Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 1 of 133 PageID #: 13466
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 10-258 (SLR)(MPT)
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`MOBILEMEDIA IDEAS LLC,
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`APPLE INC.,
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`Plaintiff,
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`Defendant.
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`v.
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`DECLARATION OF DR. SIGURD MELDAL IN SUPPORT OF PLAINTIFF
`MOBILEMEDIA IDEAS LLC’S BRIEF IN OPPOSITION TO
`APPLE’S MOTION FOR SUMMARY JUDGMENT OF INVALIDITY AND
`NON-INFRINGEMENT OF U.S. PATENT NO. RE 39,231
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`MORRIS, NICHOLS, ARSHT & TUNNELL LLP
`Jack B. Blumenfeld (#1014)
`Rodger D. Smith II (#3778)
`Jeremy A. Tigan (#5239)
`1201 North Market Street
`P.O. Box 1347
`Wilmington, DE 19899
`(302) 658-9200
`jblumenfeld@mnat.com
`rsmith@mnat.com
`jtigan@mnat.com
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`Attorneys for Plaintiff MobileMedia Ideas, LLC
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`OF COUNSEL:
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`Steven M. Bauer
`Justin J. Daniels
`Safraz W. Ishmael
`PROSKAUER ROSE LLP
`One International Place
`Boston, MA 02110-2600
`(617) 526-9600
`Kenneth Rubenstein
`Anthony C. Coles
`Alan Federbush
`PROSKAUER ROSE LLP
`Eleven Times Square
`New York, NY 10036-8299
`(212) 969-3000
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 2 of 133 PageID #: 13467
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`I, Sigurd Meldal, declare as follows:
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`I.
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`Introduction
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`1.
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`My name is Dr. Sigurd Meldal, and I have been retained by the plaintiff,
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`MobileMedia Ideas, LLC (“MobileMedia”), as an expert on some of the technology at issue in
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`this lawsuit.
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`2.
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`I submit this declaration in support of MobileMedia’s Brief in Opposition to
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`Apple’s Motion for Summary Judgment of Invalidity and Non-Infringement of U.S. Patent No.
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`Re 39,231.
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`3.
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`In my capacity as an expert, I previously prepared reports containing my opinions
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`regarding six MobileMedia patents,1 including a response to relevant sections of the expert
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`reports submitted by Dr. Jack D. Grimes, Dr. Ravin Balakrishnan and Dr. Robert Akl.
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`4.
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`I have personal knowledge of, and expert opinions regarding, the facts set forth in
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`this declaration and, if called to testify as a witness, could and would do so competently.
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`II.
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`Qualifications
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`5.
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`A true and correct excerpt from my first expert report on infringement, submitted
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`on January 13, 2012, is attached as Exhibit A. I hereby incorporate by reference into this
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`declaration my entire first expert report on infringement submitted on January 13, 2012.
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`6.
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`My first expert report on non-infringement contains a full description of my
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`educational background and qualifications. Full descriptions of my educational background,
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`professional achievements, qualifications and publications are set forth in my curriculum vitae,
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`Exhibit A to my first expert report.
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`
`1
`The six MobileMedia patents that I have examined and opined on are: U.S. 6,427,078
`(‘078 Patent); U.S. RE39,231 (‘231 Patent); U.S. 6,070,068 (‘068 Patent); U.S. 5,737,394 (‘394
`Patent); U.S. 5,915,239 (‘239 Patent); and U.S. 6,253,075 (‘075 Patent).
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`1
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 3 of 133 PageID #: 13468
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`III. Applicable Law
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`7.
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`MobileMedia’s counsel have informed me about the legal standards for patent
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`validity and infringement. I understand that a patent is presumed valid upon issuance. I also
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`understand that Apple, as the patent challenger, bears the burden of proving the elements of
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`patent invalidity by clear and convincing evidence. I further understand that the claims of the
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`patents-in-suit must be interpreted and given the same meaning for purposes of both validity and
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`infringement analyses. I further understand that to prove infringement, a patentee must
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`demonstrate that the claims, as properly construed, cover the accused device.
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`8.
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`U.S. Patent No. RE 39,231 (the ’231 patent) reissued from U.S. Patent No.
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`5,995,852 filed on December 13, 1995.
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`9.
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`I understand that both Apple and MobileMedia have proposed that certain terms
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`in the claims should be construed to have certain meanings. I understand that some of the
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`meanings proposed by Apple in its Motion for Summary Judgment of Invalidity and Non-
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`Infringement of U.S. Patent No. RE 39,231 were not previously proposed, and so I am
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`addressing them here for the first time.
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`IV. The “Alert Sound Generator for Generating an Alert Sound when the Call is
`Received”
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`10.
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`I understand that Apple contends that the claim term “alert sound generator for
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`generating an alert sound when the call is received” in claim 12 (“‘alert sound generator’ claim
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`term”) should be construed as a means plus function limitation.
