Short Summary
The PTAB denied Micron Technology's request for rehearing after institution was previously denied on claims of the NAND Flash patent 11,600,342. The Board found that Petitioner failed to provide objective evidence demonstrating how prior art references inherently teach fast charge removal.
Detailed Summary
In this Institution Decision, the Patent Trial and Appeal Board denied Micron Technology's request for rehearing regarding the denial of institution of IPR against U.S. Patent No. 11,600,342 B2. The Petitioner argued that the Board misconstrued its obviousness arguments as inherency claims, asserting that voltage differentials in Seo and Nam inherently remove fast charges when combined with Choi's teachings on charge-trap memory. However, the Board maintained that the Petitioner failed to meet its burden of proof by not providing sufficient objective evidence or explanation for how a Person of Ordinary Skill in the Art would understand this inherent property.
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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