Intellectual Ventures Management LLC v. Xilinx Inc

1. Case Identification

• Case #: IPR2012-00018
• Patent #: 7,566,960
• Filed: September 17, 2012
• Petitioner(s): Intellectual Ventures Management, LLC
• Patent Owner(s): Xilinx, Inc.
• Challenged Claims: 1-13

2. Patent Overview

• Title: Interposing Structure
• Brief Description: The ’960 patent relates to an electronic assembly containing an interposer situated within an integrated circuit (IC) package, between the IC die and the package itself. The interposer is designed to provide bypass capacitance and facilitate signal redistribution.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1, 2, 9, and 10 under 35 U.S.C. §102

• Prior Art Relied Upon: Chakravorty (Patent 6,611,419).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Chakravorty, which discloses an electronic assembly with a substrate containing embedded capacitors, teaches every limitation of the challenged independent and dependent claims. Chakravorty’s substrate (310) was identified as the claimed "interposing structure." Petitioner asserted that Chakravorty’s IC die (300) with an array of solder balls (308) corresponds to the claimed die with "micro-bumps." Crucially, Petitioner contended that Chakravorty's interposer electrically couples a first solder ball to a first landing pad opposite its position and to a second landing pad at a different position via conductive material (capacitive plate 329), thereby anticipating the core functionality recited in independent claims 1 and 9.

Ground 2: Obviousness of Claims 3-5, 7, 8, and 11 under 35 U.S.C. §103

• Prior Art Relied Upon: Chakravorty (Patent 6,611,419) and Siniaguine (Patent 6,730,540).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground used Chakravorty as the primary reference for the base assembly and added Siniaguine to teach limitations found in various dependent claims. For claim 3, Petitioner argued that Siniaguine, which describes a conventional ball grid array (BGA) package, explicitly teaches making the major surfaces of the IC die and the interposer "roughly identical." For claim 7, Petitioner asserted that Chakravorty’s embedded capacitors (330) inherently function as the claimed "bypass capacitor."
  • Motivation to Combine: Petitioner argued a POSITA would combine the teachings because Siniaguine provides a known and conventional BGA packaging technique. Applying this technique to the assembly in Chakravorty would have been a simple modification to achieve predictable results, such as improving the device's form factor and manufacturability.
  • Expectation of Success: A POSITA would have a reasonable expectation of success in modifying the Chakravorty assembly with the standard packaging features of Siniaguine, as it involved applying a known technique to a similar device to yield predictable improvements.

Ground 3: Obviousness of Claims 1-13 under 35 U.S.C. §103

• Prior Art Relied Upon: Chung (Patent 6,680,218) and Chakravorty (Patent 6,970,362).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner presented an alternative theory using a different combination of references. Chung was asserted to teach the basic assembly, including a vertical package section (304) that functions as an interposer between an IC die and a horizontal package section. The second reference, Chakravorty ’362, was introduced for its teaching of an interposer (310) that provides flexibility in signal distribution between an IC die and a primary substrate. Petitioner argued that combining these references would result in an assembly where the interposer (from Chung) electrically couples micro-bumps to different landing pads (as taught by Chakravorty ’362).
  • Motivation to Combine: A POSITA would combine these references to improve the signal routing capabilities of the package described in Chung. The flexible signal distribution provided by the Chakravorty ’362 interposer was a known solution to a common problem in IC packaging, making its incorporation into Chung’s design a logical step for a skilled artisan seeking to enhance performance.
  • Expectation of Success: Given that both references operate in the same field of IC packaging and address complementary aspects of package design, a POSITA would have reasonably expected that integrating the signal-routing interposer of Chakravorty ’362 into the vertical package structure of Chung would be successful.
• Additional Grounds: Petitioner asserted additional obviousness challenges based on other combinations, including Chakravorty ’419 in view of Siniaguine and Patel; Chakravorty ’362 in view of Siniaguine; and various combinations involving the further addition of Ma (Patent 6,423,570).

4. Key Claim Construction Positions

• "means for electrically coupling..." (Claim 9): Petitioner argued this term is a means-plus-function limitation subject to 35 U.S.C. §112(6). The stated function is "electrically coupling a first micro-bump...to a first landing pad...and to a second landing pad." Based on the ’960 patent’s specification, Petitioner identified the corresponding structure as "caposer 1082 in FIG. 24" and its equivalents. This construction was central to defining the scope of the claim for the purposes of comparing it against the prior art.

5. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1-13 of the ’960 patent as unpatentable.