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IYM Technologies LLC v. Advanced Micro Devices, Inc.

United States District Court, D. Delaware

October 27, 2017

IYM TECHNOLOGIES LLC Plaintiff,
v.
ADVANCED MICRO DEVICES, INC. Defendant.

          ORDER CONSTRUING THE TERMS OF U.S. PATENT NO. 7, 448.012

         After considering the submissions of the parties and hearing oral argument on the matter, IT IS HEREBY ORDERED, ADJUDGED, and DECREED that, as used in the asserted claims of U.S. Patent No. 7, 448, 012 ("the '012 patent"):

         1. The phrase "constructing a system of initial constraints among said layout objects, " as used in the '012 patent, is construed to mean "building a set of linear equations from the initial coordinate variables of the layout objects and the initial limitations on the geometry parameters of the layout objects."[1]

         2. The phrase "computing local process modifications to change said initial constraints using said descriptions of manufacturing process, " as used in the '012 patent, is construed to mean "computing location specific modifications to the system of initial constraints using said descriptions of the manufacturing process."[2]

         3. The phrase "constructing new local constraint distances by combining said local process modifications with constraint distances, " as used in the '012 patent, is construed to have its plain and ordinary meaning.[3]

         4. The phrase "enforcing said new local constraint distances, " as used in the '012 patent, is construed to mean "solving a set of equations after incorporating the new local constraint distances."[4]

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Notes:

[1] Plaintiffs argument is twofold: the term "constraints" needs no construction, but, if it does, the term means "limits on geometry parameters of the layout objects in the design layout." Defendant argues that the entire claim phrase requires construction and means "building a set of linear equations from the coordinate variables of the layout objects and constraint distances between layout objects." The court finds that both the term "constraints" and the entire claim phrase requires construction.

First, the term constraints should be construed to mean "limitations on the geometry parameters of the layout objects in the design layout." The Summary of the Invention describes the process of the layout production and design. When the initial layout is produced by the software, "the relative distance between layout objects are constrained by design rules." '012 patent col. 1, ll.21-23. The chip layout remains true to the design rules despite any modifications to the layout done by the present invention. Markman Hr'g Tr. 49:12-17. The design rules, therefore, act as the very first constraints among the layout objects. The specification explains that "design rules guarantee yield by limiting layout geometry parameters such as minimum spacing, minimal line width, etc." '012 patent, col. 3, ll. 10-11; see also Markman Hr'g Tr. 6:6-9. The court is satisfied that constraints, like design rules, are "limits on the geometry parameters of the layout objects in the design layout."

Plaintiff offered the court a definition of constraints, which the court accepted, but has failed to establish what "constructing a system of initial constraints" means. Defendant argues that the construction of a system of initial constraints requires three things: (1) linear equations, (2) constraint distances, and (3) coordinate variables. The court agrees that both linear equations and coordinate variables should be included in the construction of this claim phrase, but the court will not include constraint distances in its construction.

The specification and prosecution history support Defendant's argument that linear equations are a required component in the construction of a system of initial constraints. Defendant asks the court to limit the inventor's claimed "system of constraints" to linear equations. Plaintiff disagrees and argues that "constraints and equations are different concepts, " because the intrinsic evidence shows that equations can be described as something other than a constraint and a constraint does not need to be represented in an equation. Markman Hr'g Tr. 19:5-6, (D.I. 71 at 7.) Defendant argues that the specification, prosecution history, and the nature of the invention all demonstrate that constructing a system of initial constraints requires building linear equations. (D.I. 74 at 10.) The court agrees.

First, Plaintiff was unable to point to one place in the specification or embodiments that teach nonlinear equations. Instead, Plaintiff points to the prosecution history. The inventor amended claim 1 to overcome a 35 U.S.C. § 102 rejection by deleting the word linear. (2008 Amendment, at J.A. 254.) In explaining the amendment, the inventor cited the Heng and the Marple patents to support his conclusion that "non-linear constraints are implied in the present invention." (2008 Amendment, at J.A. 258), (D.I. 75 at 2.) The Heng specification teaches that "[t]he system of linear constraints is difficult to solve with a non-linear objective function." (Heng patent, at J.A. 540.) Plaintiff believes that although nonlinear constraints are more difficult to enforce, "anyone who talks about any constraints or any system of constraints know they exist." Markman Hr'g Tr. 45:15-16. The Marple patent comes to a similar conclusion. The Marple patent represents constraints both linearly and nonlinearly and teaches that "[s]ince nonlinear constraints are more difficult to enforce in mathematical programming, a linear approximation to [the] constraint is used instead." (Marple et. al, at J.A. 409), Markman Hr'n Tr. 42:22-43:2. Defendant contends that Marple "is still teaching us that in your system of initial constraints you are using linear equations." Markman Hr'g Tr. 46:20-23. The court agrees with Defendant. The inventor's amendment does not indicate that a person having ordinary skill in the art would have used nonlinear constraint equations. In fact, Marple teaches that when faced with a nonlinear constraint equation, the best way to enforce the constraint is to convert the equation from nonlinear to linear.

The specification further shows that the inventor intended that this claimed step be completed using linear equations. The sole description of the sole embodiment of this claimed step, figure 1, Block 002 points to a "well-known" procedure can be found on page 863 of the article "Algorithmic Aspects of One-Dimensional Layout Compaction" by Jurgen Doenhardt and Thomas Lengauer ("the Doenhardt article"). '012 patent, col. 3, ll. 19-23. The article's only representation of constraints is in the form of linear equations and "are generated between the x-coordinates of the layout components." (Doenhardt article, at J.A. 661.) The linear constraint equations form three classes of constraints: (1) constraints that encode contacting rules, (2) constraints that encode design rules, and (3) constraints that encode minimum distance. (Doenhardt article, .at J.A. 661-662.) Therefore, even though Philips instructs against claim constructions that limit the claimed invention to the specification or to one embodiment, here, the use of linear equations to construct a system of constraints as shown in figure 1, Block 002 and its description in the specification, the Doenhardt article, the Heng and Marple patents all exclusively use linear equations. The court finds that a person of ordinary skill in the art would rely on this evidence to achieve the objects of the '012 patent. See Medicines Company v. Mylan, Inc., 853 F.3d 1296, 1309 (Fed. Cir. 2017) (limiting a claim term to an example in a patent that was the only embodiment of the term and the only description that cast light on what the term meant to a person of ordinary skill in the art). The court, therefore, limits this claimed step to linear equations.

Next, Defendant argues-and the court agrees-that coordinate variables are a necessary component of the linear equations used in the "constructing a system of initial constraints" step. The court finds that the claim language, the nature of the invention, and the specification support the inclusion of the phrase ...


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