Free Claim Construction Opening Brief - District Court of Delaware - Delaware

Case 1:04-cv-00418-SLR

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE SEAGATE TECHNOLOGY LLC, Plaintiff, v. CORNICE, INC. Defendant. C.A. No. 04-418 (SLR)

PLAINTIFF SEAGATE TECHNOLOGY LLC'S TECHNOLOGY OVERVIEW Date: November 18, 2005 FISH & RICHARDSON P.C. Timothy Devlin (#4241) 919 N. Market Street, Suite 1100 Wilmington, DE 19899-1114 Tel: (302) 652-5070 Roger S. Borovoy David M. Barkan 500 Arguello Street, Suite 500 Redwood City, CA 94063-1526 Tel: (650) 839-5070 Ruffin B. Cordell Brian R. Nester Timothy W. Riffe Christian A. Chu 1425 K Street NW, Suite 1100 Washington, D.C. 20005 Tel: (202) 783-5070 Edmond R. Bannon Lewis E. Hudnell, III Citigroup Center 153 East 53rd Street, 52nd Floor New York, NY 10022-4611 Tel: (212) 765-5070 Attorneys for Plaintiff SEAGATE TECHNOLOGY LLC

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Plaintiff Seagate Technology LLC ("Seagate") provides this brief technology overview to assist the Court in construing the seven patents in suit. In addition to this overview, Seagate files four claim construction briefs grouped by the following U.S. Patent Nos.: Brief 1: Brief 2: Brief 3: Brief 4: 6,146,754 ("the '754 patent"); 5,600,506 ("the '506 patent"); 5,452,159 ("the '159 patent"); and 6,744,606 (the `606 patent); 5,596,461 ("the '461 patent"); 6,324,054 ("the '054 patent"); 6,545,845 ("the '845 patent").

The chart below identifies each patent-in-suit and its associated technology. U.S. Patent Number '754 patent `606 patent '845 patent '159 patent '506 patent '461 patent '054 patent Associated Technology Magnetic disc media Dual-plane Actuator Retaining actuator to bearing cartridge Latch holding actuator in place Servo system Housing of disc drive Shock absorber for exterior of drive

These technologies are discussed seriatim below. I. TECHNOLOGY OVERVIEW The technologies at issue here relate to hard disc drives. Disc drives are today's primary medium for storing electronic information, and are indispensable components of desktop and laptop computers, network servers, and consumer electronics (such as Tivo® digital video recorders and iPod® digital players). The disc drive performs a central function: it stores data in a relatively permanent form. To perform this storage function, every disc drive has a number of components in common, as illustrated below:

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Voice Coil Assembly

Bearing Cartridge

Latch

Actuator Arm Disc(s) Spindle Motor

Flexure

Read/Write Head PCB (on underside of housing)

Housing

Fig. 1: Disc Drive with cover removed At the core of a disc drive are the round flat discs depicted above. Each disc is coated with various chemical layers to create the magnetic recording " media." The composition and properties of this media are the central issue of the `754 patent. The media' s role in the disc drive is to store data in the form of magnetic patterns. Mounted onto a central spindle (shown above in Fig. 1 and below in Fig. 2), the discs rotate at high speed, driven by a spindle motor connected to the spindle. As the spindle motor rotates the discs, " heads" (also referred to as " transducers" ), which may be mounted onto " flexures," either record information onto the disc or read information from it. The flexures are in turn connected to " actuator arms" which are controlled by an " actuator."

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Actuator Bearing Cartridge

Flexure Spindle Media

Discs Fig. 2: Side view of hard disc drive Transducer/ Head The actuator is central to three of the patents-in-suit: the `606, `845, and `159 patents. The actuator is the component that moves the heads/transducers over the disc to read or write data to/from the disc. The motor that rotates the actuator is often referred to as a voice coil motor, and the voice coil rotates the actuator around a post ­ moving the heads/transducers from the inner to outer diameter of the disc as needed. A bearing cartridge allows the actuator to pivot smoothly around the post. The `606 patent discloses a novel a single-armed actuator in which the arm (or arm support) is placed in a different plane or height than the voice coil support portion of the actuator. The `845 patent discloses a novel retaining clip that fastens the actuator arm and bearing cartridge. In addition to these components, every modern disc drive also includes a way to " park" the actuator' s read/write head ­ either through a special landing zone near the center of the disc or a load-unload ramp fixed at the outer edge of the disc. This is important to ensure that when a drive is dropped, the likelihood of physical contact between the head/transducer and the disc is greatly reduced. The `159 patent discloses a magnetic latch that fixes the actuator' s head/transducer to prevent movement of and damage caused by the head contacting the fragile disc. 3

