Case 3:14-cv-02235-DMS-BLM Document 524 Filed 10/26/18 PageID.25347 Page 1 of 168
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` UNITED STATES DISTRICT COURT
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` SOUTHERN DISTRICT OF CALIFORNIA
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` BEFORE HONORABLE DANA M. SABRAW, JUDGE PRESIDING
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` ________________________________
` )
`WI-LAN INC.,
` )
`
` ) CASE NO. 14CV2235-DMS
` PLAINTIFF, ) 14CV1507-DMS
` )
` )
`VS. )
` ) SAN DIEGO, CALIFORNIA
`APPLE INC., ) TUESDAY JULY 31, 2018
`
` ) 9:00 A.M. CALENDAR
` DEFENDANT. )
` )
`---------------------------------)
`AND ALL RELATED )
`COUNTERCLAIMS. )
`
`
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`
`
`
` REPORTER'S TRANSCRIPT OF PROCEEDINGS
`
` JURY TRIAL/DAY SIX
`
` VOLUME VI-A
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`
`
`REPORTED BY: LEE ANN PENCE,
` OFFICIAL COURT REPORTER
` UNITED STATES COURTHOUSE
` 333 WEST BROADWAY, ROOM 1393
` SAN DIEGO, CALIFORNIA 92101
`
`
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` UNITED STATES DISTRICT COURT
`
` SOUTHERN DISTRICT OF CALIFORNIA
`
`
` BEFORE HONORABLE DANA M. SABRAW, JUDGE PRESIDING
`
` ________________________________
` )
`WI-LAN INC.,
` )
`
` ) CASE NO. 14CV2235-DMS
` PLAINTIFF, ) 14CV1507-DMS
` )
` )
`VS. )
` ) SAN DIEGO, CALIFORNIA
`APPLE INC., ) TUESDAY JULY 31, 2018
`
` ) 9:00 A.M. CALENDAR
` DEFENDANT. )
` )
`---------------------------------)
`AND ALL RELATED )
`COUNTERCLAIMS. )
`
`
`
`
`
`
`
` REPORTER'S TRANSCRIPT OF PROCEEDINGS
`
` JURY TRIAL/DAY SIX
`
` VOLUME VI-A
`
`
`
`REPORTED BY: LEE ANN PENCE,
` OFFICIAL COURT REPORTER
` UNITED STATES COURTHOUSE
` 333 WEST BROADWAY, ROOM 1393
` SAN DIEGO, CALIFORNIA 92101
`
`
`
`Case 3:14-cv-02235-DMS-BLM Document 524 Filed 10/26/18 PageID.25348 Page 2 of 168
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`COUNSEL APPEARING:
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`FOR PLAINTIFF:
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`JOHN ALLCOCK, ESQ.
`SEAN C. CUNNINGHAM,ESQ.
`ERIN PAIGE GIBSON,ESQ.
`JACOB ANDERSON, ESQ.
`TIFFANY CAROL MILLER, ESQ.
`DLA PIPER
`401 B STREET SUITE 1700
`
` SAN DIEGO, CALIFORNIA 92101
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`
`FOR DEFENDANT: ROBERT A. COTE, ESQ.
`JONATHAN R. YIM, ESQ.
`KEVIN R. SCHUBERT, ESQ.
`CHRISTOPHER MCNETT, ESQ.
`BRETT E. COOPER, ESQ.
`MCKOOL SMITH
`
`ONE BRYANT PARK 47TH FLOOR
`
` NEW YORK, NEW YORK 10036
`
`
`
`MIKE MCKOOL, JR., ESQ.
`ASHLEY NICOLE MOORE, ESQ.
`MCKOOL SMITH
`300 CRESENT COURT SUITE 1500
`DALLAS, TEXAS 75201
`
`
`
`
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`
`
`
`
`WARREN HENRY LIPSCHITZ, ESQ.
`MCKOOL SMITH
`1719 WHITTIER AVENUE
`DALLAS, TEXAS 75218
`
`STEVEN J. POLLINGER, ESQ.
`MCKOOL SMITH
`300 WEST 6TH STREET SUITE 1700
`DALLAS, TEXAS 75218
`
`
`
`Case 3:14-cv-02235-DMS-BLM Document 524 Filed 10/26/18 PageID.25349 Page 3 of 168
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`SAN DIEGO, CALIFORNIA - TUESDAY, JULY 31, 2018 - 9:00 A.M.
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`* * *
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`THE CLERK: NO. 1 ON CALENDAR, CASE NO. 14CV2235,
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`APPLE VERSUS WI-LAN; ON FOR JURY TRIAL.
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`THE COURT: GOOD MORNING, LADIES AND GENTLEMEN.
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`WE HAVE ALL JURORS PRESENT, COUNSEL AND PARTIES.
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`WE ARE GOING TO PICK UP WHERE WE LEFT OFF YESTERDAY
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`WITH PROFESSOR FUJA.
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`GOOD MORNING.
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`THE WITNESS: GOOD MORNING.
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`THE COURT: SIR, I WOULD REMIND YOU THAT YOU REMAIN
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`UNDER OATH FROM YESTERDAY'S PROCEEDINGS. THANK YOU.
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`THE WITNESS: YES.
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`THE COURT: MR. CUNNINGHAM.
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`MR. CUNNINGHAM: GOOD MORNING, YOUR HONOR. THANK
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`YOU.
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`DIRECT EXAMINATION(RESUMED)
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`Q. (MR. CUNNINGHAM) : AND GOOD MORNING, DR. FUJA.
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`A.
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`Q.
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`A.
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`Q.
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`GOOD MORNING.
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`HOW ARE YOU?
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`I AM FINE. THANK YOU.
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`FOR THOSE OF US WHO HAVE SLEPT, PRESENT COMPANY
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`EXCLUDED, COULD YOU REMIND THE JURY WHY YOU ARE HERE?
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`A.
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`I AM HERE TO PRESENT MY OPINIONS WITH REGARD TO WIRELESS
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`COMMUNICATIONS. IN PARTICULAR WHETHER THE '757 IS INFRINGED
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`BY THE ACCUSED APPLE PRODUCTS, AND TO PRESENT POTENTIAL
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`ALTERNATIVES TO THE ACCUSED VOLTE PRODUCT.
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`Q.
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`THANK YOU, SIR.
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`I WANT TO GET RIGHT TO YOUR OPINIONS ABOUT CLAIM 1 OF
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`THE '757 PATENT. HOW DID YOU GO ABOUT CONDUCTING YOUR
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`ANALYSIS OF THAT CLAIM?
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`A.
