PTAB

IPR2026-00018

Samsung Electronics Co Ltd v. Netlist Inc

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1. Case Identification

2. Patent Overview

  • Title: Dual In-Line Memory Module (DIMM)
  • Brief Description: The ’366 patent relates to a dual in-line memory module (DIMM) with a controller, volatile memory (DDR SDRAM), and non-volatile memory. The module includes on-board power conversion circuits and a voltage monitor to detect power failures and trigger operations to save data from the volatile memory.

3. Grounds for Unpatentability

Ground 1: Claims 1-38 are obvious over Perego in view of Harris and Amidi

  • Prior Art Relied Upon: Perego (Patent 7,363,422), Harris (Application # 2006/0174140), and Amidi (Patent 7,724,604).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that the combination of Perego, Harris, and Amidi taught all limitations of the challenged claims. Perego disclosed a buffered memory module with a configurable buffer device allowing for flexible system configurations and support for different memory types, including DDR2 SDRAM. Perego’s module was disclosed as a DIMM with edge connectors for power, data, and address/control signals. However, Perego did not explicitly detail the power distribution scheme for the various components. Harris addressed this problem by teaching an on-board voltage regulator module (VRM) for a DIMM. This VRM received a single high-voltage input from the system board (e.g., +12V) and used converter circuits, such as buck converters, to generate the multiple different, lower regulated voltages required by on-board components like DRAM devices and buffer logic. Finally, to address data loss on power failure, Amidi disclosed a power management block for a memory module. Amidi’s system monitored the main system supply, and upon detecting a failure, it generated a trigger signal to switch to an on-board battery backup and place the DRAMs in a low-power self-refresh mode to preserve their data. Amidi also taught writing system status or configuration data to non-volatile memory in response to such a trigger.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine these references to achieve predictable benefits. A POSITA starting with Perego’s flexible buffered memory module would recognize the need for an efficient on-board power solution to supply the various required voltages for different components. Harris directly solved this problem by teaching an on-board VRM to locally convert a single +12V rail into the necessary regulated voltages, providing a more cost-effective and extensible power supply. This combination creates a flexible, self-powered memory module. A POSITA would then be further motivated to incorporate Amidi's power monitoring and backup techniques into the Perego-Harris module to improve its reliability and prevent data loss during power failures, a well-known industry problem. Amidi’s solution of using a power management block to switch to battery backup was a known technique for improving such memory systems. The Board had previously found in related cases that a POSITA would have been motivated to combine Harris and Amidi.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in making this combination. The integration involved applying known design principles: powering Perego’s module with Harris’s on-board VRM and adding Amidi’s standard power-fail detection and backup circuitry. These components, including buck converters for voltage regulation and supervisory circuits for voltage monitoring, were commercially available and their integration was well within the skill of a POSITA in 2007-2008. The combination simply applied known techniques to improve a known device type, yielding the predictable result of a reliable, flexible, self-powered memory module.

  • Additional Grounds: Petitioner noted that Ground 1 was omitted in this IPR petition, which was ranked relative to other petitions against the same patent.

4. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1-38 of the ’366 patent as unpatentable.