Intellectual Ventures I LLC et al v. Toshiba Corporation et al

Filing 277

MEMORANDUM ORDER re: claim construction. Signed by Judge Sue L. Robinson on 12/17/2015. (nmfn)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
INTELLECTUAL VENTURES I LLC and
INTELLECTUAL VENTURES II LLC,
Plaintiffs/Counterclaim
Defendants,

v.
TOSHIBA CORPORATION, TOSHIBA
AMERICA, INC., TOSHIBA AMERICA
ELECTRONIC COMPONENTS, INC., and
TOSHIBA AMERICA INFORMATION
SYSTEMS, INC.,
Defendants/Counterclaim
Plaintiffs.

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) Civ. No. 13-453-SLR
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MEMORANDUM ORDER
At Wilmington this l1-"°' ay of December, 2015, having heard argument on, and
d
having reviewed the papers submitted in connection with, the parties' proposed claim
construction;
IT IS ORDERED that the disputed claim language of U.S. Patent Nos. 5, 701,270
("the '270 patent"); 5,568,431 ("the '431 patent"); 5,600,606 ("the '606 patent");
5,829,016 ("the '016 patent"); 5,500,819 ("the '819 patent"); 7,836,371 ("the '371
patent"); 5,938,742 ("the '742 patent"); 6,618,788 ("the '788 patent") shall be construed
consistent with the tenets of claim construction set forth by the United States Court of
Appeals for the Federal Circuit in Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005),
as follows:

The '270 Patent
1. "First and second banks of memory:" 1 "First and second arrays of
memory." "Plurality of memory banks:" 2 "Two or more arrays of memory." The
specification explains that:
[F]rame buffer 104 is partitioned into a selected number of memory blocks
200. In the illustrated embodiment, four memory blocks 200a-200d are
provided each of which contains an array of memory cells arranged as X
number of rows and Y number of columns and configured, output at n-bit
words per address. Each memory block is associated with an address
decoder 201.
(7:17-24) The patent refers to "multi-bank systems" and describes "inter-bank
row/column replacements," i.e., replacing defective row/columns with redundant
row/columns from another bank. (13:58-62) The specification and claim language 3
explain that each array is made up of "a predetermined number of primary memory cells
and a predetermined number of redundant memory cells." This language further
illustrates that the memory banks are delineated from one another in a "predetermined"
fashion.
2. "Redundant memory cells:" 4 "Additional memory cells that are designed
only for use in replacing defective primary memory cells." The invention's "principles
allow for the replacement of a defective row or column of a given bank with a row or
column of any other bank or array in the memory subsystem. This feature

1

Found in claim 1.
Found in claim 20.
3 Claim 1 recites in part "first and second banks of memory, each said bank including a
predetermined number of primary memory cells and a predetermined number of
redundant memory cells," and claim 20 recites "a plurality of memory banks each
comprising an array of memory cells, each said array including a preselected number of
primary cells and a preselected number of redundant memory cells."
4 Found in claims 1-2 and 20.
2

2

advantageously allows for the optimal use of the available redundant cells thereby
allowing for increased chip yield." (5:21-26; see also 4:22-27) (emphasis added) In one
embodiment, "each memory bank includ[es] a predetermined number of primary
memory cells and a predetermined number of redundant memory cells." (4:33-36) In
another embodiment, "each array includ[es] a preselected number of primary rows and
columns and a preselected number of redundant rows and columns .... Second
address logic is included for addressing the redundant rows and columns in response to
bits presented by the processing circuitry on a redundancy bus." (4:44-52) The
specification also states that "each memory block includes a number of redundant cells .
for repairing defective cells by substitution ." (7:29-33)

3. "Allowing said processing circuitry to address at least one of said
primary [redundant] memory cells:" 5 "Allowing said processing circuitry to access at

least one of said primary [redundant] memory cells." The specification explains that
processing circuitry is used to address the memory cells. (4:37-40, 47-52) For
example,
a defective set of memory cells is identified in a first one of the banks, the
defective memory cells associated with a bank select bit and a location
address bit and addressable by the controller by a primary address bus. A
redundant set of memory cells is programmed in a second one of the
banks, the redundant set of qells addressable with a bank select bit, a
primary location address bit, and a redundancy address bit by the
controller via a redundancy address bus. Access is then steered from the
defective set of cells to the corresponding redundant cells by addressing
the redundant set of cells via the redundancy bus.

