PTAB

IPR2017-00864

Delphi Technologies Inc v. Microchip Technology Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: MULTI-HOST USB DEVICE CONTROLLER
  • Brief Description: The ’243 patent describes a USB peripheral device with a multi-host controller that allows two or more host computers to share access to the device's function. The controller is configured to maintain concurrent connections to the hosts, enabling them to alternately access the device without requiring disconnection and re-enumeration for each access switch.

3. Grounds for Unpatentability

Ground 1: Anticipation of Claims 1-8, 10-11, 15-20, and 22-25 by Furukawa under 35 U.S.C. §102

  • Prior Art Relied Upon: Furukawa (Japanese Patent Application Publication 2003-256351).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Furukawa, which discloses a USB hub, teaches every limitation of the challenged claims. Furukawa describes a hub that connects a plurality of host computers to peripheral devices via multiple upstream and downstream ports. Its "controlling circuit" establishes and maintains connections, allowing multiple hosts to simultaneously request access. The circuit arbitrates these requests, enabling hosts to alternately access a peripheral without a "switching operation," which Petitioner equated to the ’243 patent’s concept of avoiding disconnection and re-enumeration. Furukawa's FIFO memories were argued to meet the buffer limitations, and its control logic for handling requests met limitations regarding simultaneous receipt and request ordering.
    • Key Aspects: Petitioner's argument centered on Furukawa's explicit solution to the problem of sharing peripherals among multiple computers without the series of operations (like loading/unloading drivers) associated with prior art switches, which directly maps to the ’243 patent’s purported invention.

Ground 2: Anticipation of Claims 1-8, 11, 15-20, and 22-25 by Dickens under 35 U.S.C. §102

  • Prior Art Relied Upon: Dickens (Patent 6,549,966).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Dickens discloses a "data routing device" that anticipates the challenged claims. The device connects multiple host computers to shared USB peripherals, such as a printer. It maintains simultaneous connections by using emulation functions, so each host computer operates as if it is continuously connected. When one host sends print data, the device routes it to the printer; if a second host sends data concurrently, it is buffered in memory and sent after a break in the first transmission. This system was argued to teach concurrent connections, simultaneous access requests, and alternating access to the shared device function without reconfiguration, as required by the claims. The memory for buffering data was mapped to the endpoint buffer limitations.

Ground 3: Obviousness of Claims 9, 11-14, and 21 over Furukawa or Dickens in view of Chen under 35 U.S.C. §103

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

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that claims reciting "interleaving" were obvious. Furukawa and Dickens provide the foundational multi-host architecture allowing concurrent connections. Chen teaches a method of improving USB data throughput by interleaving packets from different transactions—for example, starting a second transaction before a first has fully completed. This packet re-ordering is precisely what "interleaving" means in the USB context.
    • Motivation to Combine: A POSITA would combine Chen's known technique for improving data throughput with the multi-host systems of Furukawa or Dickens for the predictable benefit of increased efficiency. Since Chen’s technique improves performance in a single-host system, it would be an obvious and desirable optimization to apply in a multi-host system where managing traffic from multiple sources is a key challenge.
    • Expectation of Success: Success would be expected because Chen's method operates at the packet/transaction level and is not dependent on the number of hosts. Applying this known data-handling technique to the established multi-host architectures of Furukawa or Dickens would have been a straightforward implementation for a POSITA.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including claims 9, 11-14, and 21 over Furukawa or Dickens in view of the USB 2.0 specification, and all claims 1-25 over various other combinations including Wurzburg, Osakada, and Admitted Prior Art (APA).

4. Key Claim Construction Positions

  • "Device block corresponding to at least one function": Petitioner argued for a broad construction under the broadest reasonable interpretation (BRI) standard, meaning a segment of a device that performs a function, whether that function is a peripheral function (like printing) or a hub function. This construction was crucial for applying prior art like Furukawa, which discloses a hub, to the claims.
  • "concurrent" / "simultaneous": Petitioner argued these terms relate to the state of the connections and the ability to request access, not to simultaneous data transfer. The key distinction, per Petitioner, is that multiple hosts can maintain their enumerated connections with the peripheral at the same time, avoiding the disconnection-reconnection cycle of prior art switches, even if data is ultimately transferred alternately.
  • "Configured": Petitioner argued this term is used in two distinct ways in the patent. When referring to a device component (e.g., "controller is configured to"), it is functional language synonymous with "operable to." When referring to a host's action (e.g., "hosts configure the device"), it refers to the standard USB process of a host readying a device for use after connection.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-25 of the ’243 patent as unpatentable.