Intellectual Ventures I, LLC v. Lenovo Grp. Ltd.

365 F. Supp. 3d 200
CourtDistrict Court, District of Columbia
DecidedMarch 13, 2019
DocketCivil Action No. 16-10860-PBS; Civil Action No. 16-10868-PBS
StatusPublished
Cited by1 cases

This text of 365 F. Supp. 3d 200 (Intellectual Ventures I, LLC v. Lenovo Grp. Ltd.) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Intellectual Ventures I, LLC v. Lenovo Grp. Ltd., 365 F. Supp. 3d 200 (D.D.C. 2019).

Opinion

Saris, C.J.

INTRODUCTION

Intellectual Ventures ("IV") accuses several technology companies1 of infringing U.S. Patent No. 6,516,442 ("the '442 patent") entitled "Channel interface and protocols for cache coherency in a scalable symmetric multiprocessor system."

*203IV asserts claims 2, 8, 11, 25, and 31 against Defendants. Independent claim 1 states:

1. A shared-memory multi-processor system comprising:
a switch fabric configured to switch packets containing data;
a plurality of channels configured to transfer the packets;
a plurality of switch interfaces configured to exchange the packets with the switch fabric, exchange the packets over the channels, and perform error correction of the data in the packets exchanged over the channels;
a plurality of microprocessor interfaces configured to exchange the data with a plurality of microprocessors, exchange the packets with the switch interfaces over the channels, and perform error correction of the data in the packets exchanged over the channels; and
a memory interface configured to exchange the data with a memory device, exchange the packets with the switch interfaces over the channels, and perform error correction of the data in the packets exchanged over the channels.

Dependent claim 2 states:

2. The shared-memory multi-processor system of claim 1 wherein the interfaces are configured to add error correction codes to the packets being transferred over the channels to check the error correction codes in the packets being received over the channels and to transfer a retry request if one of the packets being received has an error.

'442 patent, claims 1 and 2 (emphasis added). The disputed terms are underlined. The parties dispute the claim construction of three terms: "packet," "error correction," and "error correction code." The Court held a non-evidentiary Markman hearing on November 16, 2018.

BACKGROUND

A. The '442 patent

The '442 patent relates to a type of computer architecture known as a symmetric multiprocessor system or "shared-memory multi-processor system" ("SMP"). '442 patent at col. 1, ll. 17-18, 65-66. In a conventional SMP, two or more processors are connected to a shared memory device via one shared "bus" - or communication channel. See id. at col. 1, ll. 18-21. A processor retrieves data from memory to perform computations, and then sends information back to memory. These transactions between the processors and the memory take place one at a time over the shared bus. See id. at col. 1, ll. 30-32. The scalability of a conventional SMP is limited because "[a]s more processors are added [to the SMP], eventually system performance is limited by the saturation [i.e., bottlenecking] of the shared system bus." Id. at col. 1, ll. 37-39.

The '442 patent solves this problem by using a "switched fabric (switch matrix) for data transfers that provides multiple concurrent buses that enable greatly increased bandwidth between processors and shared memory." Id. at col. 1, ll. 50-53. Parties have agreed that the term "switch fabric" should be construed to mean "a data switching circuitry having a matrix or similar arrangement of interconnections." Docket No. 195 at 6 n.1; Docket No. 196 at 9.

Figure 3 of the '442 patent, reproduced below, shows the basic components of the claimed system using a Flow Control Unit (FCU 220). The system includes multiple processors (CPU 120), shared memory devices (SDRAM 1300-1303), and a switch fabric composed of multiple vertical and horizontal buses (320 and 340) and switches (380). Each component has a corresponding "interface." In the '442 patent's system, processors (120) and memory devices *204(1300-1303) exchange data with, and communicate through, processor interfaces (DCIU 210) and memory interfaces (MCU 230). See '442 patent at col. 2, ll. 60-67.

A "channel" is "a general-purpose, high-speed, point-to-point, full-duplex, bi-directional interconnect bus." 'Id. at col. 6, ll. 40-43. A "packet" is sent between Channel Interface Block (CIB) transceivers via a channel. Id. at col. 6, l. 65 - col. 7, l. 2. "A 'packet' is the basic unit of transport over the channel." Id. at col. 6, l. 53. In a preferred embodiment, a "packet is a single 80-bit frame (information unit) exchanged between CIBs" over a channel. Id. at col. 6, ll. 54-60. It includes data, control information, and error correction code (ECC).2 Id. at col. 6, ll. 54-63.

B. Prior Litigation on the '442 Patent ("HCC Litigation")

In July 2015, IV sued EMC customer HCC Insurance Holdings in the Eastern District of Texas, asserting the '442 patent along with three other patents. See Docket No. 179-1, Compl., Intellectual Ventures I LLC v. HCC Insurance Holdings, Inc. , No. 6:15-cv-660 (E.D. Tex.). IV submitted an opening claim construction brief, arguing that all disputed terms should be given their "plain and ordinary meaning." See Docket No. 195-7 ("HCC Litigation Opening Brief") at 13-23. The magistrate judge held a Markman hearing and produced a report and recommendation construing disputed terms, including "packet," "error correction," and "error correction code." The magistrate judge construed "packet" to mean "a basic unit of transport over a channel that includes data, control information, and error correction code"; "error correction" to mean "reconstruction of erroneous data"; and "error correction code" to mean a "code that can be used to correct erroneous data." Docket No. 195-4 ("HCC Litigation R & R") at 8-14. The case settled.

*205C.

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Bluebook (online)
365 F. Supp. 3d 200, Counsel Stack Legal Research, https://law.counselstack.com/opinion/intellectual-ventures-i-llc-v-lenovo-grp-ltd-dcd-2019.