5

Found in claim 1. The parties presented the shortened limitation "to address at least
one of said primary [redundant] memory cells" for construction.

3

(5:7-18) During prosecution, the applicant distinguished the Park reference 6 on several
grounds, including that "[c]laim 1 ... calls out for accesses on a cell basis, a feature
which is clearly not possible with Park." (D.I. 207, ex. 9 at A262) The court disagrees
with Toshiba that such a statement warrants the additional proposed language "on a
single cell basis." Indeed, the portion of the specification quoted above teaches
addressing a set of cells.
4. "Redundancy bus:" 7 "Address bus that allows for the addressing of the
redundant memory cells independent of the addressing of the primary memory cells
through the primary address bus." The specification explains that "[a]n address bus is
included for allowing a processing circuitry to address at least one of the primary
memory cells. A redundancy bus is provided for allowing the processing circuitry to
address at least one of the redundancy cells. " (4:36-40) The description of figure 2
makes no reference to a "redundancy bus" or a "redundancy address bus." Figure "3 is
a high level functional block diagram of a second integrated controller - memory device
300 according to the principles of the present invention. Integrated device 300 further
includes a k-bit wide redundancy address bus 301." (9:53-54) (emphasis added)
Redundancy bus 301 and the additional redundancy bits presented
thereon, advantageously allow for the steering of an access directed to a
defective row or column in one bank 200 to good row in another bank 200.
Specifically, redundancy bus 301 allows for addressing of the redundant
rows/columns 205 independent of the addressing of the primary rows and
columns through address bus 202.
(12:33-40)

6
7

U.S. Patent No. 5,469,388.
Found in claims 1, 3, and 20.

4

5. "Redundancy cell memory space separate from said primary cell

memory space:" 8 "Address set for redundant memory cells separate from the address
set for primary memory cells." The specification explains that the invention "allow[s] for
the replacement of a defective row or column of a given bank with a row or column of
any other bank or array in the memory subsystem." (5:20-24)
Specifically, redundancy bus 301 allows for addressing of the redundant
rows/columns 205 independent of the addressing of the primary rows and
columns through address bus 202. The redundancy address bits increase
the size to the address set (space) to each bank to accommodate unique
addressing of redundant rows/columns. Hence, even if the lower order
address bits are identical for a good primary row/column and a
programmed redundant row in the same bank, the redundancy address
bits Rz insure that an access is not steered to multiple rows/columns
during replacement.
(12:37-47)
Specifically, in multi-bank systems, inter-bank row/column replacements
can be implemented, thereby allowing the available redundancy resources
to be put to their best use. For example, if all the redundant rows/columns
of one bank have been used for repairs, yet redundant rows or columns
remain in another bank, the first bank can still be repaired and the full
capability of the overall device maintained as a result.
(13:60-67) As previously discussed, the prosecution history distinguishes the Park
reference on several grounds, including that the Park reference "does not disclose or
suggest [the] partitioning of the primary and redundant cells into separate memory
spaces." Moreover, "block to block replacements are not even possible" in the Park
reference, instead, "replacements can only be made within single blocks." (D.I. 207, ex.
9 at A261-262)

8

Found in claim 1.

5

The '431 Patent

6. "A plurality of arrays of memory cells:" 9 "Two or more arrays of memory
cells." The specification describes a memory array as "an array of rows and columns of
memory cells." (2:53-58) More specifically, the memory array "includes an array 202 of
storage cells 203 arranged in M number of rows and N number of columns. (5:61-63)
7. "A plurality of registers:" 10 "Two or more registers, each register
exclusively associated with an array of memory cells." The entire limitation at issue
recites "a plurality of registers, each of said registers for exchanging parallel bits of data
with a corresponding one of said arrays." "Data transfer circuitry for transferring
parallel bits of data from any selected one of said arrays through the
corresponding said register to any other selected one of said arrays through the
corresponding said register." 11 The court adopts Toshiba's proposal and constrains

this limitation in that "the first 'said register' is not the same register as the second 'said
register' recited in the claim."
8. The parties dispute whether two memory arrays may share the same register.
IV relies on Hill-Rom Servs., Inc. v. Stryker Corp., 755 F.3d 1367 (Fed. Cir. 2014), to
argue that while the specification does not provide an embodiment with shared
registers, the claim language does not support the restriction of claim scope to the
described embodiment, wherein each memory bank has its own shift register. A court
should "depart from the plain and ordinary meaning of claim terms based on the
specification in only two instances: lexicography and disavowal." Id. at 1371.