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`WELL, IT IS A TWO-STEP PROCEDURE. THE FIRST THING YOU
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`HAVE TO DO IS FIGURE OUT EXACTLY WHAT THE CLAIM SAYS. AND THE
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`COURT DEFINED SOME TERMS, THEY CALL THAT A COURT CONSTRUCTION.
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`THE OTHER TERMS THAT THE COURT DOESN'T CONSTRUE WE ARE
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`SUPPOSED TO APPLY HOW THE TERM WOULD BE UNDERSTOOD BY A PERSON
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`OF ORDINARY SKILL IN THE ART.
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`SO ONCE WE HAVE GOT THE CLAIM WELL UNDERSTOOD AND
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`DEFINED THEN MY JOB IS TO LOOK AT EACH OF THE LIMITATIONS IN
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`THE CLAIM AND SO SEE IF THEY ARE PRESENT IN THE ACCUSED
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`PRODUCT.
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`Q.
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`THANK YOU. AND DID YOU DETERMINE WHO A PERSON OF
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`ORDINARY SKILL IN THE ART WOULD BE FOR THIS PATENT?
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`A.
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`I DID. AGAIN, A PERSON OF ORDINARY SKILL IN THE ART IS
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`SOMEBODY WHO HAS ORDINARY KNOWLEDGE OF THE TECHNOLOGY DURING
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`THE RELEVANT TIME PERIOD.
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`I THINK I MAY HAVE PUT IT ON A SLIDE.
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`Q.
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`YEAH.
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`MR. CUNNINGHAM: LET'S HAVE SLIDE 12, PLEASE.
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`THE WITNESS: A PERSON OF ORDINARY SKILL IN THE ART,
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`IN MY OPINION, WOULD BE SOMEBODY WHO IN DECEMBER OF 2000 HAS
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`AT LEAST A BACHELOR'S DEGREE IN EITHER ELECTRICAL ENGINEERING
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`OR COMPUTER ENGINEERING OR COMPUTER SCIENCE, AND A COUPLE OF
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`YEARS EXPERIENCE IN WIRELESS NETWORKS.
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`Q.
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`I SEE. JUST, AGAIN, WHY IS THAT -- WHY IS THIS PERSON
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`IMPORTANT TO KNOW?
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`A.
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`BECAUSE WHEN WE LOOK AT THE CLAIMS WE ARE SUPPOSED TO
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`INTERPRET THE CLAIMS THROUGH THE EYES OF A PERSON OF ORDINARY
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`SKILL IN THE ART.
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`Q.
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`NOW, WE HAVE OBVIOUSLY -- WE DISCUSSED THIS YESTERDAY,
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`BUT IS DECEMBER 2000 THE RIGHT TIME PERIOD TO BE LOOKING AT?
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`A.
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`Q.
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`A.
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`DECEMBER 2000, THAT'S CORRECT.
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`WHY IS THAT?
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`BECAUSE, AGAIN, THAT'S THE FILING DATE FOR THE ORIGINAL
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`APPLICATION OF THE PARENT PATENT. ALSO, WI-LAN HAS INDICATED
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`THAT THAT WAS THE DATE OF INVENTION.
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`Q.
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`AND BACK IN DECEMBER 2000, WOULD YOU CONSIDER YOURSELF
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`TO HAVE BEEN A PERSON OF ORDINARY SKILL IN THE ART?
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`A.
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`Q.
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`I CERTAINLY HAD THESE CREDENTIALS, YES.
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`ALL RIGHT.
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`MR. CUNNINGHAM: LET'S HAVE PX 5, WHICH IS THE '757
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`PATENT. AND I WANT TO PUT UP CLAIM 1, PLEASE.
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`Q. (MR. CUNNINGHAM) : SIR, IS THIS CLAIM 1 OF THE '757
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`PATENT?
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`A.
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`YES, IT IS.
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`
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`Q.
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`A.
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`Q.
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`IS THIS THE ONLY CLAIM THAT IS AT ISSUE IN THIS PATENT?
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`YES, IT IS. THIS IS THE ONLY ASSERTED CLAIM.
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`IN YOUR EXPERT OPINION DOES -- DO THE ACCUSED IPHONES
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`USE OR INFRINGE THIS CLAIM?
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`A.
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`Q.
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`NO, THEY DO NOT.
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`WHICH LIMITATIONS OF CLAIM 1 ARE MISSING FROM THE
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`IPHONES?
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`A.
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`THE SUBSCRIBER STATION LIMITATION. IT IS ACTUALLY IN
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`FOUR PLACES IN THE PATENT.
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`Q.
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`SO WE HAVE GOT IT, OBVIOUSLY, IN THE FIRST LINE THERE.
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`WHERE IS THE NEXT PLACE THAT APPEARS?
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`A.
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`IF YOU GO DOWN TO THE NEXT SECTION, THE VERY END OF IT
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`SAYS, SHARED WITH OTHER SUBSCRIBER STATIONS.
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`MR. CUNNINGHAM: LET'S HIGHLIGHT THAT.
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`Q. (MR. CUNNINGHAM) : YOU SAID FOUR, RIGHT?
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`A.
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`Q.
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`I BELIEVE SO, SO I GOT TO FIND THE --
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`I THINK IT IS DOWN IN THE IDENTIFY A DL SUB-FRAME MAP
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`SECTION.
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`A.
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`YEAH. SELECTED FOR THE SUBSCRIBER STATION. AND THEN
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`THE VERY LAST LINE IN THE CLAIM, SUBSCRIBER STATION ON THE
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`DOWNLINK.
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`Q.
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`A.
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`Q.
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`SO AT LINE 66 AND 7?
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`IN THAT LIMITATION, EXACTLY.
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`SO THOSE ARE THE FOUR PLACES WHERE THAT TERM APPEARS IN
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`THE PATENT CLAIM?
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`A.
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`Q.
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`THAT'S CORRECT.
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`NOW, DOES SUBSCRIBER STATION, ACCORDING TO THE COURT'S
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`CLAIM CONSTRUCTION, MEAN THE SAME THING EACH TIME IT IS USED
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`IN THIS CLAIM?
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`A.
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`Q.
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`THAT'S MY UNDERSTANDING, YES.
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`IS THE SUBSCRIBER STATION TERM SIMILAR TO THE SUBSCRIBER
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`UNIT TERM THAT WE HEARD DR. BUEHRER TALK ABOUT YESTERDAY?
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`A.
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`IT IS THE SAME TERM. THEY CALL IT A SUBSCRIBER STATION
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`HERE AS OPPOSED TO A SUBSCRIBER UNIT. BUT THEY HAVE BOTH BEEN
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`CONSTRUCTED BY THE COURT IN THE SAME WAY.
