PTAB

IPR2015-01411

Advanced Micro Devices, Inc. v. LG ELECTRONICS, INC.

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1. Case Identification

2. Patent Overview

  • Title: Power Control Apparatus for Multi-Core Processor and Method Thereof
  • Brief Description: The ’971 patent discloses systems and methods for controlling power supply in a multi-core processor. The technology involves using individual power conversion units for each processor core to independently adjust the supply voltage based on the specific power consumption or usage amount of that core.

3. Grounds for Unpatentability

Ground 1: Claims 1, 9-13, 15, 19, and 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 teaches a power control apparatus for a multi-core processor where each core is coupled to a respective local voltage regulator. These regulators (the claimed "power conversion units") independently convert a global supply voltage to a local supply voltage for each core based on a power management policy, such as whether a core is "active" or "inactive." While Zhang discloses the necessary structure and a basic policy, it lacks detail on how usage is determined. Altmejd was argued to supply this missing element, teaching a power management unit that receives detailed utilization information (e.g., percentage of time a block is idle) and uses it to adjust circuit parameters like voltage.
    • Motivation to Combine: A POSITA would combine these references to improve upon Zhang's system. Zhang provides the hardware architecture for independent voltage control but is vague on the power management policy. Altmejd provided a known, more granular method for determining circuit utilization to make power management decisions. Petitioner asserted a POSITA would integrate Altmejd’s sophisticated power management techniques into Zhang's multi-core architecture to create a more efficient and responsive system. Altmejd itself suggested its techniques are applicable to any integrated circuit where performance and power savings are considerations.
    • Expectation of Success: A POSITA would have a high expectation of success because both references address the same technical problem—power management in processors—using compatible and well-understood techniques. Integrating Altmejd's software-based utilization monitoring with Zhang's hardware-based voltage regulation was presented as a straightforward application of known principles.

Ground 2: Claims 1, 9-13, 15, 19, and 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 power monitor that receives information from each core (e.g., "basic measurements of activity level") to independently control "independently controllable power supplies" for each core. This maps to most claim limitations. Filippo was argued to teach the remaining elements, specifically disclosing the use of an "activity detector" that controls a "power gate" for individual functional units. Petitioner argued Filippo’s power gate meets the "power conversion unit" limitation, at least under the Patent Owner's alleged broad construction of the term.
    • Motivation to Combine: The motivation was framed as improving Orenstien's system. Orenstien acknowledges that simply shutting down cores can have performance drawbacks and suggests that "other power control techniques" could be employed. Filippo provided precisely such a technique: using an activity detector and power gate to control power to idle circuits. A POSA would have looked to Filippo's teachings to implement a more refined power control method than the one generally described in Orenstien, thereby achieving better power management without significant performance latency.
    • Expectation of Success: Success was expected because the combination involves the simple substitution of one known element for another. A POSA could replace Orenstien's generic "independently controllable power supplies" with either well-known power converters or, alternatively, with Filippo's disclosed power gates to achieve the predictable result of independent power control for each core.

4. Key Claim Construction Positions

  • "power conversion unit": This term was central to the petition's arguments. Petitioner argued for a construction requiring "a device that is able to convert an input voltage to another, non-zero output voltage." This construction was based on the ’971 patent's specification describing DC/DC converters and voltage regulators that provide a "suitable operating voltage." Petitioner contrasted this with the Patent Owner's alleged litigation position that the term is broad enough to include devices that merely turn power on and off, such as a simple power gate or switch. This distinction was critical, as Ground 1 (Zhang) was argued to be strong under Petitioner's narrower construction, while Ground 2 (Filippo) was strong even under the Patent Owner's broader one.
  • "information relating to/about a usage amount": Petitioner argued this term should be construed broadly to 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" itself. This supported the argument that prior art disclosures of "active" or "inactive" states or "basic measurements of activity level" meet this limitation.
  • "power management unit": Petitioner proposed this term means "hardware or software that manages or assists in managing the power supplied to a processor." This broad construction allowed Petitioner to map the term to various components in the prior art, including processors executing a power management policy, dedicated hardware units, or software routines in an operating system.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should institute review on both grounds because they are not redundant and present meaningfully distinct challenges. The two grounds were presented as having different strengths that depend on the Board's construction of the key term "power conversion unit."
  • Ground 1 (Zhang/Altmejd) was asserted to be particularly strong under Petitioner’s proposed construction, as Zhang explicitly discloses local voltage regulators that convert one non-zero voltage to another.
  • Ground 2 (Orenstien/Filippo) was asserted to be highly relevant to test the scope of the claims and remains a strong challenge even if the Board were to adopt the Patent Owner's alleged broader construction, because Filippo expressly teaches using a power gate to control power to a circuit.

6. Relief Requested

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