Short Summary
Micron’s request for Director Review of the PTAB’s decision on a 3‑D memory patent was denied. The Board’s findings that the petitioner’s proposed modifications were inoperable and lacked motivation were upheld.
Detailed Summary
In IPR2024‑00791, Micron Technology challenged U.S. Patent No. 10,937,806 covering a through‑array contact (TAC) for three‑dimensional memory devices owned by Yangtze Memory Technologies. The petitioner sought Director Review, arguing errors on Grounds 2 and 3, including alleged requirements for bodily incorporation and improper handling of new reply arguments. The patent owner’s authorized response demonstrated that the Board correctly rejected the grounds, finding that the proposed lateral replication of Toyama’s layout would render the device inoperable, that no motivation existed for a skilled artisan, and that the Board properly considered all arguments without requiring anticipation evidence. Consequently, the Board’s decision stands and the Director Review request is denied.
Practitioner Note
This case demonstrates the evidentiary and procedural standards applied in patent matters before local courts. Understanding the court's reasoning in Micron Technology, Inc. et al. vs YANGTZE MEMORY TECHNOLOGIES COMPANY, LTD. is valuable context for structuring arguments or assessing risk in similar proceedings.
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