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`MR. CUNNINGHAM: OKAY. LET'S HAVE SLIDE 13.
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`Q. (MR. CUNNINGHAM) : THIS IS THE COURT'S CLAIM
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`CONSTRUCTION. DID YOU RELY ON THIS CLAIM CONSTRUCTION IN
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`RENDERING YOUR OPINIONS?
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`A.
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`Q.
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`YES, I DID. I USED THESE CLAIM CONSTRUCTIONS.
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`AND WHAT DID YOU CONCLUDE ABOUT WHETHER THE IPHONES HAVE
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`THIS SUBSCRIBER STATION?
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`A.
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`Q.
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`A.
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`THEY DO NOT.
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`WHY NOT?
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`BECAUSE THEY DON'T ALLOCATE THE BANDWIDTH ACROSS ITS
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`USER CONNECTIONS IN THE WAY THAT THE COURT HAS DEFINED
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`CONNECTIONS; WHICH THE COURT WAS VERY SPECIFIC, CONNECTIONS
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`BETWEEN THE SUBSCRIBER UNIT AND ITS USERS.
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`Q.
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`DID YOU ALSO RELY ON THAT CONSTRUCTION OF CONNECTIONS IN
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`RENDERING YOUR OPINIONS?
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`
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`A.
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`Q.
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`YES, I DID.
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`SO, LET ME -- I AM GOING TO GO OUT TO THIS BOARD THAT WE
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`TALKED A LOT ABOUT.
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`YOU HAVE SEEN THIS?
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`MANY TIMES.
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`DO YOU BELIEVE THIS TO BE AN ACCURATE DIAGRAM OF THE
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`A.
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`Q.
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`INNER WORKINGS OF THE APPLICATION PROCESSOR AND THE BASEBAND
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`PROCESSOR, AT LEAST AS FAR AS WE ARE CONCERNED FOR THIS TRIAL?
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`A.
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`Q.
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`YES, IT IS.
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`SO TO ORIENT US AGAIN. WE HAVE THE APPLICATION
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`PROCESSOR UP HERE.
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`A.
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`Q.
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`A.
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`Q.
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`A.
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`CORRECT.
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`AND THE BASEBAND PROCESSOR DOWN HERE IN PURPLE.
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`RIGHT.
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`AND THESE TWO ARE WHAT?
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`THEY ARE BUSES. THEY ARE BASICALLY -- YOU CAN THINK OF
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`THEM AS JUST WIRES OVER WHICH DATA FLOWS.
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`Q.
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`NOW, ARE THESE BUSES THE CONNECTIONS AS THE COURT HAS
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`CONSTRUED THEM?
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`A.
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`Q.
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`A.
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`NO, THEY ARE NOT.
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`WHAT ARE THE CONNECTIONS?
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`THE CONNECTIONS ARE, THE COURT TELLS US, BETWEEN THE
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`SUBSCRIBER UNIT AND ITS USERS.
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`NOW, DR. MADISETTI HAS IDENTIFIED THE BASEBAND PROCESSOR
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`AS THE SUBSCRIBER UNIT, SO THAT'S THE THING IN PURPLE. AND
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`THEN THE USERS ARE THE APPS, FACETIME, THE MAIL APP, ET
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`CETERA. SO IT IS CONNECTIONS BETWEEN THE APPS AND THE
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`BASEBAND PROCESSOR.
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`Q.
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`OKAY. SO TELL ME -- YOU SAID BETWEEN THE APPS AND THE
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`BASEBAND PROCESSOR. I WANT TO DRAW A LINE TO GET THE
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`CONNECTIONS THAT YOU READ FROM THE COURT'S CONSTRUCTION. IS
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`THE LINE HERE?
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`A.
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`Q.
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`A.
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`IT IS STARTS AT -- YES. IT STARTS AT THE APP.
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`OKAY. WHERE DOES IT END?
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`IT ENDS AT THE BASEBAND PROCESSOR, WHICH IS WHAT HAS
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`BEEN IDENTIFIED AS THE SUBSCRIBER UNIT. SO AS SOON AS IT HITS
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`THAT BASEBAND PROCESSOR THAT'S THE OTHER END OF THE
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`CONNECTION.
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`Q.
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`I AM PUTTING A LINE ON THE -- BASICALLY ON THE PURPLE
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`LINE WHERE THE EDGE OF THE BASEBAND PROCESSOR IS. AM I DOING
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`THAT RIGHT?
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`A.
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`Q.
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`A.
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`Q.
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`I THINK THAT IS THE PLACE TO PUT IT, YES.
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`HAVE I DRAWN THAT LINE CORRECTLY?
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`YES, YOU HAVE.
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`AND SO I HAVE DRAWN SOME ARROWS BETWEEN WHAT I DREW AT
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`THE TOP AND WHAT I DREW AT THE BOTTOM.
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`SIR, ACCORDING TO THE COURT'S CLAIM CONSTRUCTION, IS
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`THAT WHERE THE CONNECTIONS ARE --
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`A.
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`Q.
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`YES.
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`-- THAT THE COURT DEFINED?
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`
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`A.
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`THAT'S CORRECT. I MEAN, YOU START AT ONE OF THE APPS
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`AND YOU FLOW THROUGH WHICHEVER BUS THE DATA IS ROUTED. AND AS
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`SOON AS YOU HIT THE BASEBAND PROCESSOR, THAT'S THE OTHER END
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`OF THE CONNECTION.
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`Q.
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`ARE THERE ANY OTHER CONNECTIONS THAT YOU FOUND IN THE
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`IPHONE THAT WOULD MEET THE COURT'S CONSTRUCTION?
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`A.
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`Q.
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`NONE THAT WOULD MEET THE COURT'S CONSTRUCTION, NO.
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`SO ARE THOSE CONNECTIONS -- THE ONES I HAVE DRAWN WITH
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`THE BLUE ARROWS -- ARE THOSE THE ONES WE NEED TO FOCUS ON?
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`A.
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`THE COURT SAID THE CONNECTIONS ARE BETWEEN THE
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`SUBSCRIBER UNIT AND IT USERS. THE SUBSCRIBER UNIT IS THE
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`BASEBAND PROCESSOR, THE USERS ARE THE APPS. I THINK THOSE ARE
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`THE ONLY ONES THAT MEET THAT CONSTRUCTION.
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`Q.
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`AND I GUESS I DREW AN ARROW IN THE MIDDLE. IS THERE A
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`THIRD CONNECTION THERE, OR DO I NEED TO SCRATCH THAT OFF?
