarchical network of the plurality of partial
`
`multi-stage hierarchical networks with said plurality of horizontal
`
`external hop wires and said plurality of vertical external hop wires are
`
`replicated in either said plurality of rows or said plurality of columns of
`
`the two-dimensional grid.
`
`Ex. 1001
`
`9:27-61,
`
`14:4-27
`
`Claim 24. (Proposed substitute for original claim 4):
`
`
`
`24. The multi-stage hierarchical network implemented in the non-
`
`Ex. 1001
`
`
`
`Page 15 of 57
`
`
`Page 17 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`transitory medium of claim 22, wherein said plurality of horizontal
`
`22:37-22:63
`
`external hop wires between switches in two said stages are substantially
`
`of equal length and said plurality of vertical external hop wires between
`
`switches in two said stages are substantially of equal length in the two-
`
`dimensional grid of said plurality of rows and said plurality of columns,
`
`or
`
`said plurality of horizontal external hop wires between switches in two
`
`said stages are substantially of hop length
`
` and said plurality of
`
`vertical external hop wires between switches in two said stages are
`
`substantially of hop length
`
` where
`
` and
`
`.
`
`Claim 25. (Proposed substitute for original claim 5):
`
`
`
`25. The multi-stage hierarchical network implemented in the non-
`
`transitory medium of claim 21, wherein said plurality of inlet links and
`
`Ex. 1001
`
`said plurality of outlet links are connected to a computational block
`
`3:63-65
`
`comprising Lookup Tables, or memory blocks, or DSP blocks.
`
`Claim 26. (Proposed substitute for original claim 6):
`
`
`
`26. The multi-stage hierarchical network implemented in the non-
`
`Ex. 1001
`
`transitory medium of claim 23, comprises either generalized multi-stage
`
`8:32-55
`
`
`
`Page 16 of 57
`
`
`h
`
`v
`
`1h
`
`1v
`
`Page 18 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`pyramid network, or generalized folded multi-stage pyramid network,
`
`or generalized butterfly fat pyramid network, or generalized multi-link
`
`multi-stage pyramid network, or generalized folded multi-link multi-
`
`stage pyramid network, or generalized multi-link butterfly fat pyramid
`
`network.
`
`Claim 27. (Proposed substitute for original claim 7):
`
`
`
`27. The multi-stage hierarchical network implemented in the non-
`
`transitory medium of claim 26, wherein said plurality of hop wires are
`
`connected from said plurality of stages of said ring in a random order.
`
`Ex. 1001
`
`29:3-33:25
`
`Claim 28. (Proposed substitute for original claim 8):
`
`
`
`28. The multi-stage hierarchical network implemented in the non-
`
`transitory medium of claim 26, wherein said switch of size
`
` of
`
`one or more stages of said plurality of stages of said ring of said one or
`
`Ex. 1001
`
`more partial multi-stage hierarchical networks of said plurality of
`
`18:44-19:5
`
`partial multi-stage hierarchical networks where
`
` and
`
`.
`
`
`
`Claim 29. (Proposed substitute for original claim 9):
`
`
`
`29. The multi-stage hierarchical network implemented in the non-
`
`Ex. 1001
`
`
`
`Page 17 of 57
`
`
`8id
`
`4od
`
`d i
`
`0d
`
`Page 19 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`transitory medium of claim 24, wherein said plurality of external hop
`
`47:3-21,
`
`wires are implemented in two or more metal layers, or
`
`47:27-29,
`
`each switch of size
`
` of each stage of said plurality of stages is
`
`47:22-26,
`
`configurable by an SRAM cell or a Flash Cell, or
`
`said plurality of internal connections and said plurality of external hop
`
`wires use a plurality of buffers to amplify signals driven through them;
`
`and said buffers are either inverting or non-inverting buffers, or
`
`said switch in one or more stages of said plurality of stages in said
`
`plurality of partial multi-stage hierarchical networks comprising six 2:1
`
`multiplexers, or eight 2:1 multiplexers, or four 2:1 multiplexers, or two
`
`2:1 multiplexers.
`
`Claim 30. (Proposed substitute for original claim 10):
`
`17:42-19:5
`
`Ex. 1006
`
`Page 80, lines
`
`22-23
`
`
`
`
`
`30. The multi-stage hierarchical network implemented in the non-
`
`Ex. 1001
`
`transitory medium of claim 21, wherein said switch of size
`
` of
`
`47:16-21
`
`each stage of said plurality of stages is either fully populated or
`
`Ex. 1006
`
`partially populated, or
`
`said plurality of partial multi-stage hierarchical networks are
`
`implemented in a 3D integrated circuit device.
