Qualcomm Inc v. Network System Technologies LLC

1. Case Identification

• Case #: IPR2024-01081
• Patent #: Patent 7,373,449
• Filed: June 21, 2024
• Petitioner(s): Qualcomm Inc
• Patent Owner(s): Network System Technologies, LLC
• Challenged Claims: 2, 6, and 9-16

2. Patent Overview

• Title: Integrated Circuit with Resource Management
• Brief Description: The ’449 patent relates to an integrated circuit, or system-on-chip (SoC), comprising multiple processing modules connected by a network. The invention centers on a "resource manager" that establishes connections between modules by first determining if sufficient network resources are available to meet the desired properties (e.g., throughput, latency) of a requested connection.

3. Grounds for Unpatentability

Ground 1: Obviousness over Goossens2002 and Drake - Claims 2, 6, and 9-16 are obvious over Goossens2002 in view of Drake.

• Prior Art Relied Upon: Goossens2002 (a 2002 publication titled "Networks on Silicon: Combining Best-Effort and Guaranteed Services") and Drake (Patent 5,461,611).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Goossens2002 disclosed a "network on silicon" (NOS), an early form of a network-on-chip, that used connections between intellectual property blocks (IPs) to provide "guaranteed services" like minimum throughput and bounded latency. While Goossens2002 identified the need for managing network resources and mentioned a "quality-of-service manager," it lacked specific implementation details. Petitioner asserted that Drake supplied these missing details. Drake taught a quality of service (QoS) management system for packet networks, including a "QoS allocator" (resource manager) that receives connection requests with specific properties, determines if network resources are available by checking a database, and reserves those resources if available. Drake also disclosed connections with independently configurable forward and backward channels.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Drake's detailed QoS management system with Goossens2002's NOS to implement the functionally described but vaguely specified "quality-of-service manager." This combination would achieve the predictable result of improving the NOS's performance and efficiency by ensuring that resources for guaranteed-service connections were actually available before establishment, a known benefit explicitly taught by Drake.
  • Expectation of Success: Petitioner contended that a POSITA would have had a reasonable expectation of success. Both references operate in the same field of managing resources in packet-based networks to provide guaranteed services. Applying Drake's established network management principles to the emerging network-on-chip context described in Goossens2002 was a straightforward application of a known solution to a known problem.

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

• Prior Art Relied Upon: Goossens2003 (a 2003 publication titled "Guaranteeing the Quality of Services in Networks on Chip") and Drake (Patent 5,461,611).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground presented a similar argument to Ground 1. Goossens2003, authored by inventors of the ’449 patent, described a more advanced network-on-chip (NOC) that offered differentiated services and connections requiring "resource management." Goossens2003 stated that connection requests are accepted or rejected based on whether the NOC has "sufficient resources available" but did not describe a specific component or mechanism for making this determination. Petitioner again argued that Drake's "QoS allocator" provided the explicit solution for determining resource availability and managing connection establishment based on desired properties. Goossens2003 also disclosed request and response channels that could be independently configured, which mapped to Drake's teachings.
  • Motivation to Combine: The motivation was parallel to Ground 1. A POSITA seeking to implement the "resource management" required by Goossens2003 would have looked to known solutions like Drake to provide a concrete mechanism for determining resource availability. The combination would predictably enhance the Goossens2003 system by adding a robust, well-understood method for ensuring QoS guarantees.
  • Expectation of Success: The expectation of success was high for the same reasons as in Ground 1. The combination involved applying a mature, proven technology (Drake's QoS management) to a newer but related environment (Goossens2003's NOC) to achieve predictable improvements in resource allocation and service guarantees.

4. Key Claim Construction Positions

• For the purposes of the IPR petition, Petitioner agreed to apply the claim constructions used in a related IPR (IPR2024-00338).
• However, Petitioner explicitly reserved its right to argue in other litigation that the term "communication manager" is indefinite. This term is central to claims 2, 6, and 10.

5. Key Technical Contentions (Beyond Claim Construction)

• A central technical contention was that the ’449 patent itself acknowledged that many issues in on-chip communication were already subjects of research in local and wide-area networks, and that results from those fields are "very much related" and "applicable on chip."
• Petitioner leveraged this admission to argue that it would have been entirely obvious for a POSITA to apply the established QoS management techniques from a general-purpose network like Drake to the specific on-chip network context of Goossens2002 and Goossens2003.

6. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §314(a) and the Fintiv factors would be inappropriate.
• The petition asserted that at least four of the six Fintiv factors strongly weighed in favor of institution: there is no trial date set in the parallel district court litigation (Factor 2); the litigation is in its early stages with no claim construction order issued (Factor 3); the IPR challenges claims (2, 6, and 9) that are not at issue in the district court case (Factor 4); and the petition presents compelling evidence of unpatentability (Factor 6).

7. Relief Requested

• Petitioner requests institution of inter partes review and cancellation of claims 2, 6, and 9-16 of Patent 7,373,449 as unpatentable.