PTAB

IPR2016-00326

Micron Technology Inc v. Innovative Memory Systems Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Device, System and Method for Data Access Control
  • Brief Description: The ’537 patent describes a system for controlling access to data on an electronic storage device, such as flash memory or a hard disk drive. The technology purports to enhance security by ensuring that an access control device is the sole pathway to the data, thereby protecting the data even if the storage device is stolen or physically separated from its host computer.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1 and 13 under §102 over Anderl

  • Prior Art Relied Upon: Anderl (Patent 4,816,653).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Anderl, which discloses a high-security portable smart card, teaches every element of claims 1 and 13. Anderl's smart card comprises a microcomputer (the claimed "access control device") and an EEPROM (the "electronic data storage device"). Petitioner asserted that Anderl’s design makes the microcomputer the only path to access the EEPROM, thus meeting the limitation that data is "only accessed through said access control device." Furthermore, Anderl’s system stores permission data (e.g., read, write, append rights) in "protection bytes" that are stored in the same file as and appended to the user data within the EEPROM. For dependent claim 13, which requires the devices be "integrated," Petitioner contended Anderl meets this limitation because its microcomputer and EEPROM are combined on the same smart card.

Ground 2: Obviousness of Claim 2 under §103 over Anderl in view of Hendry

  • Prior Art Relied Upon: Anderl (Patent 4,816,653) and Hendry (Smart Card Security and Applications, 1997).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addresses claim 2, which depends from claim 1 and adds the limitation that the "electronic data storage device and said access control device are implemented on a single chip." Petitioner argued that while Anderl discloses the base system of claim 1, the Hendry textbook provides the motivation and teaching to implement that system on a single chip. Hendry was presented as a general resource on smart card technology which explicitly states that for maximum security, a smart card must incorporate a microprocessor and that several manufacturers at the time produced single chips including both the microprocessor and memory.
    • Motivation to Combine: Petitioner asserted a POSITA would combine Anderl and Hendry because both references address the same problem of data security on portable devices like smart cards. A POSITA seeking to implement the secure architecture of Anderl would naturally look to a standard textbook like Hendry for well-known implementation options. Hendry’s disclosure of single-chip integration represented a known design choice for improving integration, reducing size, and enhancing security.
    • Expectation of Success: The combination was argued to have a high expectation of success. Placing a processor and memory on a single chip was a predictable engineering step, part of a growing industry trend toward System-on-a-Chip (SOC) technology. The result—a more compact and integrated secure device—was not only predictable but a primary goal of such design choices.

  • Additional Grounds: Petitioner asserted an alternative obviousness challenge for claims 1 and 13 based solely on Anderl, arguing that even if not fully anticipated, the claims would have been obvious variations. Petitioner also presented a redundant ground for claim 2 based on the obviousness of Anderl (per Ground 2 of the petition) in view of Hendry.

4. Key Claim Construction Positions

  • "integrated" (claim 13): Petitioner argued that, under the broadest reasonable interpretation, the term "integrated" should be construed to mean "combined." This construction was asserted to be critical for the anticipation and obviousness arguments concerning claim 13. Petitioner based this proposed construction on the ’537 patent specification, which contrasts the claimed invention’s "more integrated manner" with prior art systems where the access control and storage were "stored and implemented separately." Based on this, Petitioner contended that Anderl’s disclosure of a microcomputer and EEPROM on the same smart card satisfies the "integrated" limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, and 13 of Patent 6,324,537 as unpatentable.