9

Found in claim 1.
Found in claim 1.
Found in claim 1.

10
11

6

"Disavowal requires that 'the specification [or prosecution history] make[] clear that the
invention does not include a particular feature, ' or is clearly limited to a particular form of
the invention." Id. at 1372 (internal citations omitted).
[A]bsent some language in the specification or prosecution history
suggesting that the [limiting language] is important, essential , necessary,
[f]or the 'present invention, ' there is no basis to narrow the plain and
ordinary meaning of the term . . . . There are no magic words that must be
used, but to deviate from the plain and ordinary meaning of a claim term to
one of skill in the art, the patentee must, with some language, indicate a
clear intent to do so in the patent.

Id. at 1373. The patent at bar seeks to improve the speed of block data transfers
between address spaces. (2:11-19) The specification explains that
[e]ach memory unit is coupled to one parallel port of a corresponding shift
register. A second parallel port of each shift register is coupled to
interconnection circuitry, such as a bus. Under the control of associated
control circuitry, data may be exchanged between a given memory unit
and one or more other such memory units via the corresponding shift
registers and the interconnection circuitry.
(2:30-36) The embodiments describe using a register "coupled to the selected memory
unit" and "a plurality of shift registers each for controlling the exchange of data with a
respective subsystem." (2:47-50; 58-60) Figure 2, "a functional block diagram of a
memory according to the principles of the present invention ," illustrates a separate shift
register coupled to each memory array. The court concludes that the claim language
read in light of the specification suggests that each memory array is coupled to its own
register. Fenner Investments, Ltd. v. Gel/co P'ship , 778 F.3d 1320, 1322-23 (Fed. Cir.
2015) ("The terms used in patent claims are not construed in the abstract, but in the
context in which the term was presented and used by the patentee, as it would have
been understood by a person of ordinary skill in the field of the invention on reading the
patent documents.").
7

9. Extrinsic evidence. IV's expert, Dr. Huber, concludes that the claim
language indicates to a person of ordinary skill in that art that the registers may be the
same register. He further opines that "using a shared register for the transfer would
further the goals of the patent regarding speed and efficiency because that would
require fewer steps than using multiple registers." (D.I. 233

at~

19) Toshiba's expert,

Dr. Subramanian, opines that the claim language indicates to a person of ordinary skill
in the art that "the source address space and the destination address space reside
within different memory arrays," each array is coupled to a different register, and the
"data transfer circuitry is used to transfer the data between the register coupled to the
source array and the (different) register coupled to the destination array." (D.I. 202

at~

19) Moreover, "[o]ne of ordinary skill in the art would have understood that if the source
array and the destination array were associated with a common register, then data
could be transferred from the source array to the destination array through the common
register, bypassing the data transfer circuitry." (Id.

at~

21) In the context of the '431

patent, this would render the data transfer circuitry (and the invention) unnecessary.
"Therefore, each register recited in claim 1 must be exclusively associated with an array
of memory cells." (Id.) Evaluating the claim language in the context of the
specification's description of the prior art and invention, the court finds Toshiba's expert
more persuasive in this instance.

The '606 Patent
10. "Substantially simultaneously inputting said row address bit and

column address bit:" 12 "Inputting said row address bit and column address bit at

12

Found in claim 1.

8

substantially the same point in time." The specification describes a method of operating
a memory device, where "[a]t least one row address bit and at least one column
address bit are substantially simultaneously input during an address cycle." (Abstract;
2:32-34, 41-42, 49-51) The specification describes "serial" addressing - "row and
column addresses received at pins 220 and 230 may be word serially received (i.e., row
address bits received as a word and column address bits received subsequently as a
separate word) from a conventional multiplexed address bus" (6:20-24)- and uses the
language "substantially simultaneously" to distinguish it.
Memory system 600 is substantially similar to memory system 200, with
the primary difference being that a non-multiplexed addressing scheme is
used. In other words, during each random access, instead of receiving
and latching-in the row address with RAS and subsequently receiving and
latching in the column address with CAS, all row and column address bits
are received from the associated data bus and latched-in substantially
simultaneously.
(8:22-31) The specification describes using both "address dedicated pins 220 and the
multiplexed address/data pins 230" to input row and column address bits for the
operation of the memory devices. (6:64-7:1; see also 8:66-9:5)
11. "Column address:" 13 "the address of a column in the array." The
specification describes pins receiving "row and column addresses" (6:19-28); the
memory device waiting "for a new set of row and column addresses" (7:22-24); and
inputting "row and column addresses" (7:25-26).

