DCT

1:01-cv-00602

Via Tech v. Intel Corp

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:01-cv-00602, W.D. Tex., 09/10/2001
  • Venue Allegations: Venue is asserted based on Defendant Intel conducting business in the state of Texas, having an office in Austin within the Western District, and the alleged acts of infringement occurring in the district.
  • Core Dispute: Plaintiffs allege that Defendant’s Pentium 4 microprocessor infringes a patent related to an instruction set and method for converting and transferring data between a microprocessor's integer and floating-point units.
  • Technical Context: The lawsuit concerns the internal architecture of microprocessors, specifically how they handle different numerical data formats (integer vs. floating-point) to optimize processing efficiency.
  • Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
1997-11-29 ’311 Patent Priority Date
2001-06-26 ’311 Patent Issue Date
2001-09-10 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 6,253,311 - "Instruction Set for Bi-Directional Conversion and Transfer of Integer and Floating Point Data"

(Compl. ¶14).

The Invention Explained

  • Problem Addressed: The patent’s background describes the inefficiency in prior art microprocessors when data needed to be shared between the integer unit (IU) and the floating-point unit (FPU). This process required converting the data format and then storing the result to external system memory before it could be retrieved by the other unit, a process the patent characterizes as "very time consuming" and a source of "significant delay." (’311 Patent, col. 2:46-56).
  • The Patented Solution: The invention proposes a method and apparatus that avoids the external memory-access step. It provides distinct "convert" and "move" instructions. Crucially, a floating-point register, normally used for floating-point numbers, is also configured to temporarily store data in integer format after a conversion. (’311 Patent, Abstract; col. 2:5-18). This allows the conversion and transfer to be separated into two steps, performed rapidly within the processor without requiring intermediate storage in system memory. (’311 Patent, col. 2:62-66).
  • Technical Importance: This approach aimed to increase microprocessor performance by eliminating a significant bottleneck—slow memory access cycles—for a common set of operations in numerical and multimedia processing. (’311 Patent, col. 2:52-56).

Key Claims at a Glance

  • The complaint does not specify which claims are asserted, alleging infringement of the patent generally (Compl. ¶17). The primary independent claim is Claim 1.
  • The essential elements of independent claim 1 include:
    • A microprocessor comprising an integer register file and a floating-point register file.
    • The floating-point register file is configured to store floating-point numbers and is "also configured to store data in integer format."
    • A "first conversion instruction" that converts a floating-point number into an integer.
    • The instruction causes the resulting integer to be "temporarily stor[ed]... within said floating point register file."
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The accused instrumentality is Intel’s "Pentium 4" microprocessor. (Compl. ¶12).

Functionality and Market Context

  • The complaint identifies the Pentium 4 as a microprocessor designed and sold by Intel to Original Equipment Manufacturers (OEMs) for use in personal computers. (Compl. ¶11-12).
  • The complaint does not provide specific details about the internal architecture or operation of the Pentium 4, other than to allege that it "infringes the '311 patent." (Compl. ¶17).

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or sufficient technical detail to map specific features of the accused Pentium 4 microprocessor to the elements of the asserted patent claims. The infringement allegation is made in a single conclusory sentence. (Compl. ¶17).

No probative visual evidence provided in complaint.

  • Identified Points of Contention: Given the technology and the claims, the infringement analysis will likely raise several key questions for the court:
    • Scope Questions: Does the architecture of the Pentium 4 include a "floating point register file" that is "also configured to store data in integer format" as required by claim 1? The resolution may depend on whether any temporary, internal storage format within the Pentium 4's FPU meets the claim's definition of "integer format."
    • Technical Questions: Does the Pentium 4 utilize a "first conversion instruction" that performs the two-step function recited in claim 1: (1) converting a floating-point number to an integer, and (2) "temporarily storing said first integer within said floating point register file"? Evidence will be required to show that the accused microprocessor performs this specific sequence, rather than using a different internal mechanism (e.g., a dedicated buffer or a direct transfer to an integer register) that falls outside the claim language.

V. Key Claim Terms for Construction

  • The Term: "temporarily storing said first integer within said floating point register file" (from Claim 1)
  • Context and Importance: This phrase is the central novelty of the claim. The infringement case hinges on whether the accused Pentium 4 uses its floating-point registers for this specific temporary storage purpose after conversion, as opposed to immediately moving the data elsewhere or using a different temporary buffer. Practitioners may focus on this term because it defines the specific data pathway that distinguishes the invention from prior art that used external memory.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes this as a key feature for avoiding external memory, stating the invention provides for transfer "without requiring data to be stored in an external memory." (’311 Patent, col. 5:63-65). A party could argue any internal storage within the FPU that avoids an external memory write meets the spirit of the claim.
    • Evidence for a Narrower Interpretation: The patent repeatedly emphasizes storing the integer in the floating-point register file itself and provides specific instructions (FMXCVT_xF) that "stores the result back into the floating point register file." (’311 Patent, col. 6:22-28). A party could argue this requires the integer to occupy a formal, addressable floating-point register, not just a transient internal buffer within the FPU complex. Figure 6 shows the distinct steps of "Convert FP to Integer within FPU" (604) and then "Move Integer from FPU to IU" (606), which supports the idea of a stable, temporary storage state. (’311 Patent, Fig. 6).

VI. Other Allegations

  • Indirect Infringement: The complaint makes a bare allegation of contributory and induced infringement. (Compl. ¶17). It does not, however, plead any specific facts to support these claims, such as identifying any direct infringers (e.g., OEMs or end-users) or alleging that Intel's manuals or instructions encouraged infringing use.
  • Willful Infringement: The complaint does not contain an allegation of willful infringement or a prayer for enhanced damages.

VII. Analyst’s Conclusion: Key Questions for the Case

The resolution of this case will likely depend on the answers to two central questions:

  1. A core issue will be one of claim construction: Does the claim limitation "floating point register file also configured to store data in integer format" require the formal, addressable registers of the FPU to hold integers, or can it be construed more broadly to cover any temporary integer-holding buffer within the FPU architecture?

  2. A key evidentiary question will be one of technical operation: Assuming a claim construction is established, what is the actual data pathway inside the Pentium 4 microprocessor? The case will turn on evidence demonstrating whether the accused chip, in fact, performs the claimed two-step process of converting a floating-point number and then "temporarily storing" the resulting integer inside a floating-point register before moving it to the integer unit.