NVIDIA Corporation v. Polaris Innovations Limited

1. Case Identification

• Case #: IPR2017-01819
• Patent #: 7,124,325
• Filed: July 25, 2017
• Petitioner(s): NVIDIA Corporation
• Patent Owner(s): Polaris Innovations Ltd.
• Challenged Claims: 14, 16-18, 20

2. Patent Overview

• Title: Method And Apparatus for Internally Trimming Output Drivers and Terminations in Semiconductor Devices
• Brief Description: The ’325 patent relates to a method for adjusting the impedance of interface devices on an integrated circuit. The patent purports to improve upon prior art by integrating a "trimming unit" within the semiconductor device itself, rather than using an external device, to improve data transmission rates.

3. Grounds for Unpatentability

Ground 1: Claims 14 and 16-18 are anticipated under 35 U.S.C. §102 by Volk 450.

• Prior Art Relied Upon: Volk (Patent 6,693,450).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Volk 450 discloses every element of independent claim 14. Volk 450 describes an on-chip driver system (50) with a "tuner" (72) that adjusts the impedance of an interface device (driver 56). This interface device has a "settable control element" because its pull-up and pull-down driver elements (80, 82) have programmable and electronically adjustable impedance. Petitioner identified Volk 450’s "Adder" (98) as the claimed "trimming register" and the "tuner" (72) as the "trimming unit." The tuner writes to the adder based on a measured variable (voltage 60 from the data bus) detected on the interface device, fulfilling the claim limitations. Dependent claims 16-18 were also argued to be taught by Volk 450's disclosure of a reference voltage device (RCOMP controller 64), a comparator (90), a logic unit (tuner controller 100), and memory (96).
  • Key Aspects: This ground asserted that Volk 450's system for dynamic output impedance adjustment is functionally identical to the system claimed in the ’325 patent, including the on-chip placement of the trimming circuitry.

Ground 2: Claims 14 and 16-17 are anticipated under 35 U.S.C. §102 by Volk 105.

• Prior Art Relied Upon: Volk (Patent 6,356,105).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Volk 105, which describes an impedance control system for a termination bus in a "system logic chip," also anticipates the claims. Petitioner mapped the claimed "interface device" to Volk 105's termination components (e.g., RCOMP pad 472), which are connected to an external DDR memory. The "settable control elements" were identified as adjustable transistor devices (P1, N1). The "trimming registers" were argued to be the up/down counters (450, 456) that store impedance values. The "trimming unit" was identified as the control logic state machine (402) and comparators (458, 460), which write to the counters based on a measured voltage from the pad compared against reference voltages. Dependent claims 16 and 17 were argued to be taught by Volk 105’s disclosure of reference voltages, comparators, and logic units.
  • Key Aspects: This ground relied on a different embodiment of a similar impedance control concept from the same inventor as Volk 450, focusing on trimming a termination bus rather than an output driver.

Ground 3 & 4: Claims 14, 16-18, and 20 are obvious over Volk 450 or Volk 105 in view of Hiraki.

• Prior Art Relied Upon: Volk (Patent 6,693,450) or Volk (Patent 6,356,105) in view of Hiraki (Patent 6,201,733).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground addressed claims 18 and 20, which require a "nonvolatile memory unit." Petitioner argued that while the Volk references disclose all other elements, they do not explicitly teach that the memory for storing trimming values is nonvolatile. Hiraki was introduced because it teaches using a nonvolatile flash memory to store "voltage trimming information," which is then loaded into a "voltage trimming register" on system reset to repair or configure a volatile memory like DRAM. This teaching directly supplies the nonvolatile memory element missing from the Volk references.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Hiraki's teachings with either Volk 450 or Volk 105 to solve a known problem. The systems in Volk would lose their trimming settings upon power loss and have to restart the adjustment process from scratch. A POSITA would be motivated to incorporate Hiraki’s nonvolatile memory to store the last-used trimming value, making the system more efficient and allowing it to achieve optimal performance more quickly after a reboot.
  • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination, as it involved applying a known technique (storing configuration data in nonvolatile memory, as taught by Hiraki) to a known system (the impedance adjustment circuits of Volk) to achieve the predictable result of retaining settings.

4. Key Claim Construction Positions

• Petitioner addressed claim terms that were central to a prior, unsuccessful IPR on the same patent (IPR2017-00382).
• "interface device": Petitioner argued that the prior art in the present petition (Volk 450 and Volk 105) meets the Board's construction from the previous IPR, which construed the term as a device "associated with an interface" and "'between the semiconductor device' and 'another device external to the semiconductor device.'"
• "trimming" and "settable control element": Petitioner contended that no explicit construction was necessary for these terms. However, it argued that even under the Patent Owner's previously proposed constructions (e.g., "trimming" as "adjusting"; "settable control element" as a circuit element with programmable impedance), the teachings of Volk 450 and Volk 105 satisfy the limitations.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not exercise its discretion to deny institution under 35 U.S.C. §325(d), despite this being its second petition challenging the ’325 patent.
• Petitioner asserted that the new petition was not redundant because it was based on different prior art and arguments than the first petition. Crucially, it was drafted to specifically address the Board's claim construction of "interface device" in its decision to deny institution of the first petition.
• It was also noted that the current petition challenges a smaller subset of claims, reducing the burden on the Patent Owner and the Board.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 14, 16-18, and 20 of Patent 7,124,325 as unpatentable.