PTAB

IPR2019-00644

Kingston Technology Co Inc v. Memory Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Power Management of Peripheral Devices
  • Brief Description: The ’542 patent discloses methods and systems for managing power consumption in peripheral devices, such as memory cards, to ensure compatibility with various host devices. The technology involves the peripheral storing a range of available power consumption values that a connected host can query and use to select and set an appropriate operating power level.

3. Grounds for Unpatentability

Ground 1: Anticipation over Garner - Claims 18, 23, 28-29, 32-33, and 37-40 are anticipated under 35 U.S.C. § 102 over Garner.

  • Prior Art Relied Upon: Garner, Patent 5,724,592.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Garner, which teaches a flash memory storage device, discloses every limitation of the challenged claims. Garner’s device stores four distinct "power-expending modes" in an attribute memory, including a "lowest power mode" and a "highest power mode." Petitioner contended these directly correspond to the claimed "default value" and "limiting value," respectively. Garner's device is configured to "always power up in the lowest power mode," thus meeting the limitation of setting power consumption to a default value at startup. A host device can read the available power modes from Garner's memory and send a signal to select one. Garner’s onboard microprocessor then sets the device to the selected mode by adjusting operational configurations like clock frequency, which directly limits power consumption. This microprocessor, responsive to host commands, was argued to be the claimed "means for setting" the maximum power consumption.

Ground 2: Obviousness over Garner and Toombs - Claims 18, 23-24, 28-29, 32-33, and 37-40 are obvious over Garner in view of Toombs.

  • Prior Art Relied Upon: Garner, Patent 5,724,592, Toombs, Patent 6,279,114.
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that a person of ordinary skill in the art (POSITA) would combine Garner's power management system with the MultiMediaCard technology taught by Toombs. Toombs discloses a MultiMediaCard (teaching the limitation of dependent claims 24 and 39) that negotiates its operating voltage with a host to solve voltage compatibility issues. Petitioner argued it would have been obvious to apply Garner’s analogous power-mode negotiation system to Toombs’ device. A POSITA would have recognized that storing Garner's power mode values in Toombs' existing registers (e.g., its OCR or CSD register) would be a simple substitution of known technologies for a similar purpose.
    • Motivation to Combine: A POSITA would combine the references to create a more robustly compatible device. While Toombs addresses voltage compatibility, it does not solve power consumption compatibility, a known issue addressed by Garner. A POSITA would be motivated to add Garner's power management features to the widely used MultiMediaCard form factor taught by Toombs to improve compatibility with a broader range of hosts (especially low-power ones) and expand the device's marketability. The combination would also predictably decrease the physical size of Garner's storage system.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because both references operate in the same field (memory card compatibility) and use similar underlying techniques (negotiation between a host and card to determine an operating configuration). Applying Garner's power management logic to Toombs' flash memory card was a predictable combination of known elements to achieve the desired, predictable result of improved compatibility.

4. Key Claim Construction Positions

Petitioner argued that specific claim constructions, consistent with the intrinsic record, were crucial for mapping the prior art to the claims.

  • "peripheral device": Petitioner proposed this term means "an internal or external device capable of expanding the properties of or produce auxiliary functions for a connected electronic device," arguing this construction is broad enough to cover the memory cards described in the patent and prior art.
  • "default value": Proposed as "a preselected power consumption value to which the 'maximum power consumption' of the peripheral device is set when no alternative has been specified." This construction was used to map Garner's "lowest power mode" to the claims.
  • "limiting value": Proposed as "a power consumption value (1) to which the 'maximum power consumption' of the peripheral device can be set and (2) is higher than the 'default value.'" This was used to map Garner's "highest power mode" to the claims.
  • "maximum power consumption of the peripheral device": Proposed as "a setting by which the peripheral device limits (directly or indirectly) its power consumption." Petitioner argued this term is not an actual measurement (e.g., in Watts) but a configuration parameter that indirectly controls power use by adjusting factors like clock frequency, as taught in Garner.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 18, 23-24, 28-29, 32-33, and 37-40 as unpatentable.