PTAB

IPR2019-00642

Kingston Technology Co Inc v. Memory Technologies LLC

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1. Case Identification

2. Patent Overview

  • Title: Method and Device for Configuring Access to a Memory Device
  • Brief Description: The ’180 patent relates to a method and device for managing memory access using "predefined access profiles." These profiles, stored in device registers, are activated by commands from a host to configure the memory device for specific usages, such as read, write, or erase operations.

3. Grounds for Unpatentability

Ground 1: Anticipation over CompactFlash - Claims 1-3, 5, 16-19, 21, 32, and 35 are anticipated by the CompactFlash specification under 35 U.S.C. §102.

  • Prior Art Relied Upon: CompactFlash (CF+ and CompactFlash Specification Revision 3.0).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the CompactFlash specification inherently discloses every limitation of the challenged claims. The various MultiWord and Ultra DMA transfer modes supported by the specification function as the claimed "predefined access profiles." A host device issues a "SET FEATURES" command to the memory device's controller, which activates a selected DMA mode. This activation directly "configures access" by dictating the specific data transfer protocol the device must use for a given "usage" (e.g., a READ DMA or WRITE DMA operation). For instance, selecting an Ultra DMA mode configures the device to perform a CRC check on data transfers, a feature not used in MultiWord DMA modes. Dependent claims were argued to be met by features such as sequential data transfers (standard in READ/WRITE DMA operations) and optimized performance (Ultra DMA modes increased data throughput and reduced host CPU load).

Ground 2: Obviousness over Ziv and Vogt - Claims 1, 5, 16, 17, 21, 32, and 35 are obvious over Ziv in view of Vogt.

  • Prior Art Relied Upon: Ziv (Patent 7,478,248) and Vogt (Patent 6,681,304).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Ziv discloses a portable memory device with a secure partition that is governed by a predefined access profile. This profile consists of a stored password hash, an address offset, and an encryption key, all stored in registers. Access to the secure area is granted when a user-entered password matches the stored hash, which then activates the profile by using the address offset and encryption key to govern subsequent read/write operations.
    • Motivation to Combine: Ziv's system is activated by the host transmitting a password, which Petitioner contended may not meet the ’180 patent’s "command" limitation as interpreted during prosecution. Vogt was cited for its explicit teaching of a "password verify" command that bundles the password and sends it to a memory device to authenticate a user. A Person of Ordinary Skill in the Art (POSITA) would combine Vogt's well-known, command-based authentication method with Ziv's secure memory system. This represented a simple substitution of one known element (password transmission) for another (command-based password transmission) to achieve the predictable and known benefits of reliable and efficient host-device communication.
    • Expectation of Success: The combination was argued to be predictable, as implementing a command-based protocol for password verification in a secure memory device was a standard design choice.

Ground 3: Obviousness over Sinclair and Toombs - Claims 1-3, 5, 16-19, 21, 32, and 35 are obvious over Sinclair in view of Toombs.

  • Prior Art Relied Upon: Sinclair (Patent 7,409,489) and Toombs (Patent 6,279,114).

  • Core Argument for this Ground:

    • Prior Art Mapping: Sinclair was argued to disclose selectable memory "reclaim modes" (e.g., Reclaim Normal, Reclaim Off) that function as the claimed "access profiles." A host issues commands to select the appropriate mode based on present or expected host activity, and the device configures its background memory management operations accordingly.
    • Motivation to Combine: Petitioner argued that while Sinclair teaches these selectable modes, it does not explicitly disclose storing the list of available modes in a dedicated register for the host to query. Toombs was introduced for its teaching of MultiMediaCards that use registers (e.g., the Card-Specific Data register) to store and communicate a variety of status and internal information, including supported operational modes, to the host. A POSITA would have been motivated to apply the standard, register-based method from Toombs to Sinclair's system to allow the host to efficiently learn which reclaim modes the memory device supports before issuing a command.
    • Expectation of Success: Using registers to communicate device capabilities to a host was a fundamental and predictable technique in memory card design, ensuring successful implementation.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Ziv, Vogt, and Toombs (to add teachings of random and sequential access modes); CompactFlash and Elhamias (to add teachings of parallel processing); and Ziv, Vogt, and Elhamias.

4. Key Claim Construction Positions

  • "predefined access profile": Petitioner proposed this term be construed as "a mode, setting, control, or logic defined in advance for reading, writing, modifying, deleting, or changing the attributes of data." This broad construction was intended to encompass the various operational modes disclosed in the prior art, such as the DMA modes in CompactFlash and the reclaim modes in Sinclair.
  • "configuring access": Petitioner proposed construing this term as "setting the memory device for reading, writing, modifying, deleting, or changing the attributes of data." This construction was central to arguing that changing a data transfer protocol (as in CompactFlash) constitutes "configuring access," directly challenging arguments made during the patent's original prosecution.
  • "usage": Petitioner proposed this term means "host activity in accordance with the predefined access profile." This construction links the host's intent or action (the usage) to the specific profile selected to govern that action.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 5, 12-13, 16-19, 21, 28-29, 32, and 35 of Patent 8,307,180 as unpatentable.