PTAB

IPR2025-01171

Infineon Technologies Americas Corp v. MOSAID Technologies Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Managing Power on Integrated Circuits Using Power Islands
  • Brief Description: The ’306 patent discloses methods and systems for managing power on an integrated circuit. The technology involves partitioning the circuit into a plurality of "power islands" where power consumption can be independently controlled, and using a "power manager" to determine a target power level for an island and perform actions, such as selecting a frequency or modifying a voltage, to meet that target.

3. Grounds for Unpatentability

Ground 1: Obviousness over Nowka - Claims 1-8, 10-12, 14-23, 25-27, 29-34, 36-44, 46-48, 50-51 are obvious over Nowka.

  • Prior Art Relied Upon: Nowka (“A 32-bit PowerPC System-on-a-Chip With Support for Dynamic Voltage Scaling and Dynamic Frequency Scaling,” a Nov. 2002 IEEE Journal paper).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Nowka, a technical paper describing a system-on-a-chip (SOC), discloses all limitations of the challenged claims. Nowka’s SOC is divided into four distinct power “domains” which a person of ordinary skill in the art (POSITA) would have understood to be the claimed "power islands," as power is controlled independently within each. Nowka’s system software performs dynamic voltage and frequency scaling to meet the performance demands of an application while minimizing power consumption; this was mapped to the claimed steps of "determining a target power level" and "performing...actions" such as "selecting a frequency." The various power-saving features in Nowka, such as different clock domains, sleep/hibernation modes, and state-saving capabilities, were argued to teach the limitations of the dependent claims.
    • Key Aspects: This ground asserted that a single prior art reference, published before the patent’s priority date, renders a substantial majority of the patent's claims obvious.

Ground 2: Obviousness over Nowka and Borkar - Claims 9, 13, 24, 28, 45, and 49 are obvious over Nowka and Borkar.

  • Prior Art Relied Upon: Nowka (as described above) and Borkar (Patent 6,484,265).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground relied on Nowka for the base system of power islands with dynamic voltage and frequency scaling. Borkar was introduced to teach limitations related to modifying threshold voltage and monitoring power consumption levels. Borkar discloses controlling processor parameters by changing supply voltage, clock frequency, and threshold voltage. It also teaches using current detection circuitry to monitor power consumption, determine if a threshold level is crossed, and perform an action in response. This combination allegedly renders obvious claims requiring modification of a threshold voltage (claim 9) and monitoring a power consumption level against a threshold (claim 13).
    • Motivation to Combine: Petitioner argued a POSITA would combine Nowka and Borkar because both address the same problem of balancing performance and power consumption in integrated circuits. Nowka identifies static power leakage as a problem, and Borkar teaches using threshold voltage control as a specific solution to reduce leakage. A POSITA would have therefore looked to Borkar’s well-known techniques to improve the power management capabilities of the Nowka system.
    • Expectation of Success: The combination involved integrating a known technique (Borkar’s threshold voltage control and power monitoring) into a compatible system (Nowka’s SOC) to achieve the predictable benefit of improved static power control, resulting in a high expectation of success.

Ground 3: Obviousness over Nicol - Claims 1-5, 7-9, 11, 16-20, 22-24, 26, 31-33, 36-45, and 47 are obvious over Nicol.

  • Prior Art Relied Upon: Nicol (Patent 6,141,762).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Nicol, which discloses a dynamic load-balancing mechanism for multiprocessor systems, teaches the claimed invention. The multiple processing elements (PEs) in Nicol, each with its own independent clock and voltage source, constitute the claimed "power islands." Nicol’s operating system dynamically controls the processing load and adjusts the frequency and voltage of the PEs to minimize power consumption based on task requirements. This functionality was argued to meet the limitations of determining a target power level based on the needs and operation of the circuit and performing actions to meet that level. Nicol’s disclosure of varying threshold voltage as a known scaling technique was also argued to render claim 9 obvious.
    • Key Aspects: This ground presented an alternative primary reference that allegedly discloses the core concepts of the ’306 patent’s independent claims using a different architecture based on load-balancing between processing elements.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combining Nowka with Boerstler (for voltage multiplexing circuitry) and Bertin (for explicitly setting target power levels). Further grounds combined Nicol with Nowka (to add specific standby modes), Borkar (for power monitoring), and Naffziger (for voltage multiplexing circuitry).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should institute review because it had already done so in a prior IPR (IPR2024-00598) challenging the same patent with nearly identical grounds. That proceeding was terminated due to a settlement between the prior petitioner and the Patent Owner. Petitioner asserted that the Board has already deemed the patent likely unpatentable on these grounds, and it would be an inefficient use of resources to deny institution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-51 of Patent 7,051,306 as unpatentable.