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To properly read and write data to and from the disc, these various components must work together to position the heads at the correct location on the surface of the disc. Data is written to circular " data tracks" that are arranged concentrically on the surface of the disc (like grooves on a record album, but arranged as concentric circles instead of one continuous spiral). The read/write head must be positioned over the proper data track of the disc to a high degree of accuracy. If the read/write head is misaligned from the center of a " data track," it becomes difficult to write or read data reliably. To ensure the required accuracy, disc drive designers have devised ways to position the heads/transducer over the proper data track. This so-called " servo system" in the disc drive determines the position of the heads using special magnetic patterns ­ called " servo patterns" ­ written periodically on the surface of the disc. In simplified terms, each servo pattern is analogous to a ruler placed on the disc, extending radially outward like the spoke of a wheel. As the disc spins, the transducer " reads" the servo pattern and feeds the information back to the actuator control logic system. The system determines where the transducer is located, and in turn guides the actuator to the correct data track on the disc. This " feedback-loop" process occurs continuously at very high speed within the disc drive, and allows for the quick and accurate reading and writing of data that have made disc drives an essential component of our daily lives. The `506 patent relates to this servo pattern and servo system. The `461 and `054 patents address the exterior of the drive. As depicted in Figure 3 below, disc drives generally include a housing that is the outer shell of the drive designed to protect the internal components. The housing generally includes a base member and a cover element. Printed circuit boards (" PCB" ), which contain the electrical circuits used to control the drive, are also placed on the exterior of the drive. The '461 patent relates to a novel arrangement of the PCB in relation to the housing elements that results in a space efficient housing for the disc drive.

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Housing

Fig. 3: Exterior of a Seagate hard-disc drive

Today, disc drives are used in a number of portable consumer electronic products, such as the Apple iPod®. When a consumer drops the iPod®, the disc drive is subjected to various shock and vibration that could damage the internal components of the drive. In order to minimize or eliminate such damage, a shock absorbing material may be used on the exterior of the drive to absorb a portion of the shock. The '054 patent discloses and claims a novel shock absorber for the exterior of the drive. In the above discussion, Seagate attempts to simplify the technology at issue for purposes of claim construction. Disc drive design, however, is particularly complicated and requires extensive, multi-faceted engineering. Developing, designing, and producing innovative disc drives and drive components are inherently challenging, requiring expertise in physics, tribology, aerodynamics, fluid mechanics, information theory, magnetics, process technology, and numerous other technical disciplines. Seagate will not delve into the complex science behind each, and instead focuses on only the components at issue here. Suffice it to say, however, the design of drives crosses many engineering disciplines and components are highly interdependent for proper functionality. For example, during fiscal year 2005 alone, Seagate spent approximately $645 million in R&D and product development. These features and technology are described in greater detail in Seagate' s co-filed claim construction briefs.

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Date: November 18, 2005

FISH & RICHARDSON P.C.

By: /s/ Timothy Devlin Timothy Devlin (#4241) 919 N. Market Street, Suite 1100 Wilmington, DE 19899-1114 Roger S. Borovoy David M. Barkan D. Austin Horowitz Desa L. Burton 500 Arguello Street Redwood City, CA 94063-1526 Ruffin B. Cordell Brian R. Nester Timothy W. Riffe Christian A. Chu 1425 K Street NW, Suite 1100 Washington, D.C. 20005 Edmond Bannon Lewis E. Hudnell, III Citigroup Center ­ 52nd Floor 153 East 53rd Street New York, NY 10022-4611 Attorneys for Plaintiff SEAGATE TECHNOLOGY LLC

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CERTIFICATE OF SERVICE I hereby certify that on November 18, 2005, I electronically filed PLAINTIFF SEAGATE TECHNOLOGY LLC'S TECHNOLOGY OVERVIEW with the Clerk of Court using CM/ECF which will send notification of such filing(s) to the following: Jack B. Blumenfeld, Esquire MORRIS NICHOLS ARSHT & TUNNELL 1201 N. Market Street P.O. Box 1347 Wilmington, DE 19899-1347 Attorneys for Defendant Cornice, Inc.

I hereby certify that on November 18, 2005, I have mailed by Federal Express Service, the document(s) to the following non-registered participants: Mathew D. Powers Jason D. Kipnis WEIL, GOTSHAL & MANGES LLP 201 Redwood Shores Parkway Redwood Shores, CA 94065 Russell Wheatley WEIL, GOTSHAL & MANGES LLP 700 Louisiana, Suite 1600 Houston, TX 77002 Alan J. Weinschel David C. Radulescu Arlene Hahn WEIL, GOTSHAL & MANGES LLP 767 Fifth Avenue New York, NY 10153 Attorneys for Defendant Cornice, Inc.

Attorneys for Defendant Cornice, Inc.

Attorneys for Defendant Cornice, Inc.

/s/ Timothy Devlin Timothy Devlin

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