Ex Parte 5872952 et al - Page 43




              Appeal No. 2005-2512                                                                                         
              Reexamination Control No. 90/006,431                                                                         

                            A two-step method has been proposed.  In the first step, PowerMill                             
                     is applied to find currents flowing into the transistor blocks.  PowerMill                            
                     assumes constant voltages at power buses during this step.  Step two                                  
                     simulates the power-bus network, modeled as an RLC network and driven                                 
                     by current sources representing the simulated currents in step one.                                   
                     Based on this scheme, a power-net reliability simulation package is being                             
                     developed and tested.  It includes a layout extractor to model the power                              
                     net in terms of the extracted RLC parasitics, a power-net simulator to                                
                     simulate the RLC network driven by current sources estimated from                                     
                     PowerMill simulation on the transistor blocks, and a layout display tool to                           
                     highlight the excessive current densities and voltage drops in the power                              
                     net.  Figure 2 shows the voltage drop distribution in the power net.                                  
                     Although the actual display separates voltage levels by color, they can be                            
                     distinguished here by shades of gray.                                                                 
              Deng at 7, cols. 1, 2 (footnote omitted).  The image depicted in Figure 2 at page 7                          
              closely resembles an image in the RailMill ChipViewer display depicted by Figure 14B of                      
              the ‘952 patent, more particularly the image in chip layout display window 1406 of the                       
              display.  Deng, like Tiwary, makes no mention of RailMill.                                                   
                     Ho’s only discussion of the content of Tiwary and Deng is as follows:                                 
                            6.  . . . The Tiwary document describes work of Epic Design                                    
                     Technology.  I am informed that the Examiner has referred to page 86,                                 
                     where images of a graphical user interface are shown.  Because I have                                 
                     never seen this article before, and was not consulted in the preparation of                           
                     the article, I do not know the origin of the images on page 86.  However,                             
                     the images on page 86 appear to have been generated using ChipViewer.                                 
                                                                                                                          
                            7.  . . . The [Deng] article describes the PowerMill product of Epic                           
                     Design Technology.   I am informed that the Examiner has referred to                                  
                     Figure 2, on page 7 of the article.  Because I have never seen this article                           
                     before, and was not consulted in the preparation of the article, I do not                             
                     know the origin of the image in Figure 2.  However, the image in Figure 2                             
                     appears to have been generated using ChipViewer.                                                      



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