PTAB

IPR2019-00651

Kingston Technology Co Inc v. Memory Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method for Booting a Host Device from an MMC/SD Peripheral
  • Brief Description: The ’487 patent relates to a method and system for booting a host device from a peripheral memory card, such as a MultiMediaCard (MMC) or Secure Digital (SD) card. The invention purports to enable booting using the existing MMC/SD interface without a dedicated boot pin, by either holding the command (CMD) line low during power-up or by sending a command with a specific boot argument during initialization.

3. Grounds for Unpatentability

Ground 1: Claims 6, 7, 20, and 21 are obvious over Toombs in view of 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 a standard MMC interface connecting a host to a peripheral memory card, including command, data, clock, and power lines. While Toombs did not teach booting, McClain taught a method for booting a computer from non-volatile flash memory by using an "unusual combination" or an unused state of existing interface pins to initiate the boot sequence, thereby avoiding the need for an additional, dedicated boot pin.
    • Motivation to Combine: A POSITA would combine Toombs's standard MMC system with McClain's method for initiating a boot sequence without adding hardware. Petitioner asserted it was a predictable design choice to enable booting from the widely used MMC card format. A POSITA would have logically selected the command (CMD) line for this purpose, as the power and clock lines have other critical functions during power-up. Since the CMD line is held high for normal initialization in Toombs, using the otherwise unused low state to signal a boot request was presented as an obvious modification.
    • Expectation of Success: Petitioner contended that success was expected because the combination involved applying a known boot-initiation technique (McClain) to a standard, well-understood interface (Toombs), representing a solution chosen from a finite number of predictable options.

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 built upon the combination of Toombs and McClain by adding Kozakai. Petitioner argued Kozakai provided an explicit teaching that reinforced the combination's logic. Kozakai disclosed a flash memory device that functions as a boot device by storing a boot program at a leading memory address ("0") and is configured to read out that data in direct response to receiving a low signal at an external terminal during power-up.
    • Motivation to Combine: Kozakai strengthened the motivation to combine the primary references by explicitly linking a low signal during power-up to the function of retrieving and sending boot data from a predefined location. Petitioner argued this provided a clear and direct reason for a POSITA to modify Toombs’s MMC interface to use a low signal on the command line to trigger the boot functionality described in McClain and Kozakai.
    • Key Aspects: This ground asserted that Kozakai's disclosure removed any doubt that a POSITA would have considered using a low signal on an existing pin to initiate a boot sequence.

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 directed to the alternative boot method of sending a command with a boot argument. Petitioner argued that while Toombs and McClain provided the foundational system and boot concept, Kurakata supplied the missing element. Kurakata disclosed an MMC card that receives an initialization command (CMD0) which includes a 32-bit argument during its initialization procedure.
    • Motivation to Combine: A POSITA, seeking to implement the boot functionality of McClain within the standard MMC interface of Toombs, would recognize that using a command argument was a known alternative to asserting a low voltage state. Since Kurakata taught that the standard MMC initialization command (CMD0) could carry an argument, a POSITA would be motivated to use this existing mechanism to send a boot request. This would achieve the goal of adding boot functionality without hardware changes, consistent with the teachings of McClain.
    • Expectation of Success: Success would be expected as it involved modifying a known software-based parameter (the CMD0 argument taught by Kurakata) within a standard protocol to trigger a known function (booting from flash memory as taught by McClain).

4. Key Claim Construction Positions

  • "data frame": Petitioner proposed construing "data frame" (recited in claims 6 and 20) as "data transmission." This construction was argued to be consistent with the specification of the ’487 patent, which uses the terms interchangeably, and aligns the claim language with the disclosure of data transmission in the Toombs reference.

5. Relief Requested

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