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`11.
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`I understand that Apple contends that the claimed functions of the “alert sound
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`generator” claim term are: (1) “generating an alert sound when the call is received from the remote
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`caller” and (2) “changing a volume of the generated alert sound only for the received call when
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`controlled by the control means to do so.”
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`2
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 4 of 133 PageID #: 13469
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`12.
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`I understand that Apple contends that the structure of this “alert sound generator”
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`claim term that is disclosed in the ’231 patent is “alert sound generator”.
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`13.
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`I understand that Apple contends that this claim term is indefinite under this
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`construction because the sole disclosure of the structure for the “alert sound generator” is the box
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`labeled “alert sound generator 13” in figure 2 of the ’231 patent.
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`14.
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`I understand that MobileMedia contends that the “alert sound generator” claim term
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`should not be construed as a means plus function claim term. Rather, MobileMedia contends that the
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`“alert sound generator” claim term should be construed as “a sound generator capable of generating
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`an alert sound when a call is received from the remote caller.”
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`15.
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`I understand that Apple contends that the “alert sound generator” is indefinite under
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`this alternative construction because it would cover any mechanism capable of generating an alert
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`sound.
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`16.
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`At the time of the filing of the ’231 patent, the term “generator,” when preceded by
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`the word “sound,” or words that describe sounds, was understood by persons of ordinary skill in
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`the art to refer to an electronic circuit, including a speaker or vibrator, that was capable of
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`generating sounds, as well as stopping the generation of such sounds. This is evidenced by the
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`prolific use of the term “generator” in contemporaneous documents – including in electronics
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`catalog and hobbyist publications at the time of and even prior to the filing of the ’231 patent – in
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`precisely this context with this meaning.
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`(a)
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`For example, as far back as the 1970s, Texas Instruments sold an
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`integrated circuit called the “Complex Sound Generator” SN76477N. See Radio Shack Catalog
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`1979, p. 101 (available at www.radioshackcatalogs.com/catalogs/1979/ accessed November 17,
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`2015) (attached as Exhibit B). This integrated circuit was designed to be connected to a
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`3
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 5 of 133 PageID #: 13470
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`loudspeaker to produce complex sounds. For example, although this electronic circuit is not a
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`“barking dog,” it was capable of producing a “dog’s bark” sound from a connected loudspeaker.
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`In other words, the circuit was a sound generator designed to generate sounds. See L. Garner,
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`“Solid State: Chirp, Jangle Whoosh, Boom!,” Popular Electronics, October 1978, p. 1 (available
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`at http://www.decodesystems.com/SN76477.pdf, accessed on Nov. 17, 2015) (attached as
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`Exhibit C).
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`(b)
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`In the early 1980s, General Instrument also produced two integrated
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`circuit models, which were both called the “Programmable Sound Generator” AY-3-8910 and
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`AY-3-8912. Each of these Programmable Sound Generator IC models was capable of receiving
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`instructions from a host processor to generate sounds for output from a loudspeaker. See B.A.
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`Paturzo, “IC Applications: 1-IC Programmable,” Radio-Electronics, April 1981, p. 56-61, at p.
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`57 (available at http://www.classiccmp.org/cini/pdf/re/1-
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`IC%20Sound%20Generator%20(0481).pdf, accessed on November 17, 2015) (attached as
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`Exhibit D).
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`(c) A similar component was also disclosed in U.S. Patent No. 5,657,372
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`(“Ahlberg”) (attached as Exhibit E). Figure 3 of Ahlberg shows a cellular telephone electronic
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`circuit schematic. The cellular telephone 21 includes a notification means 46 connected to a
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`“ring signal generator 41” for alerting the user of the cellular telephone that a telephone call has
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`been placed thereto. Ahlberg, col. 6, ll. 35-39. The ring signal generator 41 can be incorporated
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`within the speaker 40 or it can be a distinct component. Ahlberg, col. 6, ll. 40-43. Ahlberg was
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`cited in Reexamination Control No. 90/011,482 of U.S. Patent No. Re. 39,231 and was applied in
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`an office action rejecting the claims. See Office Action dated April 25, 2011 in Reexamination
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`Control No. 90/011,482, p. 2, 9 and 10 (attached as Exhibit F).
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`(d)
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`Likewise, U.S. Patent No. 5,191,607 (“Meyers”) Figure 1 shows a ring