`
`Page 82, lines
`
`22-23
`
`
`
`
`
`Page 18 of 57
`
`
`d i
`
`0d
`
`d i
`
`0d
`
`Page 20 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`Claim 31. (Proposed substitute for original claim 11):
`
`
`
`31. A multi-stage hierarchical network implemented in a non-
`
`transitory medium comprising a plurality of partial multi-stage
`
`hierarchical networks and a plurality of inlet links and a plurality of
`
`outlet links,
`
`said plurality of partial multi-stage hierarchical networks arranged in a
`
`two-dimensional grid of a plurality of rows and a plurality of columns;
`
`and
`
`each partial multi-stage hierarchical network of said plurality of partial
`
`multi-stage hierarchical networks comprising at least one ring and each
`
`ring of said at least one ring comprising a plurality of stages; and
`
`one of said plurality of stages comprising an entry stage and one of said
`
`plurality of stages comprising a last stage; and
`
`each stage of said plurality of stages comprising a switch of size
`
`,
`
`where
`
` and
`
`and said switch of size
`
` having
`
` inputs
`
`and
`
` outputs; and said switch of size
`
` further comprising a
`
`plurality of multiplexers of size
`
` with each multiplexer of said
`
`plurality of multiplexers of size
`
` comprising
`
` inputs and an
`
`Ex. 1001
`
`8:57- 9:3,
`
`9:27-61
`
`
`
`Ex. 1001
`
` 5:1-3,
`
`8:57- 9:3,
`
`11:33-37,
`
`9:62-10:9,
`
`18:44-19:2,
`
`19:2-19-5,
`
`17:16-22,
`
`20:37-41,
`
`20:42-22:53,
`
`22:37-53,
`
`
`
`Page 19 of 57
`
`
`d i
`
`0d
`
`2id
`
`2od
`
`d i
`
`0d
`
`id
`
`0d
`
`d i
`
`0d
`
`2d
`
`2d
`
`d
`
`Page 21 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`output; and
`
`24:48-60,
`
`said
`
` inputs of said switch of size
`
`, and said
`
` outputs of said
`
`47:27-29
`
`switch of size
`
`, connected to a plurality of internal connections or
`
`
`
`a plurality of hop wires; and said plurality of hop wires further
`
`comprising a plurality of internal hop wires and a plurality of external
`
`hop wires; and
`
`
`
`said switch of size
`
` where
`
` or at least one input of said
`
`
`
`inputs of said switch of a first stage of said plurality of stages of a first
`
`ring of said at least one ring of a first partial multi-stage hierarchical
`
`network of said plurality of partial multi-stage hierarchical networks
`
`connected from one output of said
`
` outputs of said switch of a second
`
`stage of said plurality of stages of a second ring of said at least one ring
`
`of said first partial multi-stage hierarchical network or a second partial
`
`multi-stage hierarchical network of said plurality of partial multi-stage
`
`hierarchical networks, and
`
`each inlet link of Said plurality of inlet links is connected to one or
`
`more of said
`
` inputs of said switch of size
`
` of either said entry
`
`Ex. 1001
`
`17:34-41
`
`
`
`Page 20 of 57
`
`
`id
`
`d i
`
`0d
`
`0d
`
`d i
`
`0d
`
`d
`i
`
`d
`
`o
`
`id
`
`d i
`
`0d
`
`d i
`
`0d
`
`id
`
`0d
`
`Page 22 of 57
`
`
`
`PGR2019-00042
`Patent 10,003,553
`
`
`
`
`Paper No. 17
`Patent Owner’s Motion to Amend
`
`stage or said last stage of said plurality of stages of one partial multi-
`
`stage hierarchical network of said plurality of partial multi-stage
`
`hierarchical networks, and each outlet link of said plurality of outlet
`
`links is connected to one of said
`
` outputs of said switch of size
`
`
`
`of either said entry stage or said last stage of said plurality of stages of
`
`one partial multi-stage hierarchical network of said plurality of partial
`
`multi-stage hierarchical networks; and
`
`a first partial multi-stage hierarchical network of said plurality of partial
`
`multi-stage hierarchical networks comprising the same or different
`
`number of said a
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
