PTAB

IPR2017-00861

Delphi Technologies Inc v. Microchip Technology Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: MULTI-HOST USB DEVICE
  • Brief Description: The ’708 patent discloses a Universal Serial Bus (USB) device that allows multiple host computers to connect to and share a single USB peripheral function. The device's controller is configured to manage concurrent connections, enabling the hosts to simultaneously access the peripheral without needing to disconnect and re-enumerate the device for each access.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-8, 10-11, 15-20, and 22-25 under §102 by Furukawa

  • Prior Art Relied Upon: Furukawa (Japanese Patent Application Publication 2003-256351).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Furukawa, which discloses a USB hub, teaches every element of the challenged claims. Furukawa describes a hub that enables multiple host computers to share peripheral devices (e.g., a printer, scanner). Its "controlling circuit" establishes and manages connections between the hosts and peripherals, allowing a plurality of host PCs to access the devices simultaneously. Petitioner asserted this controller meets the limitations of a "multi-host device controller" configured to establish "concurrent" connections. Furthermore, Furukawa explicitly states its system avoids the need for a "switching operation," which Petitioner equated with the claims’ requirement of allowing alternate access without reconfiguring or re-enumerating the device.
    • Key Aspects: The core of this ground was that Furukawa's stated purpose—to share a peripheral among multiple computers without a switching operation—directly mapped onto the alleged invention of the ’708 patent.

Ground 2: Anticipation of Claims 1-8, 11, 15-20, and 22-25 under §102 by Dickens

  • Prior Art Relied Upon: Dickens (Patent 6,549,966).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Dickens, which discloses a "Data Routing Device and System," independently anticipates the claims. Dickens describes a device for routing data between multiple host computers and a shared USB peripheral, such as a printer. The device includes a microprocessor that manages communications, allowing for simultaneous actions like sending data from one host to the printer while buffering data from another. Petitioner argued this system inherently discloses concurrent connections and allows hosts to maintain their connections while alternately accessing the printer. Because the hosts in Dickens are not required to disconnect, there is no need for re-enumeration before each access, thus meeting all key limitations of the independent claims.

Ground 3: Obviousness of Claims 9, 11-14, and 21 over Furukawa or Dickens in view of Chen

  • Prior Art Relied Upon: Furukawa or Dickens, in view of Chen (Patent 7,073,010).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claims requiring the "interleaving" of host access requests. Petitioner asserted that Furukawa and Dickens disclose the foundational multi-host USB sharing systems. Chen teaches a method for improving data throughput in USB communications by interleaving transactions—specifically, by re-ordering and overlapping packets from different transactions rather than processing one full transaction before starting the next.
    • Motivation to Combine: A POSITA would combine Chen's known technique with the systems of Furukawa or Dickens to solve a known problem: managing simultaneous access requests from multiple hosts efficiently. The motivation was the explicit benefit recited in Chen of improving data throughput, a predictable outcome when applying Chen’s traffic management technique to the multi-host environments of Furukawa or Dickens.
    • Expectation of Success: Petitioner argued there was a high expectation of success because Chen’s packet-level interleaving technique was not dependent on the number of hosts and could be readily implemented in any USB system to manage data flow, making it a straightforward improvement to the base systems.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including claims 9, 11-14, and 21 as obvious over Furukawa or Dickens in view of the USB 2.0 specification, which also disclosed interleaving. Further grounds alleged all claims (1-25) were obvious over combinations involving Wurzburg and Osakada (references from the patent's prosecution history) in further view of Furukawa or Dickens.

4. Key Claim Construction Positions

  • "Function block": Petitioner argued for a broad construction, meaning a segment of a device that performs any function, not limited to a peripheral function. This construction was crucial for arguing that the hub functionality disclosed in Furukawa could meet this limitation.
  • "Device": Argued to be a broad term encompassing both hubs and peripheral functions, either as a single component or a collection of components. This supported the application of prior art disclosing multi-function hubs or routing systems to the claims.
  • "Interleaving": Construed to mean merging data transfers by alternating between portions of them (e.g., packets), as taught by Chen and the USB 2.0 specification, rather than simply holding off one host while another completes its entire data transfer. This construction was central to the obviousness argument in Ground 3.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-25 of Patent 7,627,708 as unpatentable.