PTAB

IPR2017-01425

Texas Instruments Inc v. Semcon IP Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: SYSTEM AND METHOD FOR CONTROLLING COMMUNICATIONS BETWEEN SUBSYSTEMS
  • Brief Description: The ’876 patent describes a system to address delays in conventional master-slave computer architectures, particularly in real-time systems. The invention uses a centralized coordinator to determine communication needs, assign communication channels, and instruct subsystems to communicate directly with each other over those channels, thereby managing bus access and reducing arbitration delays.

3. Grounds for Unpatentability

Ground 1: Obviousness of Claims 2, 5, 11, and 13-18 over Lambrecht

  • Prior Art Relied Upon: Lambrecht (Patent 5,905,879).
  • Core Argument for this Ground: Petitioner argued that the system disclosed in Lambrecht, which predates the ’876 patent, teaches all elements of the challenged claims. Specifically, Lambrecht describes an architecture for transferring real-time multimedia data that includes subsystems (multimedia devices) and a coordinating component (arbitration logic and a "central agent"). Petitioner contended it would have been obvious for a person of ordinary skill in the art (POSITA) to combine the disclosed hardware and software components of Lambrecht to arrive at the claimed invention.
    • Prior Art Mapping: Petitioner asserted that Lambrecht’s multimedia devices (142A-146A) are equivalent to the claimed "plurality of subsystems." Lambrecht’s arbitration logic (504) combined with its "central agent" software constitutes the claimed "communications controlling coordinator." This coordinator in Lambrecht determines communication needs by receiving requests, and it assigns channels by allocating time slices on a multimedia bus using a "time slotting" scheme, which corresponds to the claimed method of assigning a "channel."
    • Motivation to Combine: The primary argument was that a POSITA would have been motivated to implement the "central agent" software functions on the dedicated arbitration logic (504) processor, rather than on the main CPU as suggested in one of Lambrecht’s examples. This combination would optimize the system for real-time performance by reducing data transport delays, minimizing latency from CPU load, and improving overall system efficiency by dedicating a specialized component to real-time communication tasks.
    • Expectation of Success: Petitioner argued a POSITA would have a high expectation of success. Lambrecht explicitly discloses both the software functions of the "central agent" and the hardware component of the arbitration logic (504). Furthermore, Lambrecht suggests combining various embodiments for optimal performance and describes a similar I/O processor in an alternative embodiment, making the proposed combination predictable and well within the skill of a POSITA.

Ground 2: Anticipation of Claims 2, 5, 11, 13-16, and 18 by Lambrecht

  • Prior Art Relied Upon: Lambrecht (Patent 5,905,879).

  • Core Argument for this Ground: Petitioner presented an alternative argument that an embodiment described in Lambrecht (specifically in reference to its FIG. 13) anticipates the challenged claims under 35 U.S.C. §102. This ground asserted that this specific embodiment inherently contains every limitation of the claims without any modification or combination.

    • Prior Art Mapping: This argument focused on Lambrecht’s FIG. 13, which shows an I/O processor (702) coordinating communications between multimedia devices. Petitioner mapped this I/O processor directly to the claimed "communications controlling coordinator." Lambrecht explicitly states this processor "creates connections," "sets up transfers," and is programmed with knowledge of data rates and destinations to coordinate transfers. Instead of time-slicing, this embodiment uses a "byte-slicing" scheme where the I/O processor assigns different data streams to different "byte channels" on the bus, allowing simultaneous communication. Petitioner contended this directly teaches the claimed steps of determining a need, assigning a channel, and instructing subsystems to communicate.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 18 over Lambrecht (Ground 3), arguing that even if not anticipated, the "pausing" limitation was obvious based on Lambrecht's disclosure of handshake procedures between communication transfers.

4. Key Claim Construction Positions

Petitioner argued for specific constructions of key claim terms, asserting they were critical to the invalidity analysis.

  • "channel": Petitioner contended this term should be construed as "a time-based transfer window." This construction was based on the patentee acting as its own lexicographer, as the specification states, "...a time-based transfer-window ('communications channel') designation."
  • "commence communication" and "exchanging said communications": Petitioner argued these phrases require the subsystems to "directly exchange or directly exchanging data on the assigned channel without passing through a central controller." This construction was based on arguments made during prosecution (prosecution history disclaimer) where the applicant repeatedly distinguished the invention from prior art by emphasizing the direct nature of the communication between subsystems, as opposed to communication mediated through a central controller.
  • "bus": Petitioner noted the specification expressly defines "bus" as "a linear bus topology, which is a parallel, multiplexed or non-multiplexed bus of continuous lines."

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 2, 5, 11, and 13-18 of the ’876 patent as unpatentable.