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`tone mute circuit for a radio/telephone (attached as Exhibit G). Figure 1 shows a “ring tone
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`generator 113” for generating a ring tone from audio speaker 115 for an incoming call and also
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`for deactivating it. Meyers, 1:36-39, 2:1-10. Meyers was cited in Reexamination Control No.
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`90/011,482 of U.S. Patent No. Re. 39,231 and was applied in an office action rejecting the
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`claims. See Office Action dated April 25, 2011 in Reexamination Control No. 90/011,482, p. 2,
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`3, 7 and 8 (attached as Exhibit F).
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`(e)
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`By way of further example, in EP Patent Application No. 275,193 A2
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`(“Saito”), Figure 2 shows a circuit diagram of a hand-held portable telephone with a “ringing
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`signal generator 3” (attached as Exhibit H). Saito 2:39-54 (switch 2 connects and disconnects
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`ringing signal generator); 3:15-21 (detecting arrival of call starts ringing signal); 3:30-34 (ringing
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`discontinued in response to detecting off hook). Saito was cited during the prosecution of the
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`’231 patent. See PTO-1449 Form, p. 1, considered by the examiner on June 14, 2005 in U.S.
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`Patent Application No. 09/998,426 (which issued as U.S. Patent No. Re. 39,231) (attached as
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`Exhibit I).
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`(f)
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`U.S. Patent No. 6,125,264 (“Watanabe”) describes a portable telephone
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`with a “sound generator” or “calling sound generator” used as an “informing means” to generate
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`a calling sound for an incoming call supplied to a speaker (attached as Exhibit J). Watanabe,
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`1:10-16. The sound generator can be implemented by a CPU 21 issuing a calling sound
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`generator command to an audio signal processor 5 or DSP in response to determining there is an
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`incoming call. The audio signal processor 5 uses sound data stored in ROM 22, generates a
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`sound which is supplied to a speaker 8. The sound is stopped when the user answers the call.
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`Watanabe, 4:7-22, 4:32-55. The informing means can also include a vibrator 18. Watanabe
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`5
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 7 of 133 PageID #: 13472
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`7:22-29. Watanabe was cited and considered in Reexamination Control No. 90/011,482 of U.S.
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`Patent No. Re. 39,231. See PTO-1449 filed June 24, 2011, p. 3, PTO-1449 filed June 24, 2011,
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`p. 6 (attached as Exhibits K and L).
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`17.
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`According to the specification of the ’231 patent, the alert sound generator 13 of
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`Figure 2 performs the two functions alleged by Apple, as noted in paragraph 11 above. See ‘231
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`patent Figures 2-5, 2:48-55, 3:1-6, 3:16-26, 3:39-61, 4:29-60.
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`18.
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`Therefore, under Apple’s proposed construction, which is described in paragraphs
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`11-12 above, the disclosure of “alert sound generator 13” in Figure 2 is adequate corresponding
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`structure to achieve the claimed function. A person of ordinary skill in the art would be able to
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`recognize the structure in the specification and associate it with the corresponding functions of the
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`claim.
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`19.
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`For the reasons noted above in paragraph16, the “alert sound generator” claim
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`term does in fact refer to a clear structural component: in the context of a cellular phone, this term
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`was understood by persons of ordinary skill in the art to refer to an electronic circuit, including a
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`speaker or a vibrator, that was capable of generating sounds, as well as stopping the generation of
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`such sounds.
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`20.
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`Consequently, under MobileMedia’s proposed construction in paragraph 14, the
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`“alert sound generator” term, viewed in light of the specification and prosecution history, informs
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`those skilled in the art about the scope of the invention with reasonable certainty.
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`21.
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`Furthermore, for the reasons noted above in pars. 16 and 19 supra, the “alert sound
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`generator” claim term was well-understood by persons of ordinary skill in the art to have a
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`sufficiently definite meaning as the name for structure, namely, an electronic circuit, including a
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`6
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 8 of 133 PageID #: 13473
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`speaker or vibrator, that is capable of generating sounds, as well as stopping the generation of such
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`sounds.
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`V.
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`The “Control Means for Controlling Said Alert Sound Generator”
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`22.
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`I understand that the Federal Circuit court has indicated that the claim term “control
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`means for controlling said alert sound generator” (“control means” claim term) should be construed
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`as a means plus function claim term. MobileMedia, 780 F.3d at 1180.
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`23.
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`I understand that the Federal Circuit court has indicated that the function of the