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`A.
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`THAT PROBABLY DOESN'T BELONG THERE. EVERYTHING GOES
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`OVER ONE OF THOSE TWO BUSES.
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`Q.
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`ALL RIGHT. NOW, IS, IN YOUR EXPERT OPINION, THERE ANY
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`ALLOCATION OF BANDWIDTH ACROSS THE USER CONNECTIONS AS YOU
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`HAVE -- AS I HAVE DRAWN THEM ON THAT BOARD?
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`A.
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`Q.
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`NO.
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`WHERE DOES ALLOCATION OF BANDWIDTH OCCUR IN THE IPHONE
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`IF IT IS NOT AT THOSE CONNECTIONS?
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`A.
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`IT IS DOWN THERE, ACROSS THE LOGICAL CHANNELS. WE SHOW
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`THREE OF THEM. THERE COULD BE MORE, THERE COULD BE LESS. BUT
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`IT IS VERY CLEAR THAT THE LTE STANDARD REQUIRES THAT THE
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`ALLOCATION BE DONE ACROSS THE LOGICAL CHANNELS.
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`Q.
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`YOU SAY THE LTE STANDARD REQUIRES ALLOCATION BE DONE
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`ACROSS THESE LOGICAL CHANNELS. WHY DO YOU SAY THAT?
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`A.
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`Q.
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`BECAUSE THAT IS WHAT THE LTE STANDARD SAYS.
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`NOW, DID I CORRECTLY DRAW THIS LINE POINTING AT THE
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`LOGICAL CHANNELS?
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`A.
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`Q.
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`YES, YOU DID.
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`NOW, A FEW QUESTIONS ABOUT THOSE LOGICAL CHANNELS, AND
`
`THEN I AM GOING TO SHOW YOU A DOCUMENT.
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`CAN ONE OF THOSE LOGICAL CHANNELS CONTAIN DATA FROM MORE
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`THAN ONE OF THE APPLICATIONS AT THE TOP?
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`A.
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`Q.
`
`YES.
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`CAN ONE LOGICAL CHANNEL CONTAIN DATA THAT TRAVELED OVER
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`MORE THAN ONE OF THOSE TWO BUSES?
`
`A.
`
`YES. YOU HAVE HEARD MENTION OF DTMF DATA. THAT DATA
`
`ORIGINATES IN THE PHONE APP. THE DTMF DATA GOES OVER THE PCIE
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`BUS, THE VOICE SAMPLES GO OVER THE I2S BUS, BUT THEY BOTH END
`
`UP IN LOGICAL CHANNEL 3.
`
`Q.
`
`DO THESE LOGICAL CHANNELS -- WE HAD SOME TESTIMONY ON
`
`THIS YESTERDAY.
`
`DO THESE LOGICAL CHANNELS KNOW WHICH CONNECTION THE DATA
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`CAME ACROSS?
`
`A.
`
`NO. AT THAT POINT THE DATA HAS BEEN CIPHERED, IT HAS
`
`BEEN PACKETIZED. ALL THE LOGICAL CHANNEL KNOW IS PACKAGES OF
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`
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`DATA. WHAT ARE -- EXCUSE ME -- PACKAGE IN LOGICAL CHANNELS,
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`YES.
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`Q.
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`A.
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`Q.
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`A.
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`YOU SAID CIPHERED.
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`YES.
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`WHAT DOES THAT MEAN?
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`CIPHER, ENCRYPTION, WE WILL SEE IN A MINUTE. THAT
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`HAPPENS A LITTLE BIT FURTHER UP IN THE STACK. BUT THAT IS
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`BASICALLY HIDING THE DATA, MAKING IT HARD TO EXTRACT.
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`Q.
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`WELL, IS ALLOCATING BANDWIDTH TO THESE LOGICAL CHANNELS
`
`JUST THE SAME AS ALLOCATING BANDWIDTH TO THESE CONNECTIONS?
`
`A.
`
`NO. IT IS -- AGAIN, IT IS VERY DIFFERENT. YOU KNOW,
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`LOGICAL CHANNEL 1 MIGHT CONTAIN PROCESSED DATA FROM THREE OR
`
`FOUR OR FIVE APPS. BANDWIDTH IS THEN ALLOCATED ACROSS LOGICAL
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`CHANNEL 1. THEY NEVER SAY, HERE IS 5 PERCENT OF THE BANDWIDTH
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`TO THE FACEBOOK CONNECTION, HERE IS 5 PERCENT OF THE BANDWIDTH
`
`TO THE MAIL CONNECTION.
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`Q.
`
`YOU MENTIONED THE LTE STANDARD REQUIRING THIS LOGICAL
`
`CHANNEL AND BANDWIDTH ALLOCATION.
`
`MR. CUNNINGHAM: CAN WE HAVE DX 272, PLEASE.
`
`Q. (MR. CUNNINGHAM) : NOW, WE HAVE SEEN THIS SEVERAL
`
`TIMES BEFORE, BUT PLEASE REMIND US, WHAT ARE WE LOOKING AT?
`
`A.
`
`WE ARE LOOKING AT ONE OF THE DOCUMENTS THAT DEFINE THE
`
`LTE STANDARD. SO PHONES THAT ARE GOING TO WORK WITH THE LTE
`
`STANDARD, THIS DESCRIBES WHAT THEY HAVE TO DO.
`
`Q.
`
`AND IN YOUR REVIEW OF THE ACTUAL IPHONE CODE AND
`
`
`
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`DOCUMENTS, DID YOU SEE ANYTHING THAT SUGGESTED THAT THE
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`IPHONES DON'T FOLLOW THE STANDARD?
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`A.
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`NO. EVERYTHING I SAW WAS CONSISTENT WITH WHAT IS IN THE
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`STANDARD.
`
`Q.
`
`ALL RIGHT.
`
`MR. CUNNINGHAM: LET'S HAVE PAGE 24. AND JUST BLOW
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`UP THE 5.4.3.1, ALL THE WAY DOWN TO THE BOTTOM OF THE PAGE,
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`PLEASE. MAKE THAT A LITTLE BIT BIGGER.
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`Q. (MR. CUNNINGHAM) : WHAT IS THIS SECTION OF THE
`
`STANDARD DISCUSSING?
`
`A.
`
`THIS SECTION DESCRIBES SOMETHING CALLED LOGICAL CHANNEL
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`PRIORITIZATION, WHICH BASICALLY DESCRIBES HOW BANDWIDTH IS
`
`ALLOCATED ACROSS LOGICAL CHANNELS.
