Netlist, Inc. v. Micron Technology, Inc.

Netlist, Inc. v. Micron Technology, Inc. The Federal Circuit affirmed the Board’s obviousness determinations as to all challenged claims. The court held that the Board stayed within the petition’s asserted Harris-FBDIMM combination and that substantial evidence supported the Board’s findings on power-through-edge connections, multiple voltage converters, and voltage-monitoring dependent claims. The decision reinforces that the Federal Circuit will read IPR petitions as a whole and will uphold Board obviousness findings where the petition fairly presents a combined-reference theory and expert testimony supplies substantial evidence for implementation details. Affirmed. The court rejected Netlist’s argument that the Board relied on an unpetitioned theory, finding the petition fairly presented Harris plus the FBDIMM standards for the claimed interface coupling power through edge connections. Substantial evidence supported the finding that Harris, implemented in an FBDIMM architecture, taught receiving host-system power through DIMM edge connectors. The court upheld the Board’s finding that a skilled artisan would have used multiple on-module buck converters or converter circuits to generate the voltage rails required by the FBDIMM architecture. For dependent claims requiring voltage monitoring and triggering a write to non-volatile memory, the court held that Amidi’s power-fault disclosure and credited expert testimony supported obviousness, including as to overvoltage conditions. The court also rejected Netlist’s APA challenges, concluding the Board’s claim-by-claim analysis was adequate given the limited disputes Netlist presented below. § 103 waiver / forfeiture non-precedential § 103 waiver / forfeiture non-precedential § 103 non-precedential