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`“control means” claim term is “controlling the alert sound generator to change a volume of the
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`generated alert sound.” MobileMedia, 780 F.3d at 1180.
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`24.
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`I understand that the Federal circuit has indicated that the structure of the “control
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`means” claim term is “the phone’s CPU and alert sound generator on/off controller.”
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`MobileMedia, 780 F.3d at 1180.
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`25.
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`I understand that Apple contends that the “control means” claim term should be
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`construed as a means plus function claim term.
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`26.
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`I understand that Apple contends that the function of the “control means” claim
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`term is “controlling the alert sound generator to change a volume of the generated alert sound.”
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`27.
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`I understand that Apple contends that the “control means” claim term should be
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`interpreted to require as structure the phone’s CPU, which Apple alleges is a general purpose
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`processor, the alert sound generator on/off controller and an algorithm for performing the claimed
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`function.”
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`28.
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`I understand that Apple contends that the “control means” claim term is indefinite.
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`Specifically, Apple argues that the ’231 patent specification discloses no such algorithm for
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`performing the claimed function of the “control means” claim term.
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`7
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 9 of 133 PageID #: 13474
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`29.
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`I understand that the Federal Circuit has stated that “[i]n response to the depression
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`of the phone’s power key, the specification indicates that the CPU and on/off controller can ‘stop
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`the generation of the alert sound.’ Id. at 3:3-6, 2:53-55. As an alternative, the specification
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`indicates that depression of the power key can instead result in the ‘volume of an alert sound being
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`reduced.’ Id. at 4:37-43, 5:7-11. Compare id. at Fig. 3 (stopping a sound), with id. at Fig. 4
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`(reducing a volume).” MobileMedia, 780 F.3d at 1180. One or more of ‘231 patent Figs. 3, 4,
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`2:53-55, 3:3-6, 4:36-43 and 5:7-11 referenced by the Federal Circuit Court in MobileMedia, 780
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`F.3d at 1180 discloses sufficient algorithm to define the structure and make the bounds of the claim
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`understandable, namely, by state transition schematic diagrams and descriptions of the operation of
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`the CPU 7 and alert on/off controller 12.
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`30.
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`A person skilled in the art would find the required algorithm disclosed in one or more
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`of the following portions of the ’231 patent referenced in MobileMedia, 780 F.3d at 1180: 2:49-55,
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`3:3-6, 4:36-43, 5:7-11, figures 3 and 4; and/or one or more of the following additional portions of the
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`‘231 patent specification: 2:48-49, 3:11-14, 3:16-30, 3:39-46, 3:52-56 and 4:43-60.
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`VI.
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`“RF Signal Processing Means for Transmitting and/or Receiving Radio Waves”
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`31.
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`I understand that the parties have agreed that the claim term “RF signal processing
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`means for transmitting and/or receiving radio waves” (“RF signal processing means” claim term)
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`should be construed as a means plus function limitation. I understand that the parties agree to
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`interpret the function of the “RF signal processing means” claim term as “transmitting and/or
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`receiving radio waves”. I understand that the parties agree to interpret the structure of the “RF
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`signal processing means” claim term as “RF signal processing circuitry”.
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`32.
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`I understand that Apple contends that the “RF signal processing means” claim term
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`is indefinite because the disclosure of structure in the ’231 patent specification is limited to a
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`8
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`“black box” labeled “RF signal processing 10” in Figure 2 and therefore does not provide
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`sufficient description of the structure for performing the claimed functions.
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`33.
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`A person having ordinary skill in the art would understand from the descriptions in
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`the ’231 patent specification that the “RF signal processing” portion 10 is RF signal processing
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`circuitry, i.e., an RF signal processor.” The term “RF” is understood to mean radio frequency. At
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`1:58-60, the ’231 patent states that “FIG. 2 is a block diagram showing an example of the inner
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`circuit of the communication terminal equipment according to the present invention,” and thus the
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`RF signal processing portion 10 depicted in Figure 2 is a circuit/circuitry. Further, at 2:29-47 the
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`’231 patent describes that signals are transmitted and received via the RF signal processing portion
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`10 and antenna, and thus radio waves or radio frequency signals are processed by the RF signal
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`processing portion.
