PTAB

IPR2015-01411

Advanced Micro Devices Inc v. LG Electronics Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Power Control Apparatus for Multi-Core Processor and Method Thereof
  • Brief Description: The ’971 patent discloses a power control system for a multi-core processor. The system uses a power management unit to receive usage information for each core and, based on that information, independently controls separate power conversion units to adjust the supply voltage provided to each individual core.

3. Grounds for Unpatentability

Ground 1: Obviousness over Zhang and Altmejd - Claims 1, 9-13, 15, and 19-20 are obvious over Zhang in view of Altmejd.

  • Prior Art Relied Upon: Zhang (Application # 2003/0122429) and Altmejd (Patent 6,895,520).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Zhang discloses the core architecture of the challenged claims, including a multi-core processor with multiple circuits (cores), each coupled to a respective local voltage regulator that independently supplies a local voltage. These regulators function as the claimed "power conversion units" by converting a global supply voltage to a local, non-zero output voltage. Zhang’s power management is based on whether a core is "active" or "inactive," which Petitioner asserted constitutes "information relating to a usage amount." Altmejd was argued to supply the missing detail of a more sophisticated power management policy. Altmejd teaches a power management unit that receives detailed utilization information for individual circuits (e.g., percentage of idle time) and independently adjusts their voltage and clock rates accordingly.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine the references to improve the efficiency of Zhang’s system. Zhang’s disclosure focused on the hardware structure for independent voltage control but provided a rudimentary power management policy based only on "active/inactive" status. A POSITA would have looked to a reference like Altmejd, which explicitly teaches a more granular power management policy based on detailed utilization data, to implement a more effective policy for Zhang’s hardware. Altmejd’s statement that its power-saving techniques can be implemented in "any integrated circuit... where both performance and power savings are considerations" would have motivated its application to Zhang's processor.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because both references address the same technical problem of power management in integrated circuits by independently controlling voltage to different functional blocks.

Ground 2: Obviousness over Orenstien and Filippo - Claims 1, 9-13, 15, and 19-20 are obvious over Orenstien in view of Filippo.

  • Prior Art Relied Upon: Orenstien (Patent 6,804,632) and Filippo (Patent 6,976,182).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Orenstien discloses a dual-core processor with a central power monitor that receives information, such as "basic measurements of activity level," from each core. This monitor controls "independently controllable power supplies" for each core to manage their voltage and frequency. While Orenstien does not explicitly detail the power supplies as "power conversion units," Petitioner argued it would be an obvious substitution for a POSITA. Filippo was argued to disclose the specific implementation of such independent power control. Filippo teaches separate "power control units" for each functional block that monitor activity and control power accordingly. These units are disclosed as power gates, which turn power on or off based on activity.
    • Motivation to Combine: Petitioner argued that the references themselves suggest the combination. Orenstien noted that simply shutting down idle cores (as taught by Filippo's power gates) could cause performance latency, suggesting other techniques should be employed. Filippo, in turn, provides more advanced power control techniques, such as predictive functionality for determining how long a unit may be inactive. A POSITA would have looked to Filippo's detailed activity detectors and power control units to implement or improve upon the independently controllable power supplies described in Orenstien.
    • Key Aspects: Petitioner presented this ground as a strong alternative, particularly if the Board were to adopt a broad construction of "power conversion unit" that includes power gates. In that scenario, Filippo alone would teach the claimed power conversion units.

4. Key Claim Construction Positions

  • "power conversion unit": Petitioner argued this term should be construed as "a device that is able to convert an input voltage to another, non-zero output voltage." This construction was intended to be narrower than a construction allegedly advanced by the Patent Owner in co-pending district court litigation, which Petitioner claimed was broad enough to include simple power gates or switches that only turn power on or off. The distinction was critical, as the prior art in Ground 2 (Filippo) expressly teaches power gates.
  • "information relating to/about a usage amount": Petitioner proposed this term should mean "any information having a relationship with or on the subject of a usage amount, which may (but does not necessarily) include the usage amount." This broad construction would encompass indirect indicators of use, such as the "active" or "inactive" status taught by Zhang or the "basic measurements of activity level" taught by Orenstien.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 9-13, 15, and 19-20 of the ’971 patent as unpatentable.