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`UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF FLORIDA
`ORLANDO DIVISION
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`Docket No. 3:11-CV-719
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` PARKERVISION, INC. :
` :
`Orlando, Florida
` Plaintiff :
`October 10, 2013
` :
`9:01 a.m.
` v. :
` :
`QUALCOMM, INCORPORATED :
` :
` Defendant :
`. . . . . . . . . . . . . . .
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`TRANSCRIPT OF JURY TRIAL
`DAY FOUR
`BEFORE THE HONORABLE ROY B. DALTON
`UNITED STATES DISTRICT JUDGE
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`RPX-Farmwald Ex. 1015, p 1
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`UNITED STATES DISTRICT COURT
`MIDDLE DISTRICT OF FLORIDA
`ORLANDO DIVISION
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`Docket No. 3:11-CV-719
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` PARKERVISION, INC. :
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`Orlando, Florida
` Plaintiff :
`October 10, 2013
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`9:01 a.m.
` v. :
` :
`QUALCOMM, INCORPORATED :
` :
` Defendant :
`. . . . . . . . . . . . . . .
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`TRANSCRIPT OF JURY TRIAL
`DAY FOUR
`BEFORE THE HONORABLE ROY B. DALTON
`UNITED STATES DISTRICT JUDGE
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`RPX-Farmwald Ex. 1015, p 1
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`APPEARANCES:
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`For the Plaintiff: Douglas A. Cawley
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` Joshua W. Budwin
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` Leah Buratti
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` Kevin Kneupper
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` Stephen D. Busey
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` Kevin Burgess
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`For the Defendant: Stephen C. Neal
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` Timothy S. Teter
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` John DeVault
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`Court Reporter:
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`Amie R. First, RPR, CRR
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`AmieFirst.CourtReporter@gmail.com
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`Proceedings recorded by mechanical stenography.
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`Transcript produced by Computer-Aided Transcription.
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`RPX-Farmwald Ex. 1015, p 2
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`08:38:47
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`P R O C E E D I N G S
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`THE COURT: Good morning, everyone. We're back on
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`the record in ParkerVision versus Qualcomm, Case Number
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`3:11-CV-719.
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`Counsel, ready to proceed?
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`MR. BUDWIN: Yes, Your Honor.
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`MR. NEAL: We are, Your Honor. We have a few
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`unobjected to exhibits that I would like to move in. I can
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`do it now or whenever else the Court would prefer.
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`THE COURT: Now is fine.
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`MR. NEAL: All right. We will move in
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`unobjected-to -- these are all DXs -- 85, 90, 113, 357,
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`428, 466, 713, 1106, 1109, 1112, 1276, and 1701,
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`Your Honor.
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`THE COURT: All right. Thank you, Mr. Neal.
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`(Defendant's Exhibit 85, 90, 113, 357, 428,
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` 466, 713, 1106, 1109, 1112, 1276, and 1701
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` were received in evidence.)
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`MR. NEAL: Thank you.
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`THE COURT: Dr. Prucnal, how is your voice this
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`morning?
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`THE WITNESS: It's on the mend. Thank you.
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`THE COURT: Bring our jury back, please,
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`Mr. Fiorenza.
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`(Jury entered the courtroom at 9:03 a.m.)
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`RPX-Farmwald Ex. 1015, p 3
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`THE COURT: Good morning, ladies and gentlemen. I
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`hope you all had a pleasant evening. Were all of you able
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`to follow my instructions not to discuss the case amongst
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`yourselves or with anyone else?
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`JURY: Yes.
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`THE COURT: Were you all able to avoid any media
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`exposure in connection with the case?
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`JURY: Yes.
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`THE COURT: All right. Are you ready to proceed,
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`Mr. Budwin?
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`MR. BUDWIN: Yes, Your Honor.
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`THE COURT: All right. You may inquire.
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`CONTINUED DIRECT EXAMINATION
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`BY MR. BUDWIN:
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`Q
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`Good morning, Dr. Prucnal.
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`Good morning.
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`How is your voice today?