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`34. At the time of filing of the ’231 patent, “RF signal processing portion” (alternatively,
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`“RF signal processing circuitry” or “RF signal processor”) was understood by persons of ordinary
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`skill in the art to refer to an electronic circuit that was capable of processing, e.g., transmitting and/or
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`receiving, radio waves or radio frequency signals.”
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`35.
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`RF signal processing circuitry (alternatively, “RF signal processing circuitry” or “RF
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`signal processor”) was a well-known component at the time of the filing of the ’231 patent, as
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`evidenced by the prolific usage of such term in connection with wireless phones. The following
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`patents provide just a few examples of this term’s usage in connection with contemporaneous
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`wireless phone technology:
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`(a)
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`U.S. Patent No. 5,737,687 (“a digital wireless telephone system includes…an
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`RF transceiver system including…RF signal processing circuitry.”) 1:32-37 (attached as Exhibit M);
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`9
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 11 of 133 PageID #: 13476
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`(b) U.S. Patent No. 5,749,057 (“In the portable telephone 100 circuit…an RF
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`signal processor 104 transmits or receives these bass band signals.”) 3:15-19 (attached as Exhibit N);
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`(c)
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`U.S. Patent No. 5,014,346 (“A rotatable contactless RF signal coupler, which
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`couples RF signals between an antenna and an RF signal processor in a portable radio, along with an
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`antenna capable of operating in two modes.”) Abstract (attached as Exhibit O); and
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`(d) U.S. Patent No. 6,125,264 (“a signal received at antenna 1is…supplied to RF
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`signal processor 3[] in which a signal of a predetermined transmission channel is frequency-
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`converted to an intermediate frequency (IF) signal. … The frequency converted signal from the RF
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`signal processor 3 is…supplied to the antenna 1, from which it is transmitted via radio waves.”)
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`(attached as Exhibit P) ‘264 patent, 2:38-47, 3:6-12.
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`36.
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`The “RF signal processing” portion 10 (i.e., “RF signal processing circuitry” or “RF
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`signal processor”) is nothing more than a readily recognizable and available component, which
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`would have been well-known to those of ordinary skill in the art.
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`37.
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`Therefore, under Apple’s proposed construction, the disclosure of “RF signal
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`processing” portion 10 in Figure 2 is adequate corresponding structure to achieve the claimed
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`function. A person of ordinary skill in the art would be able to recognize the structure in the
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`specification and associate it with the corresponding functions of the claim.
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`VII.
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`Infringement Analysis
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`38.
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`For the “control means” claim term, I understand that Apple contends that
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`MobileMedia has failed to show which structure in the accused iPhones is identical or equivalent to
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`the corresponding structure in the ’231 patent’s specification, and which performs the identical
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`function for the “control means” claim term.
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`39.
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`The same structures that I identified in my first expert report are identical or
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`equivalent to the corresponding structure in the specification for performing the identical function
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`recited in the claim under Apple’s new claim construction.
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`40.
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`41.
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`42.
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`I declare under penalties of perjury under the laws of the United States that the
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`foregoing is true and correct.
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`Executed this 24th day of November, 2015 in Menlo Park, California.
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`/s/ Dr. Sigurd Meldal
`Dr. Sigurd Meldal
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`11
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 13 of 133 PageID #: 13478
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`Executed this 24th day of November, 2015 in Yosemite National Park, California.
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`_______________________
`Dr. Sigurd Meldal
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`12
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 14 of 133 PageID #: 13479
`Case 1:10-cv-00258—SLR Document 590 Filed 12/09/15 Page 14 of 133 PageID #: 13479
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`EXHIBIT A
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`EXHIBIT A
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 15 of 133 PageID #: 13480
`Case 1:10-cv-00258—SLR Document 590 Filed 12/09/15 Page 15 of 133 PageID #: 13480
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`REDACTED
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`REDACTED
`IN ITS
`ENTIRETY
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`IN ITS
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`ENTIRETY
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 16 of 133 PageID #: 13481
`Case 1:10-cv-00258—SLR Document 590 Filed 12/09/15 Page 16 of 133 PageID #: 13481
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`EXHIBIT B
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`EXHIBIT B
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`1979 Radio Shack Catalog
`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 17 of 133 PageID #: 13482
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`

