Intel Corp v. VLSI Technology LLC

1. Case Identification

• Case #: IPR2019-01194
• Patent #: 8,081,026
• Filed: June 28, 2019
• Petitioner(s): Intel Corporation
• Patent Owner(s): VLSI Technology, LLC
• Challenged Claims: 1, 2, 4, 5, and 7

2. Patent Overview

• Title: Power Management for Integrated Circuits
• Brief Description: The ’026 patent discloses a power-saving technique for an integrated circuit. The system uses a "power gating switch" to control the output supply voltage provided to a "power gated circuit" based on inputs from a "mode indicator" (e.g., active or sleep mode) and a "leakage indicator" that reflects the circuit's leakage current.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 4, 5, and 7 are obvious over Kim in view of Lee under 35 U.S.C. §103.

• Prior Art Relied Upon: Kim (Application # 2008/0136507) and Lee (Application # 2007/0147159).
• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued that Kim discloses the core invention of independent claim 1. Kim teaches an integrated circuit with a power gating switch (a "sleep transistor array") that controls an output voltage ("VVCC") supplied to a power-gated circuit (a "processor"). This control is based on a mode indicator (a "Sleep signal" for active/sleep modes) and a leakage indicator (programmable memory cells storing the results of leakage tests). The combination of these inputs determines the conductivity of the sleep transistor array, thus managing power consumption. For dependent claims, Petitioner asserted that Kim's "active mode" corresponds to the claimed "performance oriented mode" and its "sleep mode" corresponds to the "shut down mode" of claim 2.

    To meet limitations in other dependent claims, Petitioner relied on Lee. Specifically, claim 4 requires selecting a "leakage reduction value" based on a temperature of the integrated circuit. Petitioner argued that while Kim teaches using "external stimuli," Lee explicitly discloses using a temperature sensor to adjust its control signal to compensate for temperature-induced leakage. Claim 5 recites selecting a "retention value" when the circuit is in a "retention mode." Petitioner argued that Lee's "standby mode," which reduces power while retaining data, is analogous to the claimed retention mode. Claim 7 combines these elements, requiring selection of a retention value based on both temperature and leakage, which Petitioner argued is rendered obvious by the combination of Kim and Lee.

  • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would be motivated to combine the teachings of Kim and Lee. A POSITA would combine Lee's temperature-based control with Kim's system to improve it by addressing the well-known problem of temperature-dependent leakage, a modification suggested by Kim's own disclosure of using "external stimuli." A POSITA would also have been motivated to add Lee's "standby" (retention) mode to Kim's two-mode system to provide a more granular power-saving state that preserves data, a common and beneficial feature in processor design for enabling faster returns to an active state.

  • Expectation of Success: Petitioner asserted a POSITA would have had a reasonable expectation of success. Combining these known elements would involve applying a known technique (Lee's temperature compensation and multi-mode power management) to a similar system (Kim's) to achieve the predictable result of improved power management. The integration of a temperature sensor or an additional mode signal into Kim's architecture was presented as a matter of routine design choice with predictable outcomes.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that the Board should not exercise its discretion to deny institution under §314(a) or §325(d). It contended that the petition raises unique issues and presents prior art arguments not previously considered by the USPTO. Petitioner also asserted that an inter partes review (IPR) would be an efficient and effective alternative to the parallel, complex district court litigation, particularly given the uncertainty of the district court trial schedule.

5. Relief Requested

• Petitioner requests institution of an IPR and cancellation of claims 1, 2, 4, 5, and 7 of the ’026 patent as unpatentable.