In Re Rambus Inc.
694 F.3d 42
| Fed. Cir. | 2012Background
- Rambus appeals a PTO Board decision that claim 18 of Rambus’s ’918 patent is anticipated by Intel’s iAPX 432 Interconnect Architecture Reference Manual.
- The ’918 patent, part of the ’898 family, describes a memory device that outputs only a specified amount of data per request in a synchronous memory system; claim 18 sets out receiving block size information and outputting data synchronously with a clock.
- The district court in Micron construed ‘memory device’ as a broad memory subsystem component, not limited to a single chip or to a memory controller.
- During ex parte reexamination, the examiner rejected claim 18 as anticipated by the iAPX memory module, which includes multiple chips and a controller; Rambus appealed to the Board.
- The Board held that the iAPX memory module reads on the ’918 memory device, applying a broad read of ‘memory device’ that can encompass multi-chip structures with a controller.
- This court reviews claim construction de novo and upholds Board findings supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does ‘memory device’ require a single chip? | Rambus argues memory device must be single chip with no controller. | PTO contends memory device is broad and can include multiple chips and a controller. | No; broad construction upheld, not limited to single chip. |
| Can memory device include a controller? | Memory device excludes any controller or CPU; must be simple storage chip. | Memory device may include control logic; must enable interfacing, not purely storage. | Yes; memory device may have a controller providing necessary data-receiving/output logic. |
| Does iAPX memory module anticipate claim 18? | iAPX memory module is not the same as Rambus’s memory device; fails to anticipate. | iAPX module provides the same functionality; reads on the memory device as claimed. | Yes; substantial evidence supports anticipation. |
Key Cases Cited
- Cybor Corp. v. FAS Techs., Inc., 138 F.3d 1448 (Fed. Cir. 1998) (claim construction reviewed de novo)
- Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005) (use of intrinsic evidence in claim construction)
- Lisle Corp. v. A.J. Manufacturing, 398 F.3d 1314 (Fed. Cir. 2005) (claim scope and structural disavowals)
- Infineon Technologies AG v. Rambus, Inc., 318 F.3d 1081 (Fed. Cir. 2003) (memory device terminology and integration concepts)
- Omega Eng’g, Inc. v. Raytek Corp., 334 F.3d 1314 (Fed. Cir. 2003) (claim construction and ordinary meaning in context)