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`< 100
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 18 of 133 PageID #: 13483
`
`1979 Radio Shack Catalog
`Page 101 of 176 Back to index or low-res
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`102 >
`
`

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`< 100
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`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 19 of 133 PageID #: 13484
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`Page 101 of 176 Back to index or low-res
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`102 >
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`

`

`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 20 of 133 PageID #: 13485
`Case 1:10-cv-00258—SLR Document 590 Filed 12/09/15 Page 20 of 133 PageID #: 13485
`
`EXHIBIT C
`
`EXHIBIT C
`
`

`

`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 21 of 133 PageID #: 13486
`EE Document System SN76477 Page 1
`
`

`

`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 22 of 133 PageID #: 13487
`EE Document System SN76477 Page 2
`
`

`

`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 23 of 133 PageID #: 13488
`EE Document System SN76477 Page 3
`
`

`

`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 24 of 133 PageID #: 13489
`EE Document System SN76477 Page 4
`
`

`

`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 25 of 133 PageID #: 13490
`Case 1:10-cv-00258—SLR Document 590 Filed 12/09/15 Page 25 of 133 PageID #: 13490
`
`EXHIBIT D
`
`EXHIBIT D
`
`

`

`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 26 of 133 PageID #: 13491
`
`1-IC PROGRAMMABLE
`
`Need to control music or sound effects from software with(cid:173)
`out overtaxing your computer? Here are two new IC's that
`make it possible.
`
`BONAVENTURA ANTONY PATURZO
`
`Rf:AI.ISM IS ONE Of THE MAIN ATTRAC·
`tioos of the microprocessor-based games
`(handheld and video) that have become
`so popular in recent years. That realism
`is enhanced by the ingenious sound ef(cid:173)
`fects that are an important part of most
`of those games.
`Hobbyists and experimenters also
`want realism in their projects, but dupli(cid:173)
`cating those sound effects is not that
`easy. A microprocessor can create
`
`sounds with just a speaker. but con(cid:173)
`sidering the processor time required to
`sustain even a single note. it would be
`incapable of doing much else.
`General Instruments has developed
`two LSl circuits that have solved that
`problem. The AY-3-8910 and AY-3-8912
`PSG's (Programmable Sound Gen(cid:173)
`erator) are designed to work with a
`microprocessor/microcomputer to pro(cid:173)
`duce complex sounds under software
`
`control. The A Y-3-8910 has two 8-bit
`parallel ports and comes in a 40-lead
`DIP package. The AY-3-8912 has one
`port and 28 leads.
`The PSG's have a wide range of ap(cid:173)
`plications. Those devices can create a
`simple noise such as a gunshot or ex(cid:173)
`plosion for use with an electronic game,
`or they can create complex musical
`notes and chords for use with even
`high-end electronic instruments. You
`
`A9 AS
`
`r l-- w~rs
`I I
`I
`
`OA7·0A9
`
`RESET -[-
`
`RESET
`REGISTERS
`
`CLOCK
`
`AEGISTE R
`ADDRESS
`LATCH/
`DECODER
`
`REGISTER ARRAY
`(16 READ/WAITE
`CONTROL
`REGISTERS)
`
`LINES
`
`3x5LINES
`
`BLINES
`
`8LINES
`
`l/0 PORT
`A
`
`---l
`I l
`
`I
`I
`I
`I
`I
`
`I I
`I
`
`I
`
`I
`I
`I
`I
`I
`I
`I
`_J
`
`lOB7·lOBII
`
`IOA7·10A9
`
`FIG. 1-THE AY-3-8910 programmable sound genenitor from GeMral Instruments. The two 1/0 pons
`connect the host computer with the outside wortd.
`
`ANALOG
`CHANNEl
`A
`
`ANALOG ANALOG
`CHANNEL CHANNEL
`B
`C
`
`IJ)
`
`() z
`0 a:
`t5 w
`...J w
`6
`0
`£
`56
`
`