13

Found in claim 1.

9

The 'O 16 Patent

12. "Command and control cycle:" 14 "Command and control mode." The
specification explains that "a memory is provided which includes a plurality of
inpuUoutput terminals for exchanging data bits during a data access cycle and receiving
command and control bits during a command and control cycle." (2:49-52) The
"inpuUoutput port (pins) 220, labelled 10(0:31 ), input or output data during a data access
mode (cycle) and receive command, control and address bits during a command and
control mode (cycle)." (6:42-46; see also 7:9-11) The specification describes the timing
scheme:
In some operations, such as setting the burst and page latencies or setting
the mask, the command and control cycle may not be immediately
followed by a data access cycle. In such cases, memory 200 idles or
resumes its previous data stream as appropriate until another command
opcode is received and decoded, either during a new command/control
cycle initiated by [a command bit] or during the same command/control
cycle.
(9:49-56) During prosecution, the applicant distinguished the Farmwald reference 15
(which required serial transmission of the addresses on the bus to the identified device),
arguing that it
does not disclose a system whose addressees, opcodes and control
signals are input during one cycle and data are accessed in another.
[The Farmwald reference] defeats the advantages of the present
invention, which include the ability to load information for control
addressing, and operations, and then simply performing data accesses
through the same pins. No serial address pipelining is required with the
present invention as in [the Farmwald reference].
(D.I. 208, ex. 12 at JA625)

14
15

Found in claims 1, 26, and 27.
U.S. Patent No. 5,408, 129.
10

13. Extrinsic evidence. Toshiba's proposed construction limits the "command
and control cycle" to "a single clock cycle." Toshiba's expert, Dr. Baker, opines that
figures 3A and 3B "show that the command opcodes, addresses and control bits of
claim 1, and the command opcodes and pointer bits of claim 26, are input to the
memory through the multiplexed input/output terminals . .. during a single clock
cycle." (D.I. 203at1'f 18) As to the prosecution history discussed above, Dr. Baker
explained that
[s]erial pipelining entails inputting (or outputting) information over multiple
clock cycles. . ..
. . . In contrast, if a piece of information is input in parallel, it is not divided
into words, but rather input all at once in a single clock cycle. A person of
skill in the art .. . would ... conclude that the '016 patent does not include
serial address pipelining over multiple clock cycles.

(Id. at 1l1'f 29-30)
14. Dr. Huber disagreed and opined that the "patent equates the terms 'cycle'
and 'mode' in the specification" and "a single clock cycle is referred to as CLK." (D.I.
233 at 1l 26) Moreover, claim 1
requires that addresses, command opcodes, and control bits are received
during a command and control cycle. One of ordinary skill in the art at the
time this patent was filed would understand that a "command and control
cycle" could take more than a single clock cycle (CLK), and would not
understand the "cycle" aspect of this term to refer to a single clock cycle.
Instead , "cycle" indicates an operating mode.

(Id.) Dr. Huber explained that the specification's description of a preferred embodiment
("a command bit (CMD) which is received through a selected input (pin) controls and
times the address/control and data access modes" (6:50-53)) means that
the durations of the various modes are controlled by a command bit and
are not limited to a single clock cycle (CLK). For example, 9:49-56
provides an example where a command opcode is received , followed by
an idle period, and then, "another command opcode is received and
11

decoded, either during a new command/control cycle initiated by CMD or
during the same command/control cycle."

