Obviousness

Obviousness Analysis of US Patent 8327051 under 35 U.S.C. § 103

This analysis identifies combinations of prior art references that would render the independent claims of US Patent 8327051 obvious to a person having ordinary skill in the art (PHOSITA) at the time of the invention (priority date: November 20, 2007). The motivation to combine these references generally stems from well-known design objectives such as improving user convenience, enhancing device versatility, offloading processing from host devices, and addressing known limitations in handling protected or compressed media.

Obviousness of Independent Claim 1: Portable Handheld Memory Card

Claim 1: A portable handheld memory card comprising a Universal Serial Bus (USB) port, USB controller circuitry, an input/output (I/O) port, I/O controller circuitry, a memory, and a housing exposing the ports; wherein the USB port and the I/O port are positioned on a same end to allow a same card-insertion direction irrespective of whether a host device comprises a mating USB port or a mating I/O port; and wherein the USB port and the I/O port are positioned such that when the I/O port is electrically connected with the host device, at least one of the first set of pins of the USB port is not electrically connected to the host device, and when the USB port is electrically connected to the host device, at least one of the second set of pins of the I/O port is not electrically connected to the host device.

Combination of Prior Art References:

1. "SanDisk Ultra II SD Plus Cards" (Non-Patent Citation, NPL): This non-patent literature describes existing Secure Digital (SD) Plus cards. The US8327051 patent specification explicitly acknowledges this prior art, stating, "The USB port 102... may include a USB connector such as on a Secure Digital Plus memory card." This reference would disclose a portable handheld memory card comprising:

   • A USB port (with a first set of pins).
   • An I/O port (specifically, an SD port with a second set of pins).
   • A memory in communication with both ports.
   • A housing storing the memory and exposing both the USB and I/O ports.
   • The inherent ability of such a card to interface with either an SD host device or a USB host device.

2. US7287703B2 ([[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.)) and/or US7376773B2 (Samsung Electronics Co., Ltd.): These patents disclose removable memory cards that include both USB and "other" (I/O) controllers, connectors, and methods for operating them. US7287703B2, for example, describes "removable memory cards including USB and other controllers".

   • A PHOSITA would find it obvious to integrate into the SanDisk SD Plus card the necessary on-board controller circuitry for each interface: USB controller circuitry electrically connected with the USB port's pins, and I/O (SD) controller circuitry electrically connected with the SD port's pins. This is a standard design choice for multi-interface storage devices to manage data transfer protocols internally, as taught by these Samsung patents.

Motivation to Combine and Obviousness Reasoning:

A PHOSITA, aiming to create a highly versatile and user-friendly memory card, would be motivated to combine the dual-interface capability of known SD Plus cards with integrated controllers as taught by the Samsung references.

Regarding the specific physical arrangement limitations in Claim 1:

• "positioned on a same end to allow a same card-insertion direction irrespective of whether a host device comprises a mating USB port or a mating I/O port": Given the existence of dual-interface cards, a PHOSITA would be motivated to improve user convenience. While existing SD Plus cards may have implemented USB connectors via different mechanisms (e.g., side-mounted or flip-out), the design goal of simplifying insertion is obvious. Arranging the contacts for both the USB and I/O ports on the same physical end of the card, such that the card can be inserted with a consistent orientation into either a dedicated USB slot or a dedicated I/O (SD) slot (where the slot itself is configured to engage only the relevant contacts), would be an obvious engineering optimization for user experience. This design choice avoids the need for users to reorient the card or use external adapters.
• "when the I/O port is electrically connected with the host device, at least one of the first set of pins of the USB port is not electrically connected to the host device, and when the USB port is electrically connected to the host device, at least one of the second set of pins of the I/O port is not electrically connected to the host device": This condition is an inherent and obvious consequence of designing two distinct physical interfaces (USB and SD) into a single card. If a card with separate physical contact sets for USB and SD is inserted into an SD-only host port, only the SD pins will make electrical contact, leaving the USB pins disengaged from the host. The same applies in reverse for insertion into a USB-only host port. This is a natural result of mating connectors and distinct pin layouts, not an inventive step.

Therefore, the combination of "SanDisk Ultra II SD Plus Cards" and US7287703B2 (or US7376773B2), driven by the obvious desire for improved user convenience and efficient on-card protocol handling, would render Claim 1 obvious.

Obviousness of Independent Claim 9: Method for Data Handling with Memory Card - Type 1

Claim 9: A method performed by a portable handheld card (as described in Claim 1) comprising reading compressed data from the memory; decompressing the compressed data to decompressed data; transmitting the decompressed data on the I/O port; converting the compressed data to first converted data for transmission on the USB port; and transmitting the first converted data on the USB port.

Combination of Prior Art References:

1. The Memory Card of Obvious Claim 1: Provides the base hardware platform with dual interfaces, on-card USB and I/O controllers, and memory.
2. US7433994B2 (Ocz Technology Group, Inc.): This patent describes "On-device data compression to increase speed and capacity of flash memory-based mass storage devices". While focused on compression, the concept of on-device processing of data for storage efficiency and offloading host tasks is clearly taught. For multimedia content, on-device decompression is the complementary function to enable playback on simpler host devices. The US8327051 patent itself states a problem in the background: "accessing compressed data stored on existing memory cards may require that the connected electronic device include decompression capability. For example, playing back a song compressed in the MP3 format that is stored on an existing memory card may require an audio player with MP3 decompression circuitry. Such a player may be expensive and complex."

