PTAB

IPR2019-00644

Kingston Technology Company, Inc. v. Memory Technologies, LLC

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1. Case Identification

2. Patent Overview

  • Title: Methods and Systems for Managing Power Consumption of a Peripheral Device
  • Brief Description: The ’542 patent is directed to methods and systems for managing the power consumption of peripheral devices, such as memory cards, to ensure compatibility with various host devices. The technology involves the peripheral storing a "default value" and a "limiting value" for power consumption, negotiating with a host to set a "maximum power consumption" level within that range, and adjusting its operational configurations (e.g., clock frequency) to comply with the set level.

3. Grounds for Unpatentability

Ground 1: Anticipation over Garner - Claims 18, 23, 28-29, 32-33, 37, 38, and 40 are anticipated by Garner under §102.

  • Prior Art Relied Upon: Garner (Patent 5,724,592).
  • Core Argument:
    • Prior Art Mapping: Petitioner argued that Garner, which describes managing power in a microprocessor-controlled storage device, discloses every limitation of independent claims 18 and 28. Garner’s device stores four "power-expending modes" in an attribute memory, including a "lowest power mode" and a "highest power mode." Petitioner contended these modes correspond directly to the claimed "default value" and "limiting value." Garner’s device is configured to power up in a default mode (the lowest power mode) and can subsequently be set by a host to any of the other modes, including the highest, within the available range. The means-plus-function limitation "means for setting a maximum power consumption" was argued to be disclosed by Garner’s microprocessor (28), which is responsive to commands from the host, reads a configuration register, and controls the setup process (e.g., clock frequency, data-access bandwidth) to place the device into the selected power mode.
    • Key Aspects: Petitioner asserted that Garner's microprocessor and associated logic perform the identical function of the claimed means-plus-function element in the same way to achieve the same result. Petitioner also emphasized that Garner was not presented to or considered by the USPTO during the original or reissue prosecution of the ’542 patent.

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 under §103.

  • Prior Art Relied Upon: Garner (Patent 5,724,592) and Toombs (Patent 6,279,114).
  • Core Argument:
    • Prior Art Mapping: Petitioner argued that Garner teaches the fundamental power management system (negotiating power modes, storing default/limiting values, adjusting clock frequency). Toombs, which addresses voltage compatibility, teaches a MultiMediaCard capable of negotiating operating parameters with a host and discloses the specific form factor and connector pin structure for such a card. The combination of Garner’s power management system with Toombs’ MultiMediaCard platform was argued to render all challenged claims obvious, including dependent claims requiring a "MultiMediaCard" (claims 24 and 39) that are not explicitly taught by Garner alone. A person of ordinary skill in the art (POSITA) would have found it obvious to either implement Garner's power management system in the MultiMediaCard taught by Toombs or, conversely, modify Toombs' card to include Garner's power negotiation capabilities.
    • Motivation to Combine: A POSITA would combine the references because both address the same core problem (compatibility between removable memory cards and hosts) in a similar field (memory card configuration) using a similar solution (negotiation). Implementing Garner's power-mode negotiation on the standard MultiMediaCard form factor from Toombs would predictably improve the card's compatibility with a wider range of host systems, especially those with varying power supply capabilities. This achieves Garner's stated objective of allowing a storage device to "function with as many types of digital systems as possible." Further motivation comes from the benefits of a microprocessor-controlled system as taught by the combination, which provides logical abstraction for the host, allows for software-based updates, and simplifies system design.
    • Expectation of Success: A POSITA would have a high expectation of success because the combination involves applying a known power management technique to a standard memory card platform. This constitutes a simple substitution of known, compatible elements to achieve the predictable result of a power-managed MultiMediaCard. The underlying techniques for storing configuration data in a register and negotiating with a host are similar in both references.

4. Key Claim Construction Positions

Petitioner dedicated significant argument to the construction of four key terms, asserting they are critical to the invalidity analysis.

  • “peripheral device”: Petitioner proposed this term be construed broadly as "an internal or external device capable of expanding the properties of or produce auxiliary functions for a connected electronic device." This construction is based on the specification’s examples (memory cards, cameras) and is necessary to ensure the prior art devices fall within the scope of the claims.
  • “default value” and “limiting value”: Petitioner argued these terms should be understood as preselected power consumption values that define the boundaries of a negotiable range. The "default value" is the setting used at startup or when no alternative is specified. The construction is derived from the specification and prosecution history, where the terms evolved from "first/second maximum value" to overcome indefiniteness rejections.
  • “maximum power consumption of the peripheral device”: This was the most heavily disputed term. Petitioner argued it does not refer to a direct physical measurement of power (e.g., Watt-Hours) but rather to "a setting by which the peripheral device limits (directly or indirectly) its power consumption." This construction is supported by the prosecution history, including an inventor declaration explaining the term relates to a limit that affects fluctuating power use. This interpretation allows a parameter like a "power mode" or a clock frequency setting in the prior art to meet the claim limitation, as it indirectly determines the upper boundary of power usage.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review (IPR) for claims 18, 23-24, 28-29, 32-33, and 37-40 of Patent RE45,542 and the cancellation of these claims as unpatentable.