PTAB

IPR2019-00651

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

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1. Case Identification

2. Patent Overview

  • Title: An MMC/SD Device Method a Host Device May Be Booted From
  • Brief Description: The ’487 patent describes methods and devices for booting a host system from a peripheral memory device, such as a MultiMediaCard (MMC) or Secure Digital (SD) card. The invention purports to enable booting without requiring a dedicated boot pin, instead using either a low signal on the command (CMD) line during power-up or a specific command argument to initiate the boot process.

3. Grounds for Unpatentability

Ground 1: Claims 6, 7, 20, and 21 are obvious over Toombs and McClain.

  • Prior Art Relied Upon: Toombs (Patent 6,279,114) and McClain (Patent 7,058,779).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Toombs disclosed all elements of a standard MMC interface—including power, command, data, and clock terminals—but did not teach booting from it. McClain taught a method for booting a computer from non-volatile flash memory by using an unused signal state on an existing interface pin, thereby avoiding the need for a dedicated boot pin. The combination of Toombs's standard MMC interface and McClain's boot-from-flash methodology allegedly rendered the challenged claims obvious. Specifically for independent claim 6, Toombs taught the MMC interface and receiving power (6[a]), while the combination taught receiving a low signal on the command terminal to initiate boot (6[b]) and then sending predefined boot data starting with a start bit (6[c]), as taught by McClain and Toombs, respectively.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the references to add a known booting capability (from McClain) to a standard MMC card system (from Toombs). McClain taught the benefits of using a single, existing signal for booting, and Toombs disclosed a minimal-signal MMC interface. A POSITA would logically select the command (CMD) line of the Toombs interface for this boot signal, as the power, clock, and data lines have other essential functions during power-up. Driving the CMD line low was a predictable design choice, as Toombs did not disclose any use for a low state on the CMD line during initialization, making it an "unused state" as contemplated by McClain.
    • Expectation of Success: Given that the structures for flash memory booting and MMC interfaces were well-known, a POSITA would have had a reasonable expectation of success in implementing McClain’s booting method on the Toombs interface.

Ground 2: Claims 6, 7, 20, and 21 are obvious over Toombs, McClain, and Kozakai.

  • Prior Art Relied Upon: Toombs (Patent 6,279,114), McClain (Patent 7,058,779), and Kozakai (Patent 7,012,845).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground presented a similar argument to Ground 1, with Kozakai added as further support. Kozakai was cited for its disclosure of a flash memory device that functions as a boot device by storing a boot program at a leading address. Critically, Kozakai taught that this boot data is read out in response to a low signal received at an external terminal of the flash memory from a host CPU during power-up.
    • Motivation to Combine: The motivation to combine Toombs and McClain was the same as in Ground 1. Petitioner argued that Kozakai reinforced this motivation by providing another explicit example of using a low signal on an external pin during power-up to trigger a boot sequence from a flash memory. This teaching allegedly made it even more obvious to a POSITA to apply a low signal to the unused state of the Toombs CMD line to initiate booting as taught by McClain.
    • Expectation of Success: The addition of Kozakai's direct teaching of a low-signal boot trigger further strengthened the argument that a POSITA would have expected success in combining the references.

Ground 3: Claims 13, 26, 42, and 52 are obvious over Toombs, McClain, and Kurakata.

  • Prior Art Relied Upon: Toombs (Patent 6,279,114), McClain (Patent 7,058,779), and Kurakata (Patent 7,188,265).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addressed claims related to booting via a command argument, rather than by simply holding a line low. Petitioner asserted that Kurakata taught an MMC card receiving an initialization command (CMD0) that includes a 32-bit argument. The combination of Toombs's MMC interface, McClain's teaching of using an unused signal state for a boot request, and Kurakata's teaching of using a command argument for initialization allegedly rendered claims reciting this functionality obvious. For independent claim 13, the combination taught receiving a boot request argument (13[a]), receiving a clock signal (13[b]), and sending data if boot data is stored (13[c]).
    • Motivation to Combine: The motivation to combine Toombs and McClain remained the same. A POSITA seeking to implement McClain’s concept of an "unused signal" for a boot request on the Toombs interface would look for a state other than the "contiguous stream of logical '1's" used for normal initialization in Toombs. Petitioner argued that Kurakata provided the obvious alternative: sending a specific initialization command (CMD0) with an argument for the boot request. This was a predictable and well-understood way to add functionality to a command-based interface without adding hardware.
    • Expectation of Success: A POSITA would have expected to successfully integrate Kurakata’s command-argument method into the Toombs/McClain framework to achieve a non-hardware-based boot trigger.

4. Key Claim Construction Positions

  • "data frame": Petitioner proposed that "data frame" as recited in claims 6 and 20 should be construed as "data transmission." This construction was asserted to be consistent with the ’487 patent's specification, which used the terms interchangeably. This interpretation was critical to mapping Toombs, which disclosed a "data transmission" beginning with a start bit, to the claim limitation of sending a "data frame" starting with a start bit.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 6, 7, 13, 20, 21, 26, 42, and 52 of the ’487 patent as unpatentable.