Motivation to Combine and Obviousness Reasoning:

A PHOSITA would be motivated to integrate data decompression capabilities (as broadly taught by references like US7433994B2 concerning on-device data processing, or general knowledge in multimedia playback) into the versatile dual-interface memory card of Claim 1. This integration directly addresses the known problem of requiring expensive and complex decompression circuitry in host devices, as described in the '051 patent's own background. By performing decompression on the card, the memory card enhances its utility and compatibility with a wider range of simpler playback devices.

• "reading compressed data from the memory": A standard operation for any memory card.
• "decompressing the compressed data to decompressed data": This step, performed on the card, would be an obvious application of known decompression techniques by a PHOSITA, motivated by the desire to alleviate processing burdens on host devices, as highlighted in the background of US8327051.
• "transmitting the decompressed data on the I/O port": This is a standard function of the card's I/O controller once data is prepared.
• "converting the compressed data to first converted data for transmission on the USB port" and "transmitting the first converted data on the USB port": These are standard functions of the card's USB controller and USB port for data transfer, which would be present in the card of Claim 1.

Thus, performing on-card decompression and routing the decompressed data through the I/O port, or routing the original compressed data (or converted version) through the USB port, would be obvious to a PHOSITA combining the multi-interface card with known on-device data processing techniques to enhance device functionality and user experience.

Obviousness of Independent Claim 16: Method for Data Handling with Memory Card - Type 2

Claim 16: A method performed by a portable handheld card (as described in Claim 1) comprising reading data from the memory; determining whether the data is to be transmitted via the USB port or I/O port; and transmitting the data to the host device via the determined port.

Combination of Prior Art References:

1. The Memory Card of Obvious Claim 1: Provides the base hardware platform with dual interfaces, on-card USB and I/O controllers, and memory.
2. US20080071940A1 (Samsung Electronics Co., Ltd.): This patent discloses a "Device of identifying host protocol and smart card including the same". This reference explicitly teaches methods for a card to determine the protocol of a connected host.

Motivation to Combine and Obviousness Reasoning:

A PHOSITA would be motivated to incorporate intelligent port selection logic (as taught by US20080071940A1) into the dual-interface memory card derived from Claim 1. For a device designed to connect to different host interfaces, the ability to automatically detect which interface the host is expecting and route data accordingly is a fundamental and obvious requirement for proper operation and user convenience.

• "reading data from the memory": A standard operation for any memory card.
• "determining whether the data is to be transmitted via the USB port or I/O port": This step is directly taught by US20080071940A1, which describes a mechanism for a card to identify the host protocol. This identification process inherently leads to the determination of which port (USB or I/O) should be used for transmission.
• "transmitting the data to the host device via the determined port": This is a standard function of the selected port's controller, which would be present in the card of Claim 1.

Therefore, the method of reading data, determining the appropriate transmission port based on host detection (as in US20080071940A1), and then transmitting data through that port would be obvious to a PHOSITA when applied to a dual-interface memory card as derived from Claim 1.

Additional Considerations for Dependent Claims:

• Decryption (Claim 2, 10, 17): US20060177064A1 (Micky Holtzman) describes a "Secure memory card with life cycle phases" that can handle secure or DRM-protected content. The '051 patent's background discusses the limitations of DRM-protected content on existing cards. A PHOSITA would be motivated to integrate on-card decryption capabilities into the memory card to enable playback of DRM-protected content independently of the host device, addressing a clear market need and a problem identified in the patent itself.
• Power Management (Claim 4, 11): The inclusion of a power management unit or converting voltage (e.g., from USB Vbus) is a standard engineering practice for any electronic device that receives power from an external source and needs to regulate it for internal components.
• Host Interface Module (Claim 5, 12): The host interface module (or I/O controller circuitry) is explicitly part of Claim 1 and necessary for communicating with the I/O port.
• Control Read/Write Operations (Claim 6, 13): Circuitry configured to control read and write operations to memory is fundamental to any memory device and is universally known.
• Secure Digital (SD) Port (Claim 7, 14, 20): The SD Plus card (NPL) clearly specifies an SD port, which is a common I/O port.
• Flash Memory (Claim 8, 15, 21): The use of Flash memory as the storage medium is a ubiquitous and obvious choice for portable memory cards.
• Parallel Pins, Different Layout (Claim 23, 24, 25): These describe design choices for the physical arrangement of the pins, which would be routine design optimizations for a PHOSITA trying to implement a compact dual-interface card on a single end, as previously discussed for Claim 1.
• Separation of USB and I/O Controller Circuitry/Pins (Claim 26, 27): The non-connection between the specific pins/data lines of one port and the controller of the other port is inherent to having distinct, independently controlled interfaces, as taught by the Samsung multi-controller patents.