`

`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 27 of 133 PageID #: 13492
`
`SOUND GENERATOR
`
`may even want to use one of the PSG's
`to generate sound effects for
`the
`Unicorn- I robot. (Note: If you come up
`with a sound effects circuit for the
`Unicorn-/, send it to us at: Editorial
`Departinent, Rtulio-Electronics, 200
`Park A\•e. S., New York. NY /0003.
`We'll pass the better ones along to our
`readers-Editor.)
`To generate sounds. the host proces(cid:173)
`sor gives the PSG instructions as to
`what sound is to be produced by writing
`to specific registers within the PSG.
`Once dune. the processor is free to do
`other chores while the PSG generates
`the desired sounds.
`
`The PSG
`The A Y-3-8910/A Y -3-8912 contain
`the following sound generating blocks
`(Fig. 1):
`three square(cid:173)
`·Tone generators -
`wave generators which, depending
`on the clock frequency used, can
`produce tones from sub-audible to
`supra-audible in frequency.
`Noise generator - produces a fre(cid:173)
`quency-modulated pseudo-random
`pulse-width squarewave output.
`combine the outputs of
`Mixers -
`the tone generators and the noise
`generator (there's one mixer for
`eaci'T channel).
`provides the
`Amplitude control -
`internal 0/A (Digital to Analog) con(cid:173)
`verters with either a fixed or variable
`amplitude pattern. The fixed ampli(cid:173)
`tude pattern is under control of the
`CPU, while the variable amplitude
`pattern comes from use of the en(cid:173)
`velope generator.
`Envelope generator - provides am(cid:173)
`plitude modulation of the output
`from each mixer. Both shape and
`cycle of the envelope can be set by
`the user.
`0/A converters- the three convert(cid:173)
`ers each produce an output signal
`of up to 16 levels as determined by
`the amplitude control.
`Additionally, the 1/0 ports can be
`used to interface the host processor and
`the outside world. (Refer to Fig. 2 for
`a pin-out diagram of the PSG).
`Sixteen registers control the sound(cid:173)
`generating blocks and 1/0 ports of the
`PSG. Those registers are memory(cid:173)
`mapped and appear to the processor as
`a 16-word block out of 1024 possible
`addresses. The four low-order data/
`
`vtall ...
`&q.
`MMOl~·
`M¥111:1.-e A
`
`1$. -.... -... -
`
`AG. 2-PINOUT fot the AY-3-8910 lnd the AY- 3-8912 pt0gr8mmllble 10t1nd generators.
`
`TABLE 1
`
`BDIR
`0
`
`BC1
`1
`
`BC2
`0
`
`PSG FUNCTION
`INACTIVE -
`the PSG DA7-DAIII are in a high im(cid:173)
`pedance state.
`
`0
`
`READ FROM PSG - causes contents of currently ad(cid:173)
`dressed register to appear on DA7-DA0.
`
`• WRITE TO PSG -latch data on DA7-DAIII into current(cid:173)
`
`ly addressed register.
`
`LATCH ADDRESS- the PSG DA7-DA0 contain a reg(cid:173)
`ister address (select the register whose address ap(cid:173)
`pears on DA7-DA0).
`
`address bits on · the PSG (D0-DA3)
`select one of the 16 registers. Data/
`address bits DA4-DA7 must be low, pin
`AS must be high, and pin A9 must be
`low when selecting a register. After the
`desired register has been selected,
`DA0-DA7 are used for either a read(cid:173)
`from, or write-to, PSG operation. The
`bus direction input (BDIR-pin 18), BCI
`(pin 20), and BC2 (pin 19) are used to
`select whether to latch an address into
`the PSG, perform a write-to or read(cid:173)
`from PSG, or go into the inactive state.
`
`Table l summarizes the operations.
`Before going into the different opera(cid:173)
`tions of the PSG, it is necessary to un-
`. derstand the proper sequence of signals
`to and from the devices. During a
`register-addressing sequence, the bus
`controls (see Table I) should assume an
`"inactive" state and then a "latch
`address" state; the address is then
`placed on the bus, followed by an "in(cid:173)
`active" state. A write-to-PSG sequence
`would
`involve sending "inactive",
`placing the data on the bus. sending a
`
`> 'tl
`J)
`;=
`
`57
`
`

