PTAB

IPR2015-00926

Apple Inc v. ZiiLabs Inc

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1. Case Identification

2. Patent Overview

  • Title: Doubly-Virtualized Texture Memory
  • Brief Description: The ’615 patent relates to a computer graphics system architecture where a dedicated graphics memory is "doubly virtualized." This allows graphics data, such as textures, to be paged from the dedicated graphics memory into the host computer's main physical memory (a first level of virtualization) and subsequently from main memory into the host's bulk storage, such as a hard disk (a second level of virtualization).

3. Grounds for Unpatentability

Ground 1: Claims 1 and 3 are obvious over Herrell in view of Priem

  • Prior Art Relied Upon: Herrell (Patent 5,301,287) and Priem (Patent 7,136,068).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Herrell disclosed a host computer system comprising all the necessary high-level components: a central processing unit (CPU), main memory, and bulk storage (a swap disk). Herrell’s system used a virtual direct memory access (VDMA) interface to connect to a graphics subsystem, enabling the virtualization of memory between the graphics unit and the host. However, Herrell provided only a high-level description of the graphics subsystem itself. Priem was argued to fill this gap by disclosing the specific details of a graphics accelerator, including its own local memory (the claimed "specialized graphics memory") and rendering engine (the claimed "specialized graphics-processing logic"). Petitioner contended that combining Priem’s graphics accelerator with Herrell’s host system would result in a complete system meeting every limitation of claims 1 and 3. The first level of virtualization was mapped to Herrell's VDMA system managing data between Priem's local graphics memory and Herrell's main memory, and the second level was mapped to Herrell's use of a swap disk to page data from main memory.
    • Motivation to Combine: Petitioner asserted that a Person of Ordinary Skill in the Art (POSITA) would have been motivated to combine the references because they address complementary parts of a computer graphics system. Herrell provided the host architecture and memory interface, while Priem provided the detailed graphics processing unit. Integrating Priem’s specialized accelerator into Herrell’s system was presented as an obvious design choice to improve performance, add advanced 3D graphics capabilities like texturing, and create a more efficient overall system.
    • Expectation of Success: The combination was described as a routine engineering task that would yield predictable results, as no technical incompatibilities existed between the two systems.

Ground 2: Claim 1 is obvious over Herrell in view of Priem, further in view of Hennessy

  • Prior Art Relied Upon: Herrell (Patent 5,301,287), Priem (Patent 7,136,068), and Hennessy (a 1996 computer architecture textbook).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative or supplement to Ground 1, specifically addressing the claim limitation requiring the bulk storage unit to have an access time "more than ten times greater than the minimum access time of said main memory." Petitioner argued that even if this feature was not considered inherent in the Herrell/Priem combination, the Hennessy textbook explicitly taught the well-known principle that disk storage access times were orders of magnitude (often over 10,000x) slower than main memory access times in standard computer systems of the era. Therefore, implementing the combined Herrell/Priem system using conventional components as described in Hennessy would necessarily and obviously satisfy this limitation. Petitioner also noted that the patent examiner during original prosecution had found this limitation to be "inherent to any standard system."
    • Motivation to Combine: A POSITA would naturally consult a foundational textbook like Hennessy for established principles and component characteristics, such as relative memory access speeds, when designing or integrating computer systems. The motivation was to use standard, well-understood components to build the system proposed in the primary combination of Herrell and Priem.

4. Key Claim Construction Positions

  • Petitioner argued for the broadest reasonable interpretation of several key terms that were used in the claims but not explicitly defined in the ’615 patent’s specification. These constructions were central to mapping the prior art to the claims.
  • "specialized graphics-processing logic": Construed as "logic dedicated to processing graphics," distinct from the system's main CPU.
  • "specialized graphics memory" / "dedicated graphics memory": Construed as the "primary memory used by the graphics-processing logic for storing graphics data."
  • "[first/second] level of virtualizing": Construed as configuring a higher-level memory tier (main memory or bulk storage) to provide a larger apparent address space for a lower-level memory tier (graphics memory or main memory) through virtualization techniques like paging.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1 and 3 of Patent 6,683,615 as unpatentable.