A patent is not valid (i.e., it is "invalid") if the invention was "obvious" due to methods/devices/stuff that is already known out in the world. That is "prior art." Actually, prior art is an even broader concept.
Here Whyte says the methods/devices/stuff put forward by Hynix in a motion for summary judgment is not manifestly sufficient to find that the Rambus patents (i.e., the ones attacked by that summary judgment motion) are invalid due to prior art.
So the issue of invalidity due to prior art must be decided by a jury.
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