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`I think it's a little better.
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`Maybe just move that mic a little closer to you.
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`Hopefully you and I can do a little better with that today.
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`Q
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`Okay.
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`Dr. Prucnal, yesterday I may have put the cart before
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`the horse, and I'd like to summarize a little bit, if
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`that's okay with you.
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`A
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`Okay.
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`RPX-Farmwald Ex. 1015, p 4
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`MR. BUDWIN: Can we get slide 104, please,
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`Mr. Moreno? And I think we checked that last element
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`yesterday before we left. Thanks.
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`BY MR. BUDWIN:
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`Now, Dr. Prucnal, what is a patent claim?
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`A patent claim defines the boundaries of the patent.
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`And are the claims important?
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`Sorry. Go ahead.
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`Are the claims important?
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`The claims are very important, yes.
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`And why is that?
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`Because the claims define what the patent is.
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`Now, is what we see here a patent claim?
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`Yes.
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`Which patent is this a claim from?
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`This is the '518.
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`Now, are there other patents and other claims that
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`you'll show us in your analysis?
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`A
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`Yes.
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`What is the claim construction?
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`The claim construction is the Court's definition of
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`certain terms within the claims.
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`Is the claim construction important?
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`Yes, it's important.
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`And why is that?
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`RPX-Farmwald Ex. 1015, p 5
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`Because it's important to understand what the claim
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`terms mean.
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`And have you followed the claim constructions in your
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`analysis?
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`Q
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`Yes.
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`Now, Dr. Prucnal, why have you put checks next to each
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`element of claim 82 of '518 patent?
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`A
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`In the analysis that we went through yesterday, we --
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`I went through each of these claim elements and found the
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`elements in the accused product and checked it off when I
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`did.
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`Q
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`And what do the checks next to each claim element
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`prove with respect to claim 82 in the '518 patent and the
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`accused products in this case?
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`Q
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`That this claim is infringed by the accused products.
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`What do the schematics that you showed us yesterday
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`represent?
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`A
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`These schematics represent the circuits that are
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`within the accused products.
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`Q
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`And I may not have been clear about this, but whose
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`schematics are they?
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`A
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`Q
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`Those are schematics from Qualcomm.
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`Are they confidential?
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`Yes.
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`Now, when we were looking at the schematics yesterday,
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`RPX-Farmwald Ex. 1015, p 6
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`we saw that they were printed on this yellow paper. Do you
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`understand why they were printed on this yellow paper?
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`Yes.
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`Why is that?
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`They're confidential documents. It's to distinguish
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`them from other documents. And, in addition, at the bottom
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`of each page, there is a statement of confidentiality.
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`Q
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`And, Dr. Prucnal, do you have an understanding as to
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`why we had to look at the schematics on the ELMO instead of
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`on the screen?
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`A
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`Yes. These are not in electronic form for us. These
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`are hard, paper copies.
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`Q
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`To your understanding, were we allowed to make
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`electronic copies of the schematics?
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`A
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`Q
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`I understand that we were not.
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`Now, what do the design documents that you showed us
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`yesterday represent?
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`A
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`Those are also confidential documents from Qualcomm
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`describing the chips.
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`Q
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`Now, to your knowledge, was Mr. Sorrells permitted to
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`showed them in court yesterday?
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`Q
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`Not to my knowledge.
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`Now, why did you get access to them?
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`Because I've entered into a confidentiality agreement.
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`RPX-Farmwald Ex. 1015, p 7
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`Q
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`Was it important in your analysis of Qualcomm's
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`infringement to review both the schematics and the design
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`documents?
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`A
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`Q
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`A
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`Yes.
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`Why is that?
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`This provides the information that I need to find the
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`elements of the claim in the accused products.
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`Q
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`And would you have been comfortable asserting
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`infringement merely by looking at high level block diagrams
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`of the accused products?
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`A
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`Q
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`A
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`No.
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`Why not?
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`High-level documents could lack the necessary detail.
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`Now, in addition to claim 82 in the '518 patent, do
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`the accused products infringe the other asserted claims?