(Id.) Dr. Huber additionally opines that the disputed prosecution history "does not
support the notion that a command and control cycle is a single clock cycle, and does
not mention 'CLK' or 'clock cycle.' The distinction ... was not directed to one clock
cycle vs. multiple clock cycles, but instead on the presence or absence of multiplexed
pins." (Id.

at~

27) The court finds Dr. Huber's explanations more consistent with the

specification's disclosures and the prosecution history and, therefore, more persuasive.
15. "Addresses:" 16 "Bits that identify locations in an array of memory cells.''
The specification states that "[t]he page pointer bits select one row in array 201 and the
burst pointer bits select at least one initial w-bit wide location along that row for access."
(10:6-8) Moreover, "[a]fter a delay of a pre-determined number of master clock cycles,
to allow for sense amplifiers 203 to set-up, 32-bit words of data can be read or written
to/from locations of the selected page (row) .... " (10:24-27)
16. "Receiving addresses." 17 The parties disagree on whether the limitation
should exclude "serial address pipelining." For the reasons discussed above in
paragraphs 12 and 13, the court concludes that the applicant did not disclaim "serial
address pipelining" in distinguishing the Farmwald reference.
The '819 Patent
17. "Sensing the bitlines of the array to read data stored in the cells of the
selected row with a bank of master sense amplifiers:" 18 "Detecting and amplifying a

16

Found in claim 1.
Found in claim 1.
18 Found in claim 17. The parties submitted "sensing the bitlines of the array to read
data stored in the cells" for construction.
11

12

voltage level on each of the bitlines of the cells for reading data using sense amplifiers."
The memory system of the invention uses "master sense amplifier circuitry for reading
and writing data into ... selected cells." (2:55-57) The "bank of master sense
amplifiers is coupled to the bitlines." (3:18-19) "Mode control circuitry 214 receives
mode control signals from input circuitry 206 and provides in response wordline timing
and control signals to row decoder 205 and sense timing and control signals to master
sense amplifiers 208." (6:15-18) "A first row to be read is selected by activating the
associated wordline. The bitlines are then sensed with a bank of master sense
amplifiers to read the data stored in the cells of the first row." (3:55-58) The
specification also describes an example wherein, "[i]n a random access (read or write)
to the cells" of a memory array, "the master sense amplifier bank 208 sets the selected
bitlines 204 to the proper voltages." (6:24-25, 33-35)
18. Extrinsic evidence. The parties' experts offer competing opinions
regarding whether the limitation's construction should require "amplifying a voltage level
on each of the bitlines." Dr. Huber opines that bitlines are sensed. Moreover, he
disagrees that "sensing" must include amplifying the voltage, concluding that this would
be a separate step not recited in the claim and not discussed by the patent. Dr. Huber
opines that "there are multiple types of sense amplifiers, including notably differential
voltage sense amplifiers, current mirror sense amplifiers, and inverters," and that
Toshiba's construction would exclude "the entire class of sense amplifiers that detect
the differential voltage on a pair of bitlines." (D.I. 233 at 1J1J 31-32; D.I. 253at1J 10)
19. Mr. Murphy, Toshiba's expert, explains that "[a] sense amplifier senses the
bitline by detecting the slightly changed bitline voltage level and amplifying that voltage

13

level to a proper, full voltage representing the 'high' or 'low' logic value stored in the
cell." (D.I. 204

at~

12) To a person of ordinary skill in the art, "the term 'sensing'

means detecting voltages set on the bitlines by memory cells .... " (Id.

at~

13) More

specifically, Mr. Murphy describes:
When the data in a particular memory cell is read, that memory cell alone
is coupled to the bitline, inducing a change in the bitline voltage, the
direction of the change corresponding to the data value stored in the cell.
Because memory cells are so small, and the bitlines relatively large, the
memory cell is only capable of inducing a very small change in the bitline
voltage. Before other circuits can recognize what data this small change
represents, the small change must be amplified to a full "low" or a full
"high" voltage level. Detection alone is insufficient to sense the data
stored in the cells by master sense amplifiers. Sensing the bitlines of the
·array to read data stored in the cells requires both detecting and
amplifying a voltage level on each bitline, to read the data stored in the
cells.
(0.1. 244 at~ 6) As to the different types of sense amplifiers, Mr. Murphy explains that

"[w]hile the different types of sense amplifiers operate differently, they all sense a small
sense voltage and output a full 'low' or a full 'high' voltage level. Therefore, Toshiba's
construction is inclusive of all types of sense amplifiers." (Id.

at~

8)

20. The parties additionally provide a textbook reference 19 which explains that
read circuitry "involves the use of a sense amplifier to read the low level of signal from
the cell. A simple invertor can be used as a sense amplifier, however, a pair of singleended differential sense amplifiers are used in the case shown in Figure 5.8 since they
can sense and amplify a very small difference between the level on the bit and bit
lines." (D.I. 201, ex. G at TOSH-IV213008; see also 0.1. 232, ex. D) The court finds Mr.