`
`Q.
`
`NOW, I SEE IT BEGINS WITH, THE LOGICAL CHANNEL
`
`PRIORITIZATION PROCEDURE IS APPLIED WHEN A NEW TRANSMISSION IS
`
`PERFORMED.
`
`DO YOU SEE THAT?
`
`YES, I DO.
`
`WHAT DOES THAT MEAN?
`
`IT MEANS THAT WHENEVER THERE IS DATA TO BE TRANSMITTED
`
`A.
`
`Q.
`
`A.
`
`THIS IS THE ALGORITHM, THIS IS THE PROCEDURE THAT IS FOLLOWED
`
`TO ALLOCATE RESOURCES.
`
`MR. CUNNINGHAM: IF YOU DROP DOWN THERE IS SORT OF A
`
`DASH -- YEAH. RIGHT THERE.
`
`Q. (MR. CUNNINGHAM) : THE UE SHALL ALLOCATE RESOURCES TO
`
`
`
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`THE LOGICAL CHANNELS IN THE FOLLOWING STEPS.
`
`DO YOU SEE THAT?
`
`I DO.
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`WHAT IS BEING DESCRIBED THERE. I SEE AT LEAST THREE
`
`A.
`
`Q.
`
`STEPS: STEP 1, STEP 2, STEP 3. WHAT IS THAT?
`
`A.
`
`OKAY. THIS IS THE PROCEDURE BY WHICH -- THERE IS DATA
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`WAITING IN EACH OF THOSE LOGICAL CHANNEL BUCKETS. AND THE UE,
`
`WHICH IS TO SAY THE HANDSET, IS GIVEN A BANDWIDTH ALLOCATION.
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`IT THEN ALLOCATES THAT BANDWIDTH ACROSS THOSE LOGICAL
`
`CHANNELS. AND THE STEP 1, STEP 2, STEP 3 ARE THE DETAILS OF
`
`HOW THAT PROCEDURE IS CARRIED OUT.
`
`Q.
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`AND WHAT'S THE OVERALL GOAL OF THIS THREE-STEP PROCESS?
`
`WHAT ARE WE TRYING TO ACHIEVE?
`
`A.
`
`THE MAIN THING YOU WANT TO DO IS PRIORITIZE DATA THAT
`
`NEEDS TO BE PRIORITIZED, BUT NOT PRIORITIZE IT SO MUCH THAT
`
`THE OTHER LOGICAL CHANNELS GET WHAT IS CALLED STARVED. YOU
`
`DON'T WANT THEM TO -- YOU DON'T WANT TO GIVE ALL OF THE
`
`BANDWIDTH TO THE TOP PRIORITY LOGICAL CHANNEL AND LEAVE
`
`EVERYBODY ELSE OUT IN THE COLD.
`
`SO THE POLICY THAT TAKES PLACE, THE PROCEDURE THAT TAKES
`
`PLACE, AT MAYBE NOT AT A HIGH LEVEL BUT KIND OF A MEDIUM
`
`LEVEL, THERE ARE THREE PARAMETERS ASSOCIATED WITH THE -- EACH
`
`LOGICAL CHANNEL. YOU CAN SEE THEM UP THERE AT THE TOP.
`
`PRIORITY, THAT GIVES IT THE PRIORITY NUMBER. PRIORITIZE BIT
`
`RATE. AND THEN BUCKET SIZE DURATION. SO THOSE ARE THE THREE
`
`
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`PARAMETERS THAT ARE USED TO CARRY OUT THE PRIORITIZATION
`
`Q.
`
`A.
`
`WHERE DO THE PARAMETERS COME FROM?
`
`THOSE PARAMETERS ARE SIGNALED BY THE NETWORK. THOSE
`
`PARAMETERS COME FROM THE BASE STATION.
`
`Q.
`
`I SEE. NOW, I SEE IN THIS THREE-STEP PROCESS SEVERAL
`
`REFERENCES TO LOGICAL CHANNELS. IS THERE ANYTHING IN THIS
`
`THREE-STEP PROCESS THAT RELATES TO ALLOCATING BANDWIDTH TO
`
`CONNECTIONS?
`
`A.
`
`Q.
`
`THERE IS NOTHING IN HERE ABOUT CONNECTIONS, NO.
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`IS THERE ANYTHING IN THESE STEPS ABOUT ALLOCATING
`
`BANDWIDTH TO USER CONNECTIONS?
`
`A.
`
`Q.
`
`NO, THERE IS NOT.
`
`IS THERE ANYTHING IN THESE THREE STEPS ABOUT ALLOCATING
`
`BANDWIDTH TO BUSES?
`
`A.
`
`Q.
`
`NO, NOTHING LIKE THAT.
`
`IS THIS THREE-STEP PROCESS THE THING THAT ALLOCATES
`
`BANDWIDTH IN THE IPHONE?
`
`A.
`
`Q.
`
`YES, IT IS.
`
`NOW, IF THIS THREE-STEP PROCESS THAT WE ARE LOOKING AT
`
`HERE WANTED TO ALLOCATE BANDWIDTH ACROSS THE TWO USER
`
`CONNECTIONS THAT I HAVE DRAWN AT THE TOP OF THAT DIAGRAM,
`
`COULD IT?
`
`A.
`
`Q.
`
`A.
`
`NO, IT COULD NOT.
`
`WHY NOT?
`
`BECAUSE AT THIS POINT IT DOES NOT HAVE ACCESS TO THAT
`
`
`
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`INFORMATION. AT THIS POINT WHAT IT IS DEALING WITH ARE JUST
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`PACKETS, AND ALL IT KNOWS ABOUT EACH PACKET IS WHICH LOGICAL
`
`CHANNEL THE PACKET IS IN AND WHAT ARE THE PARAMETERS, WHAT IS
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`THE PRIORITY RATE, THE PRIORITIZED BIT RATE, AND BUCKET SIZE
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`DURATION FOR THAT LOGICAL CHANNEL. THAT IS ALL THE PROCESSOR
`
`KNOWS WHEN IT GOES ABOUT MAKING THIS DECISION.
`
`Q.
`
`DID YOU HEAR DR. MADISETTI TESTIFY ABOUT HOW THE
`
`BASEBAND PROCESSOR WOULD KNOW WHAT DATA IS COMING OVER THOSE
`
`TWO BUSES? DO YOU REMEMBER THAT?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`YES, I DID.
`
`DO YOU AGREE WITH WHAT HE IS SAYING?
`
`NO, I DON'T.
`
`WHY NOT?
