Synopsys, Inc. v. Atoptech, Inc.
685 F. App'x 951
| Fed. Cir. | 2017Background
- Synopsys owns U.S. Patent No. 6,567,967, which claims methods for improving integrated-circuit layout by splitting large components into smaller subcomponents and optimizing interconnections.
- Relevant claim elements: claim 1 requires “flattening … by eliminating superfluous levels of hierarchy above said atomic blocks”; claim 32 requires “determining optimal placement of each of the hard blocks.”
- ATopTech petitioned for inter partes review (IPR); the Patent Trial and Appeal Board instituted review and found claim 1 obvious in view of Fields and Su, and found claim 32 anticipated by Su. Dependent claims tied to claim 1 were also held obvious.
- Fields describes reorganizing FPGA hierarchical blocks (splitting R0 and X0 into smaller same-level blocks) and warns that excessively flat designs can be hard to route.
- Su describes a performance-driven method focused on soft-macro clustering and placement, provides algorithms for optimal soft-block size/location, and briefly states that a commercial floorplanner is used to place hard macros.
- Synopsys appealed the Board’s findings to the Federal Circuit; the panel reviews legal conclusions de novo and factual findings for substantial evidence.
Issues
| Issue | Plaintiff's Argument (ATopTech) | Defendant's Argument (Synopsys) | Held |
|---|---|---|---|
| Whether Fields and Su disclose/elicit "flattening" by eliminating superfluous hierarchy above atomic blocks (claim 1 / obviousness) | Fields and Su together show removal of hierarchy levels above atomic blocks; figures show macros moved to same layout plane | Neither reference teaches eliminating hierarchy above atomic blocks; Fields expands same-level blocks; Su’s figures are unrelated and don’t show flattening above atomic blocks | Reversed: Board’s obviousness finding not supported by substantial evidence; neither reference nor combination teaches the claimed flattening |
| Whether Su anticipates claim 32’s “determining optimal placement of each of the hard blocks” | Su’s use of a commercial floorplanner and performance-driven methodology implies optimal placement of hard blocks | Su focuses on soft-macro placement; floorplanner reference does not disclose optimal hard-block placement | Reversed: Su does not expressly or inherently disclose optimal placement of hard blocks; Board’s anticipation finding not supported by substantial evidence |
Key Cases Cited
- Meiresonne v. Google, Inc., 849 F.3d 1379 (Fed. Cir.) (review standards: legal conclusions de novo; factual findings for substantial evidence)
- REG Synthetic Fuels, LLC v. Neste Oil Oyj, 841 F.3d 954 (Fed. Cir.) (anticipation is a question of fact reviewed for substantial evidence)
- Apple Inc. v. Samsung Elecs. Co., 839 F.3d 1034 (Fed. Cir.) (obviousness is a legal conclusion based on underlying facts)
- King Pharm., Inc. v. Eon Labs, Inc., 616 F.3d 1267 (Fed. Cir.) (inherency requires that the unstated limitation must necessarily be present)