In its Decision, the Board denied institution of inter partes review of any of the challenged claims of the ’861 Patent. The ’861 Patent involves memory devices such as Quad Data Rate (“QDR”) Static Random Access Memory (“SRAM”) devices. The ’861 Patent allows the write operation to commence immediately after the read operations by using a write address captured during a prior clock cycle, rather than during the same clock cycle as in the prior art.
The Board began with claim construction, stating that they interpret the terms using the broadest reasonable construction in light of the specification of the patent. Petitioner proposed an interpretation of the phrase “as soon as,” but Patent Owner argued that the interpretation of the phrase is unnecessary for purposes of this Decision. The Board agreed with Patent Owner that an express construction is not necessary. Patent Owner proposed an interpretation of the “wherein” clause, but the Board again found that express construction is not necessary.
Turning to the grounds of patentability, the Board noted that each challenged claim requires that the write address received in a given clock cycle is not the write address used in that clock cycle and, complementary to this, that the write address used in that clock cycle was received in a prior clock cycle. The Board stated that each of Petitioner’s grounds of unpatentability relied on Takahashi to describe these features, but Petitioner had not sufficiently shown that Takahashi discloses these features. In particular, while Takahashi discloses a write operation immediately following a read operation, it enables this not by using a previously gathered write address, but by overlapping the read and write cycles and writing at the same time as selecting the word line. Petitioner also argued that these features are disclosed in Okuyama because it would have been obvious to implement the memory in Okuyama as a late write part, but Petitioner only provided a bare explanation of what “late write” means, and conclusory evidence and analysis as to how a “late write” would satisfy the limitations. Therefore, the Board found this insufficient to demonstrate a reasonable likelihood of prevailing in showing that the claims are obvious in view of Okuyama alone.
GSI Technology, Inc. v. Cypress Semiconductor Corporation, IPR2014-00419
Paper 9: Decision Denying Institution of Inter Partes Review
Dated: August 11, 2014
Patent 6,967,861 B2
Before: William V. Saindon, Miriam L. Quinn, and Kevin W. Cherry
Written by: Saindon
Related Proceedings: IPR2014-00121; IPR2014-00202; IPR2014-00426; IPR2014-00427; Cypress Semiconductor Corp. v. GSI Technology, Inc., No. 3:13-cv-02013-JST, 4:13-cv-03757-JST (N.D. Cal.)