`
`WELL, WE ARE LOOKING AT THE ALGORITHM. THERE IS NOTHING
`
`IN HERE WHICH SUGGESTS THAT IT MAKES USE OF THAT INFORMATION.
`
`AND GIVEN THAT THE DATA, AS IT IS FLOWN -- THE DATA AS IT HAS
`
`FLOWED THROUGH THE PROCESSING, THE DATA HAS BECOME CHANGED, IT
`
`HAS BECOME ENCRYPTED. BY THE TIME YOU GET DOWN TO THE LOGICAL
`
`CHANNEL LEVEL, ANY INDICATION OF WHAT APP IT STARTED IN IS
`
`UNAVAILABLE.
`
`Q.
`
`I SEE. NOW, DR. MADISETTI TESTIFIED THE OTHER DAY THAT
`
`LOGICAL CHANNELS WEREN'T ESSENTIAL TO HIS ANALYSIS. DO YOU
`
`REMEMBER THAT?
`
`A.
`
`Q.
`
`I DO.
`
`I THINK HE EVEN SAID HE DIDN'T WANT TO COMMENT ON THE
`
`
`
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`LOGICAL CHANNELS.
`
`A.
`
`Q.
`
`I REMEMBER THAT, YES.
`
`DO YOU AGREE WITH THAT LOGICAL CHANNELS AREN'T
`
`ESSENTIAL?
`
`A.
`
`I THINK THEY ARE FUNDAMENTAL. I MEAN, THIS IS HOW --
`
`THIS IS HOW BANDWIDTH IS ALLOCATED, AND IT IS ALL ABOUT
`
`LOGICAL CHANNELS.
`
`Q.
`
`WERE LOGICAL CHANNELS ESSENTIAL TO DR. MADISETTI'S
`
`ANALYSIS IN HIS EXPERT REPORT?
`
`A.
`
`HE CERTAINLY REFERENCED LOGICAL CHANNELS IN HIS EXPERT
`
`REPORT, YES.
`
`MR. CUNNINGHAM: LET'S HAVE HIS REPORT, PAGE 66,
`
`PARAGRAPH 164. LET'S HAVE THAT ON THE SCREEN, PLEASE.
`
`Q. (MR. CUNNINGHAM) : NOW, THE MIDDLE SENTENCE SAYS, THE
`
`ACCUSED PRODUCTS ALLOCATE BANDWIDTH BASED ON PRIORITY USING
`
`LOGICAL CHANNEL PRIORITIZATION.
`
`HE CONTINUES, THE ACCUSED PRODUCTS USE LOGICAL
`
`CHANNELS IN THE PROCESS OF ALLOCATING BANDWIDTH BASED ON
`
`PRIORITIZATION.
`
`DO YOU SEE THAT, SIR?
`
`I DO.
`
`IS HE RIGHT IN PARAGRAPH 164 OF HIS EXPERT REPORT?
`
`YES, AS WE JUST SAW. THEY CERTAINLY USE LOGICAL
`
`A.
`
`Q.
`
`A.
`
`CHANNELS IN THE PROCESS OF ALLOCATING BANDWIDTH BASED ON
`
`PRIORITIZATION.
`
`
`
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`Q.
`
`CAN YOU SQUARE WHAT WE HAVE ON THE SCREEN FROM HIS
`
`EXPERT REPORT WITH WHAT HE SAID A COUPLE OF DAYS AGO TO THIS
`
`JURY?
`
`A.
`
`Q.
`
`I THINK THOSE TWO STATEMENTS ARE INCONSISTENT.
`
`ALL RIGHT. LET'S THEN STAY WITH DR. MADISETTI FOR A
`
`MOMENT.
`
`MR. CUNNINGHAM: I WANT TO HAVE SLIDE 52 FROM HIS
`
`PRESENTATION. THANK YOU.
`
`Q. (MR. CUNNINGHAM) : DR. FUJA, DID YOU HAVE A LOOK AT
`
`THIS DURING DR. MADISETTI'S TESTIMONY?
`
`A.
`
`Q.
`
`YES, I DID.
`
`IN YOUR VIEW IS THIS AN ACCURATE DEPICTION OF WHAT THE
`
`INSIDE OF THE APPLICATION PROCESSOR AND THE INSIDE OF THE
`
`BASEBAND PROCESSOR LOOK LIKE?
`
`A.
`
`NO, IT IS NOT. IT IS MISSING A LOT. AND SOME OF THE
`
`THINGS DON'T SEEM TO BE IN THE RIGHT PLACE.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`I SEE. DOES THIS LEAVE OUT SOME DETAILS?
`
`YES, IT DOES.
`
`DOES IT LEAVE OUT SOME IMPORTANT DETAILS?
`
`YES, IT DOES. THERE IS SEVERAL LAYERS OF PROCESSING
`
`AFTER THE DATA FLOWS ACROSS INTO THE BASEBAND PROCESSOR BEFORE
`
`THE QUEUES THAT DR. MADISETTI INDICATES CONTAIN THE DATA.
`
`Q.
`
`A.
`
`Q.
`
`DID YOU SPEND SOME TIME TRYING TO FIX THIS DIAGRAM, SIR?
`
`YES, I DID.
`
`ALL RIGHT. LET'S SEE WHAT YOU DID.
`
`
`
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`SO FIRST THING I WANT TO TALK ABOUT IS THIS, THE TRUCK
`
`THAT SAYS MAC PACKET. I KNOW THAT THAT IS OBVIOUSLY AN
`
`ANALOGY FOR SOMETHING. DO YOU THINK IT IS A FAIR ANALOGY?
`
`A.
`
`IT IS A LITTLE INACCURATE. THERE ARE MAC PACKETS,
`
`CERTAINLY, AND I DON'T MIND SHOWING THEM ASSOCIATED WITH, I
`
`GUESS, A MAC TRUCK.
`
`BUT THE MAC PACKETS ARE GOING TO JUST BE FLOWING TO
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`ANOTHER LAYER OF PROCESSING IN THE BASEBAND PROCESSOR, THEY
`
`ARE NOT GOING TO BE DRIVING OFF TO THE BASE STATION. SO I
`
`THINK PROBABLY WE SHOULD TAKE THAT OFF.
`
`Q.
`
`WHY DON'T WE REMOVE THAT.
`
`SO THE TRAFFIC SIGNALS THAT APPEAR OVER THE TOP OF THESE
`
`TWO CONNECTIONS, I REALIZE THAT IS ANOTHER ANALOGY. IS THAT A
`
`FAIR ANALOGY?
`
`A.
