PTAB

IPR2024-00338

Samsung Electronics Co Ltd v. Network System Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Integrated Circuit with Networked Processing Modules
  • Brief Description: The ’449 patent relates to an integrated circuit with multiple processing modules connected by a network. The invention focuses on establishing connections with specific "connection properties," such as guaranteed throughput and latency, by using a "resource manager" to determine if network resources are available before creating a connection.

3. Grounds for Unpatentability

Ground 1: Obviousness over Goossens2002 and Drake - Claims 1-6 and 9-16 are obvious over Goossens2002 in view of Drake.

  • Prior Art Relied Upon: Goossens2002 (a 2002 article on "Networks on Silicon") and Drake (Patent 5,461,611).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Goossens2002 discloses a system-on-chip (SoC) with multiple intellectual property blocks (modules) connected by a packet-switched "network on silicon" (NOS) to provide guaranteed communication services. Goossens2002 recognized the need for resource management by mentioning a "quality-of-service [QoS] manager" but did not provide implementation details. Petitioner asserted that Drake remedies this deficiency by teaching a detailed QoS management system for packet networks. Drake's "QoS allocator" functions as the claimed "resource manager" by receiving requests for connections with specific properties (e.g., throughput, latency), checking a database to determine if network resources are available, and reserving them if they are. This combination allegedly teaches the key limitation that led to allowance: a resource manager determining connection availability based on connection properties.
    • Motivation to Combine: A POSITA would combine Goossens2002 with Drake to implement the functionality of the "QoS manager" that Goossens2002 identified as beneficial but did not detail. Drake provided a known, detailed solution to the same problem of managing network resources to ensure quality of service. This combination would predictably improve the performance of Goossens2002's network by ensuring that its promised "guaranteed services" could be reliably established and maintained in a resource-constrained SoC environment.
    • Expectation of Success: Petitioner contended a POSITA would have a high expectation of success, as both references address managing resources in packet-based networks to provide guaranteed services. Applying Drake’s established network management principles to the specific on-chip network context of Goossens2002 was presented as a predictable integration of known technologies.

Ground 2: Obviousness over Goossens2003 and Drake - Claims 1-6 and 9-16 are obvious over Goossens2003 in view of Drake.

  • Prior Art Relied Upon: Goossens2003 (a 2003 article on "Guaranteeing the Quality of Services in Networks on Chip") and Drake (Patent 5,461,611).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Goossens2003, co-authored by the inventors of the ’449 patent, discloses a network-on-chip (NOC) that provides differentiated services using "connections" between intellectual property blocks. Goossens2003 explicitly stated that establishing such connections requires "resource management" and that the NOC accepts or rejects connection requests based on whether it "has sufficient resources available," but it did not describe a specific component for making this determination. As in Ground 1, Petitioner argued that Drake’s "QoS allocator" supplies the detailed teachings of the claimed "resource manager" that is absent from Goossens2003.
    • Motivation to Combine: The motivation was presented as analogous to Ground 1. A POSITA seeking to implement the "resource management" process explicitly required by Goossens2003 would have been motivated to incorporate the known and detailed system from Drake. This would provide a concrete mechanism for determining resource availability and ensuring the reliable delivery of guaranteed services within the Goossens2003 NOC.
    • Expectation of Success: Petitioner asserted a high expectation of success, as the combination involves applying a well-understood network resource management system (Drake) to a system (Goossens2003) that expressly identified the need for such management to function as intended.

4. Key Technical Contentions (Beyond Claim Construction)

  • Petitioner contended that the challenged claims are not entitled to their asserted priority date of October 8, 2002. The argument was that the foreign priority application (EP196) fails to provide adequate written description for the claimed "resource manager" and "communication manager" and their respective functions. This contention, if successful, establishes that Goossens2002 (published August 2002) and Goossens2003 (published January 2003) are valid prior art references under pre-AIA 35 U.S.C. §102.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under 35 U.S.C. §325(d), noting that the asserted prior art references (Goossens2002, Goossens2003, Drake) and combinations were never considered during the original prosecution. The allowance was based on a limitation—the resource manager determining availability based on connection properties—that Petitioner contended is directly taught by the new art combinations.
  • To avoid discretionary denial under Fintiv, Petitioner stipulated that, if the IPR is instituted, it will not pursue in parallel district court litigation the specific grounds asserted in the petition or any other grounds that could have been reasonably raised. Petitioner also argued that the parallel litigation is in its early stages and that the petition presents compelling evidence of unpatentability.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-6 and 9-16 of Patent 7,373,449 as unpatentable.