PTAB

IPR2021-01111

Intel Corp v. Acqis LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Computer System with Attached Computer Module and Peripheral Console
  • Brief Description: The ’750 patent describes a modular computer architecture comprising a removable Attached Computer Module (ACM) containing core processing components (CPU, graphics) and a Peripheral Console (PCON) containing I/O devices and expansion slots. The two units connect via an Exchange Interface System (XIS) bus.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chu330 and Cupps - Claims 5-13, 18-20, 25-28, 35-38, and 46-47 are obvious over Chu330 in view of Cupps.

  • Prior Art Relied Upon: Chu330 (Patent 6,345,330) and Cupps (Application # 2003/0135771).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chu330, which is substantially identical to the ’750 patent’s disclosure, teaches nearly every limitation of the challenged claims. Chu330 discloses a modular computer with an ACM containing a CPU, graphics subsystem, and a host interface controller (HIC), and a PCON, connected by a high-speed bus (XPBus) that uses Low Voltage Differential Signal (LVDS) channels. However, Chu330 discloses these core components as discrete units. The key limitations not explicitly taught by Chu330 are the integration of the CPU, graphics subsystem, and/or interface controller onto a single chip and the direct connection of an LVDS channel to this integrated chip. Cupps was introduced to supply these missing elements. Cupps explicitly teaches integrating a CPU (non-embedded processor), graphics controller (GMCH), and I/O controller (ICH) onto a single integrated circuit chip to combine their functionalities. The combination of Chu330’s architecture with Cupps’s single-chip integration teaching renders the claims obvious.
    • Motivation to Combine: Petitioner asserted two primary motivations for a Person of Ordinary Skill in the Art (POSITA) to combine the references. First, Chu330 expressly states a design goal of low power consumption, and Cupps teaches that integrating components onto a single chip is a well-known method to achieve "improved power efficiency." A POSITA would have been motivated to apply Cupps’s power-saving integration technique to Chu330’s similar system. Second, Cupps discloses other predictable benefits of integration, including increased performance, reduced component count, and a smaller physical footprint, all of which would have been desirable improvements to the modular system of Chu330.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the components described in Chu330 (CPU, graphics, interface controller) are functionally analogous to the processors and controllers that Cupps teaches integrating onto a single chip. Applying this known integration technique to Chu330’s components would yield the predictable results of improved efficiency and performance as taught by Cupps.

4. Key Technical Contentions (Beyond Claim Construction)

  • Priority Date Challenge: A central contention of the petition is that the ’750 patent is not entitled to a priority date earlier than April 15, 2011. Petitioner argued that the key limitations requiring an "integrated CPU-graphics/controller" in a "single chip" were not disclosed in any application in the priority chain preceding the ’436 patent. This subject matter, including Figure 8B which allegedly provides the only support for these limitations, was first introduced via an amendment on April 15, 2011. Petitioner contended that the patent owner’s attempt to incorporate this matter by reference from the ’886 provisional into an earlier application (Chu330) was legally deficient because it was, at best, a claim to priority and not an express, specific incorporation of technical disclosure within the four corners of the specification. This effective priority date makes Cupps (2003) and Chu330 (1998) valid prior art against all challenged claims.

5. Arguments Regarding Discretionary Denial

  • Arguments Against §325(d) Denial: Petitioner argued that denial under §325(d) was inappropriate because the Examiner never substantively considered the prior art or arguments in a manner material to patentability. Although Chu330 was listed in an Information Disclosure Statement, it was never applied against any claims. Furthermore, the Examiner materially erred by failing to properly determine the priority date of the challenged claims, and therefore never considered references like Cupps, which teach the allegedly new matter.
  • Arguments Against Discretionary Denial under Fintiv: Petitioner contended that the Fintiv factors strongly favor institution. The trial date in the parallel district court litigation involving Real Parties-in-Interest (RPIs) was estimated to be December 2022, approximately 18 months after the petition filing and well after the statutory deadline for a Final Written Decision (FWD). The litigation was in its early stages, with discovery stayed and no claim construction briefing. Crucially, Petitioner Intel Corporation is not a party to the parallel litigation, a fact which weighs heavily against denial. Moreover, the RPIs expressed a willingness to stipulate not to pursue the same invalidity grounds in the district court if the IPR was instituted, mitigating concerns of duplicative efforts.

6. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 5-13, 18-20, 25-28, 35-38, and 46-47 of the ’750 patent as unpatentable.