`
`WELL, TO THE EXTENT THAT THEY REPRESENT THE TRAFFIC FLOW
`
`TEMPLATES, AGAIN I THINK THEY ARE IN THE WRONG PLACE. WE CAN
`
`BRING THEM IN THE TRAFFIC FLOW TEMPLATE BACK LATER, BUT FOR
`
`RIGHT NOW I WOULD LIKE TO TAKE THAT OFF.
`
`MR. CUNNINGHAM: LET'S REMOVED THAT, PLEASE.
`
`Q. (MR. CUNNINGHAM) : NOW, THE TWO THINGS CALLED VOLTE
`
`CONNECTION AND DATA CONNECTION, ARE THOSE THINGS ACTUALLY IN
`
`THE IPHONE?
`
`A.
`
`NO. WHAT THERE ARE, AS WE HAVE HEARD, ARE TWO BUSES
`
`THAT GO FROM THE APPLICATION PROCESSOR TO THE BASEBAND
`
`PROCESSOR.
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`
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`Q.
`
`A.
`
`Q.
`
`CAN WE JUST REMOVE THOSE LABELS FOR THE TIME BEING?
`
`SURE.
`
`NOW, YOU MENTIONED THAT THE TRAFFIC FLOW TEMPLATE, YOU
`
`THOUGHT, WAS IN THE WRONG PLACE. DO YOU WANT TO REMOVE THAT,
`
`AND MAYBE WE WILL PUT IT BACK ON LATER?
`
`A.
`
`Q.
`
`SURE. THAT SOUNDS FINE.
`
`ALL RIGHT. AND WHAT ABOUT THIS ARROW THAT SAYS
`
`PARAMETER VALUES, IS THAT IN THE RIGHT SPOT?
`
`A.
`
`YOU KNOW, THE BASE STATION DOES SEND PARAMETER VALUES TO
`
`THE BASEBAND PROCESSOR, BUT THAT'S NOT ALL THEY SEND. THEY
`
`SEND COMMANDS. COLLECTIVELY THEY CALL THOSE THINGS MESSAGES.
`
`Q.
`
`A.
`
`SO CAN WE TAKE THAT OFF, AND MAYBE PUT IT BACK ON?
`
`YEAH. LET'S TAKE IT OFF, WE WILL PUT IT BACK ON AS
`
`MESSAGES LATER.
`
`Q.
`
`OKAY. NOW I WANT TO TALK ABOUT THESE THINGS THAT LOOK
`
`LIKE PIPES, THE GREEN AND BLUE THINGS. IN THE ACTUAL IPHONE
`
`DO THESE PIPES ACTUALLY EXTEND DOWN INSIDE THE BASEBAND
`
`PROCESSOR?
`
`A.
`
`NO. THESE REPRESENT BUSES, AND THE BUSES GO FROM THE
`
`APPLICATION PROCESSOR TO THE BASEBAND PROCESSOR, BUT THEY
`
`DON'T EXTEND INTO EITHER ONE.
`
`Q.
`
`DID YOU HEAR MR. KODALI SAY THAT THESE BUSES ACTUALLY
`
`CONNECT TO PINS ON THE BASEBAND PROCESSOR?
`
`A.
`
`Q.
`
`I DID.
`
`WHAT DOES THAT MEAN?
`
`
`
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`A.
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`ON THE EDGE OF A -- OF ANY KIND OF INTEGRATED CIRCUIT
`
`THERE ARE PINS THAT ALLOW YOU ACCESS TO THAT INTEGRATED
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`CIRCUIT. SO THE FACT THAT THERE IS A BASEBAND PROCESSOR AND
`
`AN APPLICATION PROCESSOR, WE GET DATA ONTO AND OFF THEM VIA A
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`PIN. AND WHAT MR. KODALI SAID WAS THAT THE BUSES GO FROM ONE
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`PIN ON THE APPLICATION PROCESSOR TO ANOTHER PIN ON THE
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`BASEBAND PROCESSOR.
`
`Q.
`
`SO WOULD IT BE MORE ACCURATE THEN, SIR, TO SORT OF CUT
`
`THESE PIPES RIGHT WHERE THEY HIT THE BASEBAND PROCESSOR LIKE
`
`WE HAVE DONE ON THIS CHART?
`
`A.
`
`YES, IT WOULD BE MORE ACCURATE.
`
`MR. CUNNINGHAM: LET'S DO THAT.
`
`Q. (MR. CUNNINGHAM) : AND IS THE SAME TRUE ON THE
`
`APPLICATION PROCESSOR SIDE WHERE DO THESE PIPES ACTUALLY
`
`EXTEND INSIDE THE APPLICATION PROCESSOR?
`
`A.
`
`NO. THE BUSES DO NOT EXTEND INTO THE APPLICATION
`
`PROCESSOR, THEY STOP AT THE EDGE.
`
`Q.
`
`A.
`
`Q.
`
`CAN WE CUT THOSE AS WELL?
`
`YES.
`
`WHILE WE ARE AT IT, CAN WE LABEL THESE WITH THE NAMES
`
`THAT THEY ACTUALLY HAVE?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`I THINK THAT WOULD BE A GOOD IDEA DO.
`
`WHAT ARE THOSE NAMES?
`
`THAT IS PCIE BUS AND THE I2S BUS.
`
`OKAY. NOW, WHAT WE HAVE LEFT IN THE MIDDLE IS LABELED
`
`
`
`Case 3:14-cv-02235-DMS-BLM Document 524 Filed 10/26/18 PageID.25368 Page 22 of 168
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`PRIORITY QUEUES. IS THERE SOMETHING CALLED PRIORITY QUEUES IN
`
`THE IPHONE?
`
`A.
`
`NOT THAT I HAVE SEEN THAT ARE CALLED PRIORITY QUEUES.
`
`WHAT THERE ARE ARE QUEUES, WHICH IS JUST SORT OF A SOFTWARE
`
`CONSTRUCT THAT ALLOWS YOU TO STORE DATA, MOVE DATA IN AND OUT
`
`OF THOSE LOCATIONS. THERE ARE LOGICAL CHANNELS THAT HAVE
`
`QUEUES ASSOCIATED WITH THEM, AND THOSE LOGICAL CHANNELS HAVE
`
`PRIORITY. SO INDIRECTLY YOU COULD SAY THERE ARE PRIORITIES
`
`ASSOCIATED WITH QUEUES, BUT I DIDN'T SEE ANYTHING CALLED A
`
`PRIORITY QUEUE.
`
`Q.
`
`ALL RIGHT. CAN WE JUST TAKE THE LABEL OFF FOR THE
`
`MOMENT?
