PTAB

IPR2016-00500

Intellectual Integrity LLC v. Apple Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Analog Layout for a Pixel with a Pinned Photodiode and a Transfer Gate
  • Brief Description: The ’163 patent discloses a pixel cell layout for a complementary metal-oxide-semiconductor (CMOS) image sensor. The technology focuses on a specific two-dimensional arrangement of a pinned photodiode, a transfer gate, a floating diffusion region, and several transistors to reduce noise and enhance pixel performance and fill factor.

3. Grounds for Unpatentability

Ground 1: Anticipation by Lee - Claims 1, 2, 4, 5, 8, 9, 12, and 13 are anticipated by Lee.

  • Prior Art Relied Upon: Lee (Patent 7,742,090).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lee discloses every element and limitation of independent claim 1 and the challenged dependent claims. Petitioner asserted that Lee teaches a pixel cell comprising a pinned photodiode for accumulating photo-generated charge, a transfer gate adjacent to the photodiode, and a floating diffusion region for receiving the charge. The core of the argument was that Lee’s figures and specification explicitly illustrate the claimed spatial arrangement, where the floating diffusion region is laterally spaced from the transfer gate. Furthermore, Petitioner contended that Lee’s described reset, source follower, and row select transistors constitute the claimed "functional block" and are arranged relative to the other components as required by the claim. The arguments for dependent claims mapped specific transistor types and layout features disclosed in Lee to the limitations of those claims.

Ground 2: Obviousness over Lee and Krymski - Claims 6, 7, and 10 are obvious over Lee in view of Krymski.

  • Prior Art Relied Upon: Lee (Patent 7,742,090) and Krymski (Patent 6,903,771).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Lee teaches all limitations of the base claims upon which claims 6, 7, and 10 depend, as established in Ground 1. These dependent claims add limitations requiring the gate of the source follower transistor to have an "L-shape." While Lee discloses the necessary transistor, it does not explicitly show this shape. Petitioner argued that Krymski, which is directed to optimizing active pixel sensor cell layouts, remedies this deficiency by expressly teaching the use of an L-shaped gate for a source follower transistor. Krymski explains this shape allows for a more compact and efficient pixel layout.
    • Motivation to Combine: A POSITA would combine Lee with Krymski to achieve a more compact and area-efficient pixel layout, a well-known and critical goal in the image sensor field. Petitioner argued that a skilled artisan implementing the pixel architecture of Lee would be motivated to consult prior art, such as Krymski, for established techniques to optimize component layout. Integrating Krymski’s L-shaped transistor gate into Lee’s circuit was presented as a common-sense design choice to improve the overall pixel design.
    • Expectation of Success: A POSITA would have had a high expectation of success in making this combination. The modification involved applying a known layout technique (an L-shaped gate) to a standard component (a source follower transistor) within a conventional pixel circuit. This combination was argued to be a predictable integration of known elements, yielding the expected benefit of improved layout density without any technical uncertainty.

4. Key Claim Construction Positions

  • "functional block": Petitioner argued this term should be construed according to its plain and ordinary meaning, referring to a group of components—specifically the reset, source follower, and row select transistors—that operate together to perform a collective function within the pixel. This construction was crucial to the anticipation argument, as it did not require the transistors to be physically contiguous or isolated in a specific enclosure beyond what was necessary for their function, thereby allowing the layout shown in the Lee reference to satisfy the claim limitation.
  • "L-shaped": For claims 6, 7, and 10, Petitioner contended that "L-shaped" should be understood simply as a shape having two segments disposed at an angle to one another, consistent with its common geometric meaning. This straightforward interpretation was key to demonstrating that the transistor gate taught by Krymski clearly met the limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, 4-10, 12, and 13 of Patent 7,864,163 as unpatentable.