PTAB

IPR2015-01197

American Megatrends Inc v. Kinglite Holdings Inc

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1. Case Identification

2. Patent Overview

  • Title: Functionalities For A System Basic Input/Output System (BIOS)
  • Brief Description: The ’656 patent describes a method and system for adding functionalities to a computer’s Basic Input/Output System (BIOS). The technology centers on an "interface module" that receives requests and system information from the BIOS, translates that information, and transfers it to another module for tasks like displaying data to a user.

3. Grounds for Unpatentability

Petitioner asserted a single ground of unpatentability.

Ground 1: Obviousness over Nunn and AMIBIOS - Claims 1, 2, 10, 11, 19, and 20 are obvious over Nunn in view of AMIBIOS.

  • Prior Art Relied Upon: Nunn (Patent 6,317,828) and AMIBIOS (AMIBIOS Technical Reference 98).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the challenged claims merely describe a conventional BIOS setup utility, the components and operation of which were well-known prior to the invention. Nunn was cited as disclosing a "BIOS/Utility Setup Display" program, which serves as the claimed "interface module." This program interfaces with the system BIOS to display a list of bootable devices. Petitioner mapped the claim steps to the standard operation of Nunn’s utility: a "request" is received from the BIOS when a user presses a key (e.g., ) during boot; the utility then receives "system device information" (the bootable device list) from the BIOS; this information is "translated" from raw data into a human-readable format for display; and the translated information is "transferred" to a "corresponding module" (the graphics controller/driver) to be rendered on-screen.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would not have needed a specific motivation to "combine" these references, as AMIBIOS simply describes the standard, underlying technical environment in which a utility like Nunn's would operate. AMIBIOS explained the fundamental interactions between user input (keyboard interrupts), the system BIOS, setup utilities, and video services (e.g., the INT 10h video interrupt routine). Therefore, a POSITA implementing the BIOS setup utility taught by Nunn would have naturally and necessarily used the conventional BIOS architecture and video display methods detailed in AMIBIOS.
    • Expectation of Success: A POSITA would have had a very high expectation of success, as the combination represented a routine implementation of a common feature (a BIOS setup screen) using standard, well-understood hardware and software interactions that were ubiquitous in personal computers at the time.

4. Key Claim Construction Positions

Petitioner argued that several claim terms should be construed under the Broadest Reasonable Interpretation (BRI) standard to reflect their plain meaning in the context of computer software, contending these constructions demonstrate the claims cover nothing more than generic software operations.

  • "interfacing an interface module": Proposed as "a module capable of communicating text, data, graphics or electrical signals to another module." This construction aimed to define the core element of the invention as a generic software component for communication.
  • "a request ... to perform a task": Proposed as "soliciting action to be taken." Petitioner asserted that the patent’s only example of a "task" is displaying information, a fundamental computer function.
  • "translating": Proposed as "converting to another data format." This construction was argued to cover the routine process of converting binary data into a text string or graphical representation for display, a necessary step in any user interface.
  • "corresponding module": Proposed as "a software module associated with another module." Petitioner contended this term simply refers to the next software component in the processing chain, such as a graphics driver that receives formatted data for display.

5. Key Technical Contentions (Beyond Claim Construction)

Petitioner’s central technical contention was that the ’656 patent claims a system architecture and operational flow that was the de facto standard for personal computers long before the patent's filing date. The argument went beyond claim construction to assert that the claimed process is a mere recitation of the fundamental steps required for a computer to display BIOS-level information during startup. Petitioner detailed this standard process:

  • A user presses a key during the Power-On Self-Test (POST) sequence.
  • This action generates a hardware interrupt that the system BIOS handles.
  • The BIOS, in response, invokes a separate software routine (the setup utility).
  • The setup utility retrieves configuration data stored by the BIOS.
  • The utility formats this data and uses standard BIOS video services (e.g., INT 10h) to pass the formatted data to the video hardware for display.
    Petitioner argued this entire sequence was common knowledge and that the claims of the ’656 patent do not add any inventive concept beyond this well-established, conventional process.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 2, 10, 11, 19, and 20 of the ’656 patent as unpatentable under 35 U.S.C. §103.