`
`A.
`
`Q.
`
`SURE.
`
`NOW, THIS GREEN AND BLUE BOXES THAT ARE INSIDE WHAT WE
`
`HAD LABELED PRIORITY QUEUES, IS THAT -- ARE THOSE BOXES IN THE
`
`RIGHT PLACE? ARE THEY DRAWN CORRECTLY ACCORDING TO THE REAL
`
`IPHONE?
`
`A.
`
`IT SUGGESTS THAT WE HAVE GOT ONE BUFFER DEDICATED TO I2S
`
`BUS DATA AND ANOTHER BUFFER OR QUEUE ASSOCIATED WITH THE PCIE
`
`BUS, AND THAT IS NOT TRUE.
`
`Q.
`
`CAN WE TAKE THAT OFF FOR NOW, AND I THINK WE WILL PUT IT
`
`BACK ON IN A MINUTE.
`
`A.
`
`Q.
`
`YES.
`
`HOW ABOUT THE WHITE BOXES THAT ARE LEFT, ARE THEY IN THE
`
`RIGHT SPOT?
`
`
`
`Case 3:14-cv-02235-DMS-BLM Document 524 Filed 10/26/18 PageID.25369 Page 23 of 168
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`A.
`
`THEY ARE DEFINITELY QUEUES, I BELIEVE THEY ARE MEANT TO
`
`INDICATE QUEUES. BUT IN TERMS OF THE DATA PROCESSING, NO,
`
`THEY ARE NOT IN THE RIGHT SPOT.
`
`Q.
`
`WE WILL PUT THOSE BACK ON LATER, I THINK, BUT LET'S TAKE
`
`THEM OFF FOR NOW.
`
`A.
`
`Q.
`
`OKAY.
`
`OKAY. SO NOW WE HAVE AN EMPTY BASEBAND PROCESSOR. IS
`
`THAT RIGHT?
`
`A.
`
`Q.
`
`A.
`
`NO, THAT IS NOT RIGHT EITHER.
`
`OKAY. SO SHOULD WE START ADDING THINGS BACK IN?
`
`I THINK THE FIRST THING THAT YOU MIGHT WANT TO ADD IN
`
`ARE SOME ADDITIONAL APPS, JUST BECAUSE DRAWING IT LIKE THIS
`
`SUGGESTS THAT THERE IS ONLY EVER TWO APPS RUNNING. AND THAT
`
`IS CERTAINLY NOT THE CASE.
`
`Q.
`
`A.
`
`WHAT ARE YOU GOING TO PUT ON HERE, THEN?
`
`I THINK WE GOT ANOTHER COUPLE OF APPS, IF WE GO TO THE
`
`NEXT SLIDE. RIGHT.
`
`WE HAVE GOT THE MESSAGING APP AND THE MAIL APP ALONG
`
`WITH THE TWO THAT WERE THERE ORIGINALLY.
`
`AND I ALSO INDICATED HERE WHERE DATA CAN FLOW FROM EACH
`
`OF THE APPS ACROSS WHICH BUSES.
`
`Q.
`
`AND JUST FOR POSTERITY'S SAKE, THE ORANGE LINE THAT GOES
`
`FROM THE PHONE APP TO THE PCIE BUS, WHAT IS THAT?
`
`A.
`
`WE HAVE HEARD THERE IS AT LEAST TWO DIFFERENT KINDS OF
`
`PHONE DATA THAT TRAVELS ACROSS THE PCIE BUS. THERE IS THIS
`
`
`
`Case 3:14-cv-02235-DMS-BLM Document 524 Filed 10/26/18 PageID.25370 Page 24 of 168
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`DTMF DATA, YOU KNOW, THE PUSH BUTTON DATA. AND THEN THERE IS
`
`ALSO WHAT IS CALLED SIP AND SDP DATA, WHICH IS SESSION
`
`INITIATION PROTOCOL AND SESSION DESCRIPTION PROTOCOL. THAT
`
`BASICALLY HELPS THE PHONE SET UP THE PHONE SESSION.
`
`Q.
`
`THANK YOU. AND SO ON OUR BOARD WE HAVE A NUMBER OF
`
`THINGS THAT WE HAVE TERMED THE SOFTWARE LAYERS.
`
`A.
`
`Q.
`
`UM-HUM.
`
`DID DR. MADISETTI'S DIAGRAM HAVE ANY OF THOSE SOFTWARE
`
`LAYERS?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`NO, IT DID NOT.
`
`SO CAN WE ADD THOSE BACK IN?
`
`SURE.
`
`WHAT IS THE FIRST SET OF THINGS THAT THE DATA WOULD
`
`ENCOUNTER INSIDE THE BASEBAND PROCESSOR?
`
`A.
`
`WELL, YOU CAN SEE IT RIGHT OVER THERE. THE DATA THAT
`
`COMES ACROSS THE I2S BUS COMES INTO AN AUDIO DSP.
`
`GO AHEAD AND CLICK, YOU CAN SEE THAT COME IN. OKAY.
`
`SO THE DATA COMING ACROSS THE I2S BUS GOES THROUGH THIS
`
`AUDIO DSP.
`
`WHAT THAT DOES, THE DATA COMING ACROSS THE I2S BUS
`
`ARE -- YOU HAVE HEARD THIS WORD BEFORE, SPEECH SAMPLES. OKAY.
`
`SO A MICROPHONE GENERATES A FLUCTUATING VOLTAGE BASED ON THE
`
`VOICE THAT GOES INTO IT. SAMPLES JUST MEANS YOU ARE TAKING
`
`THAT AND YOU ARE DETERMINING WHAT VALUE THE VOLTAGE TAKES,
`
`LET'S SAY 8,000 TIMES A SECOND. THEN YOU REPRESENT EACH ONE
`
`
`
`Case 3:14-cv-02235-DMS-BLM Document 524 Filed 10/26/18 PageID.25371 Page 25 of 168
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`OF THOSE SAMPLES WITH A FIXED NUMBER OF BITS, AND THOSE ARE
`
`WHAT ARE COMING ACROSS THAT I2S BUS, THE AUDIO DSP.
`
`THE AUDIO DSP THEN COMPRESSES, CRUNCHES IT DOWN. MAYBE
`
`GOES FROM 60 OR 70,000 BITS PER SECOND DOWN TO LESS THAN
`
`10,000 BITS PER SECOND.
`
`Q.
`
`THANK YOU. NOW, DID THOSE -- WHAT WE JUST ADDED, DO
`
`THOSE CORRESPOND TO THESE TWO BLOCKS ON DX 40?
`
`A.
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