PTAB

IPR2025-01008

Micron Technology Inc v. Palisade Technologies LLP

Key Events

Petition

petition

Title: Memory Card with Multiple Interfaces
Brief Description: The ’051 patent discloses portable handheld memory cards designed to transfer data using multiple interfaces. The invention features a housing with both a Universal Serial Bus (USB) port and a separate input/output (I/O) port (e.g., a Secure Digital port) positioned to allow a single insertion direction into a host device.

Prior Art Relied Upon: Diggs (Application # US2009/0031073).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Diggs, which was not considered during prosecution, teaches every element of the challenged claims. Diggs discloses a portable, handheld solid-state storage subsystem (a memory card) with multiple physical connectors for different interfaces, specifically a USB mini-A connector and an IEEE-1394 (Firewire) connector. Petitioner asserted that these two physically separate connectors, positioned on the same end of the card's housing, satisfy the key limitations of claim 1, including the USB port, I/O port, memory, controllers, and housing. Critically, because the ports are physically separate, connecting a host to the I/O port (IEEE-1394) necessarily means the USB port pins are not connected, and vice-versa, directly teaching the functional positioning requirement of the claims.
- Motivation to Combine (for §103 grounds): Not applicable as this ground is based on a single reference. Petitioner contended that all claimed features are present in Diggs.
- Expectation of Success (for §103 grounds): Not applicable.

Prior Art Relied Upon: Diggs (Application # US2009/0031073) and Thorsten (German Application # DE 10220629A1).
Core Argument for this Ground:
- Prior Art Mapping: This ground addresses dependent claims 2 and 17, which add limitations for decrypting encrypted data. Petitioner argued that Diggs teaches the base memory card of claim 1, while Thorsten supplies the missing decryption circuitry. Thorsten discloses a memory card with a "logic component" that performs on-card encryption and decryption, making the card compatible with various host applications without requiring the host to have specific decryption algorithms.
- Motivation to Combine (for §103 grounds): A POSITA would combine Thorsten's on-card encryption/decryption with Diggs's multi-interface memory card to solve a known problem: securely storing sensitive data while maintaining compatibility with different host devices. Adding Thorsten's host-agnostic security module to Diggs's versatile card was presented as a predictable improvement, applying a known technique to a known device to achieve expected results.
- Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success because both references describe similar memory card architectures, and Thorsten’s logic component could be readily integrated as an additional module with Diggs's controllers to achieve predictable data encryption and decryption.

Prior Art Relied Upon: Lin (Application # US 2006/0053241).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner presented Lin as an alternative primary reference that also teaches all elements of the independent claims. Lin discloses a removable memory card with a single set of interweaving contact pads that supports multiple operating modes, including a USB mode and a MultiMedia Card (MMC) mode. An interface mode detector determines which protocol to use upon insertion into a host. Petitioner argued this arrangement meets the claim limitations because the set of pins used for the USB mode constitutes the "USB port" and the set of pins used for the MMC mode constitutes the "I/O port." When the card operates in one mode (e.g., MMC), the pins dedicated to the other mode (e.g., USB's D+/D- pins) are not electrically connected to the host, satisfying the key "positioned such that" limitation through logical, rather than physical, separation.
- Motivation to Combine (for §103 grounds): Not applicable as this ground is based on a single reference.
- Expectation of Success (for §103 grounds): Not applicable.
Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 2 and 17 based on Lin in view of Thorsten, relying on the same motivation to add on-card encryption as in Ground 2.

Petitioner requests institution of an inter partes review and cancellation of claims 1-2, 4-8, 16-17, 20-21, and 23-27 of the ’051 patent as unpatentable.