The main lesson here is that a “device” is a broad term and may be interpreted as being composed of several constituent components, perhaps even seemingly disparate components (e.g., while the “memory device” could not include the CPU, it could include a memory controller in addition to the memory itself). However, perhaps the most interesting aspect of the opinion is the court’s reliance on estoppel from other, related patents. Citing Omega Eng’g, Inc. v. Raytek Corp., 334 F.3d 1314, 1334 (Fed. Cir. 2003), the court emphasized that “unless otherwise compelled … the same claim term in the same patent or related patents carries the same construed meaning.” The court then went on to construe the “memory device” at issue as encompassing multiple chips based on a claim differentiation argument, in that the single chip embodiment was recited in a dependent claim of a related application. This was just one of several factors taken into account, but something to keep in mind nonetheless.
Background / Facts: The patent under reexamination is part of a family of patents from Rambus covering synchronous memory devices and related technology. Previous memory devices would output all of the data located at a requested address, and that data would be filtered so only the desired data would be passed on to the processor. The patent describes a method where synchronous memory devices output only a specified amount of data in response to a request. The entire anticipation dispute turns on whether the memory device in claim 18 of the patent reads on the memory module in an iAPX Manual prior art reference.
Issue(s): Whether the “memory device” at issue is limited to a single chip (and thus, distinguishes over the prior art) or may encompass multiple chips (and thus, is anticipated by the prior art).
Holding(s): “Memory device” is a broad term which has been used consistently in the patent and in the family of patents related to it to encompass a device having one or more chips. The court agreed with the Board that the specification does not restrict the invention to single chip memory devices and there are no words of manifest exclusion or clear disavowals of multichip devices. There are only preferred embodiments and goals of the invention that Rambus argues are better met by single chip devices, but this is not sufficient for disavowal. The court noted that to the extent Rambus wanted to limit the memory device to a single chip component, it could have expressly done so. It did not, and the court refused to do so here.