RPX Corp v. Iym Technologies LLC

1. Case Identification

• Case #: TBD
• Patent #: 7,448,012
• Filed: July 28, 2017
• Petitioner(s): RPX Corporation and Advanced Micro Devices, Inc.
• Patent Owner(s): IYM Technologies LLC
• Challenged Claims: 1-14

2. Patent Overview

• Title: Techniques for Improving Integrated Circuit Layout
• Brief Description: The ’012 patent describes computer-implemented methods for improving integrated circuit (IC) layouts. The core concept involves modifying global design rule constraints with new, local constraints that account for specific local conditions, thereby increasing manufacturing yield and performance without unnecessarily increasing overall chip size.

3. Grounds for Unpatentability

Ground 1: Claims 1-5 and 13 are obvious over Côté.

• Prior Art Relied Upon: Côté (Patent 6,745,372).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Côté discloses all limitations of the challenged claims. Côté teaches a method to optimize an IC layout by first identifying local "problem areas" that are susceptible to manufacturing variations, even when the layout complies with global design rules. It then generates "additional constraints" based on "local layout requirements" for these specific areas. These new local constraints are fed to a layout optimizer to produce a new, more resilient layout. This process directly maps to the claimed method of receiving a layout, constructing initial constraints, computing local modifications, and enforcing new local constraints to produce an improved layout.
  • Motivation to Combine (for §103 grounds): Not applicable (single reference ground). Petitioner asserted that anticipation is the epitome of obviousness under 35 U.S.C. §103.
  • Expectation of Success (for §103 grounds): Not applicable.
  • Key Aspects: Côté was not of record during the original examination of the ’012 patent. Petitioner contended Côté recognizes the same problem as the ’012 patent—that global design rules can be inefficient—and solves it in the same way by applying local modifications.

Ground 2: Claims 1-3, 5, 10-11, and 13 are obvious over Côté in view of Bamji.

• Prior Art Relied Upon: Côté (Patent 6,745,372) and Bamji (Patent 5,663,891).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that while Côté teaches the overall method of local optimization, it does not describe a specific optimization technique in detail. Bamji remedies this by disclosing a sophisticated mathematical model for IC layout optimization using a "constraint graph" and "cost functions." Bamji's method translates layout design rules and performance criteria (e.g., yield, power consumption, cross-talk) into a solvable graph problem. The combination provides a detailed implementation for the "layout optimizer" described conceptually in Côté.
  • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSA) implementing the layout optimization described in Côté would have sought a known, effective optimization technique. A POSA would combine Côté with Bamji because Bamji’s constraint graph method was well-suited for Côté’s system and addressed the industrial need to simultaneously optimize for multiple performance criteria, a feature Bamji explicitly states is required by "most industrial applications."
  • Expectation of Success (for §103 grounds): A POSA would have had a high expectation of success because both references describe IC optimization based on an input layout and design rules, making their techniques compatible.

Ground 3: Claims 4 and 6-9 are obvious over Côté in view of Bamji and Kroyan.

• Prior Art Relied Upon: Côté (Patent 6,745,372), Bamji (Patent 5,663,891), and Kroyan (Patent 7,523,429).

• Core Argument for this Ground:

  • Prior Art Mapping: This combination builds upon the Côté and Bamji framework by adding the teachings of Kroyan. Kroyan discloses a method to improve optimization efficiency by creating a database of known layout "weak spots" (or "hotspots") and their associated pre-determined remedial solutions. Instead of always running a full simulation to find a fix (as in Côté), Kroyan’s system first checks its database for a matching pattern. This maps to claim limitations involving detecting processing hotspots (Kroyan’s “weak spots”), evaluating process response variables, and calculating modifications using predetermined functions or look-up tables.
  • Motivation to Combine (for §103 grounds): A POSA would combine Kroyan with the Côté/Bamji system to improve its efficiency. By incorporating Kroyan's database of known problematic patterns and their solutions, the system could quickly retrieve a known fix rather than performing a computationally expensive simulation and optimization for every identified hotspot. This reuse of previously determined optimizations would be an obvious and advantageous improvement.
  • Expectation of Success (for §103 grounds): Success was expected because all three references address the same technical field of local layout optimization, and Kroyan’s database method represents a complementary efficiency improvement to the core process taught by Côté and Bamji.

• Additional Grounds: Petitioner asserted an additional obviousness challenge for claim 12 over Côté in view of Bamji and Cobb (Patent 6,249,904). Cobb teaches selectively applying Optical Proximity Correction (OPC) only to tagged, problematic edge fragments to save processing time.

4. Key Claim Construction Positions

• "description(s) of manufacturing process" (Claim 1): Petitioner argued this term should be given its plain and ordinary meaning, which would encompass one or more of the items listed in the specification (e.g., design rules, simulation models, equipment settings). Petitioner contended that construing the term to require all listed items would be improper for two main reasons:
  • Claim Differentiation: Dependent claim 4 recites a specific subset of these items ("design rules, simulation models, equipment settings, material selections, and look-up data tables"). For claim 4 to have any separate meaning, independent claim 1 must be broader and cannot be limited to requiring all of these elements.
  • No Lexicography: The specification provides a list of examples of what a "process description" might include, but does not act as a lexicographer to provide a restrictive definition requiring every listed item. This construction is critical because prior art references like Côté disclose some, but not necessarily all, of the exemplary items.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of Patent 7,448,012 as unpatentable.