19

Betty Prince, Semiconcuctor Memories: A Handbook of Design, Manufacture, and
Application (2nd ed. 1991 ).
14

Murphy's explanations more persuasive in the context of the patent and extrinsic
evidence.
21. "Writing the data:" 20 "Transferring said amplified voltage level to the
bitlines for writing data." The specification states that to write data, "[f]irst data is
latched in a first bank of slave sense amplifiers. This first data is then written into first
selected cells in the array." (4:3-5) To write entire rows, data inputs and writes to the
array are alternated "until a desired block of data has been written. Preferably, each
slave sense amplifier bank 210 and 211 includes write driver (buffer) circuitry which
provides sufficient write voltage drive to cause master sense amplifiers 208 to latch the
proper write voltages and transfer these voltages to the bitlines 204."21 (7:32-38)
The '371 Patent
22. "System operation signals during normal system operation:" 22 "Signals
internal to the integrated circuit when the integrated circuit is operating normally."
"System operation signals on said system bus during normal system
operation:" 23 "Signals internal to the integrated circuit on said system bus when the
integrated circuit is operating normally." The abstract provides that "[t]est and debug
circuits may be designed to observe states in user-definable circuits during the normal
system operation of said user-definable circuits. " (Abstract) According to the invention,
"a Service Processor Unit (SPU) is incorporated within an integrated circuit" (IC) and
used to address "the problems of testing and debugging the IC," thus simplifying "the

°Found in claims 17 and 19.

2

21

The court also relies on the intrinsic and extrinsic evidence discussed in paragraphs
16-18.
22 Found in claim 1.
23 Found in claim 7.
15

problem of resetting the IC and observing its current state." (4:33-38) The specification
describes a mode of operation where
the diagnostics console 103 invoke[s] the IC 100 to execute its normal
system operations. If and when the selected trigger event is detected and
the analysis engine 215 has captured the required data, the diagnostics
console 103 instructs the SPU 101 to transfer the captured data values
out of the IC 100 and into the diagnostics console 103 where the data may
be formatted and presented for analysis and interpretation.
(14:20-27) The specification also describes "normal mode" and "test mode" in the
context of input and output signals, which terms do not define "normal system
operations:" 24
The control signal on the line 300 selects whether the functional signal at
data-in terminal 302 or the signal held in the scan flip-flop 301 is passed
onto the data-out terminal 307. When the control signal of the line 300
signal is not-asserted, i.e., normal mode, there is normal operational
signal flow between the data-in terminal 302 and the data-out terminal
307. On the other hand, when the control signal on the line 300 is in
asserted state, i.e., test mode, the current state of the scan flip-flop 301 is
passed onto the data-out terminal 307; the data-in terminal 302 and the
data-out terminal 307 are isolated from one another.
(8:4-15)25
23. "System bus:"

26

"A communication path within a system that can be

shared." The specification describes various embodiments wherein the system bus
connects various components: a host processor connected by a system bus to various
circuit blocks (6: 15-17); a peripheral bus which is connected to the system bus by a
bridge (6: 19-20); "a system bus interface 214, a test bus interface 213 and a built-in

24

This section of the specification contains the singular use of each term - "test mode"
and "normal mode."
25 Extrinsic evidence. IV's expert, Dr. Oklobzija, opines that this passage shows that
"normal mode and test mode are used to refer to how data signals are passed out from
the device." (D.I. 235at1f 16)
26 Found in claim 7.
16

self-test (BIST} engine 212, which are all interconnected by a processor bus 219" (6:3740); and the system bus connected to the SPU 101 (10:20-21; 12:30-31 ).
The '7 42 Patent

24. "Bus interrupt line:" 27 "A line dedicated to carrying bus interrupt signals."
The specification describes "an intelligent daisy-chainable serial (IDCS) bus structure
[that] is used to connect one or more peripheral devices to a base station such as a
palm-top computer." (2:13-17) "The ICDS bus of this invention is fully interrupt driven.
Peripheral devices send interrupts over a bus interrupt line to get the attention of the
bus dispatch unit." 28 (4:25-27) "Base station 100 is connected to bus connector 401 by
a first bi-directional signal line MBDATA, a second bi-directional signal line MBCLK, and
unidirectional interrupt line MBINT." (12:65-13:1) "If a peripheral device needs to
transfer data to bus dispatch 305, peripheral device 410, 420 or 430 must first interrupt
bus dispatch 305 via a unidirectional interrupt on its respective line MBINT .... "
(14:50-53) "Interrupt signals flow only from peripheral devices ... to bus dispatch 305,
i.e., upstream only, and so buffers on line MBINT pass a signal upstream to bus
dispatch 305." (17:1-4)
25. "Data transfer speed of the peripheral device:" 29 "Speed at which the
peripheral device can transfer data." Claims 62 and 63 recite in part "wherein
information including the data transfer speed of the peripheral device is sent to a bus

