PTAB

IPR2015-01409

Advanced Micro Devices Inc v. LG Electronics Inc

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1. Case Identification

2. Patent Overview

  • Title: Power Management for Multi-Core Processors
  • Brief Description: The ’863 patent discloses methods and systems for controlling power consumption in a multi-core processor. The invention describes using a single device driver and an embedded controller to individually manage power supplied to each core via corresponding DC/DC converters based on the monitored status and usage of the cores.

3. Grounds for Unpatentability

Ground 1: Claims 4 and 30 are obvious over Orenstien in view of Nicol and ACPI.

  • Prior Art Relied Upon: Orenstien (Patent 6,804,632), Nicol (Patent 6,141,762), and ACPI (Advanced Configuration and Power Interface Specification, Rev. 2.0).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Orenstien taught the central concept of an operating system (OS) monitoring the state and activity level of multiple processor cores to independently control their power. However, Orenstien omitted specific implementation details, which Petitioner contended were well-known in the art. Nicol supplied the disclosure of using individual DC/DC converters for each core to achieve this independent, OS-level voltage control. ACPI, as the prevailing industry standard for OS-directed power management, supplied the disclosure of using a "single device driver" as the necessary software interface between the OS and the processor hardware.
    • Motivation to Combine: A POSITA would combine these references to implement Orenstien's high-level power management scheme using standard, off-the-shelf components and interfaces. Nicol provided the obvious hardware structure (individual DC/DC converters) for independent voltage control, and ACPI provided the standard software interface (a device driver) for OS-based control. This combination was particularly compelling because Intel, Orenstien's assignee, was a primary promoter of the ACPI standard, making an ACPI-compliant implementation the expected approach.
    • Expectation of Success: The combination involved applying a known software interface (ACPI) to known hardware (Nicol's converters) to achieve the predictable result of OS-based power management taught by Orenstien. No unexpected results would arise from implementing a known control scheme using standard, compatible components.

Ground 2: Claims 8 and 9 are obvious over Orenstien and Nicol, in view of Saeed and ACPI.

  • Prior Art Relied Upon: Orenstien (Patent 6,804,632), Nicol (Patent 6,141,762), Saeed (Patent 6,711,447), and ACPI (Advanced Configuration and Power Interface Specification, Rev. 2.0).
  • Core Argument for this Ground:
    • Prior Art Mapping: This argument incorporated the combination from Ground 1 and added Saeed to address the "power management mode" limitations of claims 8 and 9. While Orenstien taught checking a general "battery mode," Petitioner argued Saeed explicitly disclosed specific, user-defined power schemes controlled by the OS. These schemes included a "maximum frequency mode" (mapping to the claimed "higher performance mode"), an "auto mode" (mapping to the "adaptive mode"), and a "maximum battery mode" (mapping to the "power saving mode"), which directly corresponded to the modes recited in dependent claim 9.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Saeed's more detailed power mode management techniques into the broader architectural framework established by Orenstien, Nicol, and ACPI. The motivation was strong, as Saeed and Orenstien were both assigned to Intel, addressed the same technical problem of processor power management, and were filed around the same time, making their teachings complementary. Adding Saeed's specific mode controls was a logical enhancement to Orenstien's general system.
    • Expectation of Success: Integrating Saeed's specific power modes into an ACPI-compliant, OS-controlled system as suggested by the combination of Orenstien and Nicol would have been a straightforward implementation with predictable results in power savings and performance management.

4. Key Claim Construction Positions

  • "single device driver" (claims 4, 8, 30): Petitioner contended this term should be construed as "software that is part of an operating system for interfacing with hardware." This construction was central to its argument for incorporating the teachings of the ACPI standard, which defines device drivers in this specific context. Petitioner argued this was necessary to distinguish the claimed element from any generic software program that interacts with hardware.
  • "each of the plurality of cores to individually receive DC power from a corresponding one of a plurality of DC/DC converters" (claim 4): Petitioner argued this phrase, and similar phrases in other claims, requires "hardware that converts a non-zero input DC voltage to another, non-zero output DC voltage." This construction was asserted to be critical to distinguish a true DC/DC converter, as taught by Nicol, from a simple power gate or switch, which merely passes or blocks voltage. Petitioner noted that the Patent Owner had allegedly equated the term with a switch in parallel district court litigation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 4, 8, 9, and 30 of Patent 7,636,863 as unpatentable.