`

`-·
`Case 1:10-cv-00258-SLR Document 590 Filed 12/09/15 Page 28 of 133 PageID #: 13493
`fN =
`fcL0?-.
`16 NP10
`Where:
`fN =desired noise fre-
`quency
`fcLOCK = input clock fre(cid:173)
`quency
`NP10 =decimal equiva(cid:173)
`lent of the noise
`period register
`bits 64-80.
`
`5-BIT PERIOD CONTROL
`TONE
`B
`l1
`l1
`l1
`
`A
`L3
`LJ
`L3
`
`M
`M
`M
`
`c
`l2
`L2
`l2
`
`A
`LD
`Lll
`Ll
`
`R7
`
`ENABLE
`
`RID CHANNEL A AMPLITUDE
`Rll CHANNEL 8 AMPLITUDE
`R12 CHANNEL C AMPLITUDE
`R13
`
`ENVELOPE PERIOD
`
`ENVELOPE SHAPE/CYCLE
`R16 UO PORT A DATA STORE
`R17
`l/0 PORTB DATA STORE
`
`8·BIT PARALLEL l/0 PORT B
`
`FIG. 3-0ETAIL of the rud/wrl .. control realat..- ar111y ahown In Fig. 1. Note reglatera R16 and R17
`that rastore the parallel port taken up by the PSG and, in the cue of the AY-3-8810, add another.
`
`''write-to PSG" signal. and finally
`sending an "inactive" signal. A read(cid:173)
`from-PSG sequence involves sending
`"inactive", then a " read-from-PSG"
`signal, reading the data on the bus, and
`finally sending an "inactive" signal.
`Note that the read/write data sequences
`normally (though not necessarily) fol(cid:173)
`low the register-addressing operation.
`That allows for multiple reads and
`writes of the !klme register without re(cid:173)
`addressing.
`
`Operation
`Figure 3 shows the various register
`arrays contained within the PSG and
`their corresponding functions. Bits 87-
`80 correspond to OA7-0A0 once the
`specific register has been selected.
`As seen in Pig. 3, registers R0-R5
`con£rol the frequencies of the three
`tone generators. Note that each chan(cid:173)
`nel (the PSG has 3 independently-pro(cid:173)
`grammable analog output channels) has
`an eight-bit
`fine-tune and four-bit
`coarse-tune register. The equations for
`the tone frequency output are:
`
`1. fr "' fcLOCK
`16TP10
`2. TP10 = 256CT1o + FT1o
`
`Where:
`
`fr = desired tone fre-
`quency
`fcLOCK = input clock fre(cid:173)
`quency
`TP10 = decimal equiva(cid:173)
`lent of the tone
`period bits TP11-
`TP0.
`CT10 = decimal equiva(cid:173)
`lent of the coarse(cid:173)
`tune register bits
`63-60 (TP11 -
`TP8)
`FT1o = decimal equiva(cid:173)
`lent of the fine-
`
`C/)
`
`l> z
`0 a:
`t3 w
`.J w
`0
`~
`
`58
`
`tune register bits
`67-80 (TP7-
`TP0)
`
`Note that TP is the 12-bit combination
`of the coarse- and fine-tune registers.
`Equation 2 breaks TP into its comp