Found in claim 57.
Extrinsic evidence. Toshiba's expert, Dr. Stevenson, opines that "if a line is denoted
as carrying a certain type of signal, a person of ordinary skill in the art would understand
that it only carries that type of signal." (D.I. 205 at 1f 19) IV did not provide expert
testimony regarding this claim limitation.
29 Found in claims 62 and 63.
21
28

17

dispatch." The specification explains that a peripheral configuration sequence is
performed, wherein
bus dispatch 305 requests identification and peripheral information ... for
each newly addressed peripheral device on IDCS bus 150. Bus dispatch
305 also locates and attaches a peripheral client for each of the newly
addressed peripheral devices. The information procured tells bus
dispatch 305 how to refer to the peripheral device and the speeds at which
bus dispatch 305 can send commands and data to the peripheral device
as well as important peripheral device requirements like the frequency of
interrupt servicing required during isochronous data transfers.
(50:43-53) Command sequencer 2614, has a "set bus speed step 2901" in which "bus
dispatch 305 sets the speed of IDCS bus 150 based on the type of command or data
being sent and the capabilities of the addressed peripheral device." (59:30-33)
26. "Locate peripheral client sequence:" 30 "Steps used to find the client
(software driver) that can service the peripheral device." The specification explains that
in the "locate client sequence 2103, ... bus dispatch 305 uses the peripheral ID
information to find the client that can service the peripheral device." (54:18-21) The
"client" is the "software driver'' for the peripheral device. (2:33-39)
The '788 Patent

27. "Packet-to-ATA bridge" 31 and "packet-to-ATA bridging device:" 32
"Hardware or software that enables packet-to-ATA or ATA-to-packet transfer." The
specifications explains that "[t]he portions of the [patented] method ... that are
performed by the bridge form another aspect of the invention. The methods can be

3o
31
32

Found in claim 62.
Found in claim 10.
Found in claim 24.
18

performed by hardware, software, or a combination of the two." (4:24-27) More
specifically,
[a]lthough the [patent's] description focuses on a hardware bridge
implementation, the described methods are also appropriate for software
implementation. As such, the scope of the present invention extends to
an apparatus comprising a computer-readable medium containing
computer instructions that, when executed, cause a processor or multiple
communicating processors to perform one of the described methods.
(13:30-38)
28. "Parsing the command block into a sequence of ATA register
operations:" 33 "Retrieving a sequence of ATA register operations from the command

block." The specification explains that a command block in packet format is transmitted
to the packet-to-ATA bridge. "The bridge parses the command block into a sequence of
ATA operations necessary to execute the given ATA register-delivered transaction."
(4:9-23) For example, "an ATA command protocol adapter is included [in an apparatus
comprising a packet-to-ATA bridge] to parse a command packet into a sequence of ATA
register operations and cause that sequence of operations to be performed by the ATA
register protocol adapter." (4:41-44) Or, "[w]hen controller 166 receives an ATA
command block, it recognizes the command block as such, checks it for
inconsistencies, and parses it into a sequence of ATA register accesses." (6:11-14)
29. "ATA interface:" 34 "Component used to transmit ATA host signals to an
ATA device and receive ATA device signals from the device." The specification
describes the "ATA interface 98 [as] provid[ing] the low-level timing, handshaking, and
signal-driving necessary to communicate with ATAPI device 100 over ATA PHY 101."

33
34

Found in claims 10 and 24.
Found in claims 10 and 24.
19

(3:34-37) In another aspect of the invention, "[t]he bridge also comprises an ATA
interface to transmit ATA bus host signals to an ATA device and receive ATA device
signals from the device." (4:34-36)
30. The court has provided a construction in quotes for the claim limitations at
issue. The parties are expected to present the claim construction consistently with any
explanation or clarification herein provided by the court, even if such language is not
included within the quotes.

20