PTAB

IPR2023-00779

Intel Corp v. BiTMICRO LLC

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Multi-Profile Memory Controllers and Computing Devices
  • Brief Description: The ’190 patent discloses multi-profile memory controllers for solid-state storage devices. The controller performs memory transactions on a memory store containing multiple memory devices, where different memory locations are associated with distinct "device profiles" that contain a set of memory attributes (e.g., page size, device type).

3. Grounds for Unpatentability

Ground 1: Obviousness over Danilak and Cornwell - Claims 1-2, 5-8, 11, 19, 29-30, 33, 36-39, 42, 94, and 100 are obvious over Danilak in view of Cornwell.

  • Prior Art Relied Upon: Danilak (Application # 2008/0086588) and Cornwell (Application # 2007/0180186).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of Danilak and Cornwell discloses all limitations of the challenged claims. Danilak was asserted to teach the overall system architecture, including a "flash interface circuit" (the claimed "controller") that manages multiple physical flash memory devices and presents them to a host as a single "virtual flash memory device." Danilak’s system supports different memory types (e.g., NAND and NOR) with differing attributes. However, Petitioner contended that Danilak lacks detail on how the memory devices store their own configuration data.

    Cornwell was argued to supply this missing element by teaching a non-volatile memory device that stores its own "device data" in a dedicated area. This data includes attributes like page size, block size, access time, and device type (explicitly "NAND and/or NOR flash media"). Petitioner asserted that this stored "device data" in Cornwell directly corresponds to the "device profile" recited in the ’190 patent. The combination, therefore, taught a memory system (Danilak) where each memory device contains its own set of attributes (Cornwell), forming distinct device profiles for different memory types. The arguments for independent claims 29 (computer readable medium) and 100 (method) relied on the same mapping, with Petitioner arguing that implementing Danilak's controller functions in software was a well-known, motivated design choice.

    • Motivation to Combine: Petitioner asserted multiple motivations for a Person of Ordinary Skill in the Art (POSITA) to combine the references. First, a POSITA would combine Cornwell’s teachings into Danilak's system to create a complete, operational memory system. Danilak provided a high-level architecture but was silent on the internal structure of its flash devices; Cornwell provided the necessary, conventional details on how such a device stores its own configuration data. Second, the combination represented a simple substitution of a known element (Cornwell’s detailed memory device) for another (Danilak’s generic flash device) to achieve the predictable result of a functional memory system.

    Furthermore, Petitioner argued a POSITA would be motivated to use both NAND and NOR flash devices in the combined system to optimize performance. It was well-known that NOR flash is optimal for random-access reads (e.g., code execution), while NAND flash is superior for sequential writes and high-density storage. Combining them allowed a system to "get the best of both worlds," a common practice in devices like smartphones prior to the patent's filing date. This directly taught using different memory devices with different "profiles" optimized for different data types (random vs. sequential), as claimed.

    • Expectation of Success: Petitioner argued a POSITA would have a reasonable expectation of success because both references operate in the same technical field of flash memory management, address complementary aspects of system design, and rely on standard, predictable interfaces.

4. Arguments Regarding Discretionary Denial

  • Parallel Litigation (Fintiv Factors): Petitioner argued against discretionary denial based on parallel litigation in the Northern District of California (NDCA). It was asserted that the district court case was in its early stages, with no scheduling order, claim construction, or significant discovery having occurred. The estimated trial date in the NDCA (February 2025) was projected to be more than two months after the deadline for a Final Written Decision (FWD) in the IPR, weighing against denial.
  • Prior Petition (General Plastic Factors): Petitioner argued that a prior IPR filed by Kioxia America, Inc. against the ’190 patent should not preclude institution. Petitioner contended that it had no significant business relationship with Kioxia, was accused of infringement based on different products, and had no involvement in preparing or filing the Kioxia petition. As this was Petitioner's first challenge to the patent and was filed only nine days after the Kioxia IPR, Petitioner argued the Board could efficiently consider the petitions.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-2, 5-8, 11, 19, 29-30, 33, 36-39, 42, 94, and 100 of the ’190 patent as unpatentable.