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`Yes.
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`MR. BUDWIN: Can I see slide 106 please,
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`Mr. Moreno?
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`BY MR. BUDWIN:
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`Q
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`What is this showing us, Dr. Prucnal?
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`This shows the -- the asserted patents and claims.
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`And which claim did you show us already, Dr. Prucnal?
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`That was 82, claim 82 of the '518.
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`And so can we put a check next to that one as well?
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`Yes.
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`RPX-Farmwald Ex. 1015, p 8
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`Q
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`Now, Dr. Prucnal, are there some similarities between
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`some of the other asserted claims and claim 82 of the '518
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`patent?
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`A
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`Q
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`Yes.
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`And do those similarities enable you to provide an
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`analysis maybe a little bit more quickly than what we
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`walked through for the one claim yesterday?
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`A
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`Q
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`Yes.
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`And have you prepared a demonstrative graphic to help
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`explain that?
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`A
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`Yes.
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`09:08:41
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`12
`
`MR. BUDWIN: Can I see slide 107, please,
`
`09:08:44
`
`13
`
`Mr. Moreno?
`
`09:08:45
`
`14
`
`BY MR. BUDWIN:
`
`09:08:46
`
`15
`
`09:08:48
`
`16
`
`Q
`
`A
`
`Dr. Prucnal, what are you showing us here?
`
`On the left-hand side is claim 82, which was just
`
`09:08:52
`
`17
`
`discussed. And on the right-hand side is claim 90.
`
`09:08:57
`
`18
`
`Q
`
`So let me stop you there. So the left-hand side, is
`
`09:08:59
`
`19
`
`this the claim that you already showed us?
`
`09:09:02
`
`20
`
`09:09:02
`
`21
`
`09:09:05
`
`22
`
`09:09:06
`
`23
`
`A
`
`Q
`
`A
`
`Q
`
`Yes.
`
`And is the right-hand side a new claim?
`
`Yes.
`
`And then I see some color coding. What does the color
`
`09:09:09
`
`24
`
`coding represent?
`
`09:09:10
`
`25
`
`A
`
`The color coding indicates the analogy between
`
`RPX-Farmwald Ex. 1015, p 9
`
`
`
` 10
`
`09:09:15
`
` 1
`
`elements of claim 82 and the same or similar elements of
`
`09:09:20
`
` 2
`
`claim 90.
`
`09:09:21
`
` 3
`
`Q
`
`And so by proving all of the elements of claim 82 of
`
`09:09:24
`
` 4
`
`the '518 patent, as you did yesterday, have you already
`
`09:09:28
`
` 5
`
`proven some of the elements of claim 90 of the '518 patent?
`
`09:09:32
`
` 6
`
`09:09:33
`
` 7
`
`09:09:33
`
` 8
`
`A
`
`Q
`
`A
`
`Yes.
`
`Which elements?
`
`The ones that are shown in the -- that are colored on
`
`09:09:36
`
` 9
`
`the right-hand side.
`
`09:09:37
`
`10
`
`Q
`
`And for the benefit of the record, it's the first four
`
`09:09:40
`
`11
`
`elements of claim 90 of the '518 patent?
`
`09:09:43
`
`12
`
`A
`
`Yes.
`
`09:09:44
`
`13
`
`MR. BUDWIN: And so if I could see slide 108,
`
`09:09:46
`
`14
`
`please, Mr. Moreno.
`
`09:09:48
`
`15
`
`BY MR. BUDWIN:
`
`09:09:48
`
`16
`
`09:09:51
`
`17
`
`09:09:54
`
`18
`
`Q
`
`A
`
`Q
`
`What is this, Dr. Prucnal?
`
`This is claim 90 with its elements shown.
`
`Now, in light of the color coding on the prior side,
`
`09:09:57
`
`19
`
`can we go ahead and check the first four elements here?
`
`09:10:00
`
`20
`
`A
`
`Yes.
`
`09:10:00
`
`21
`
`MR. BUDWIN: And can we do that, please,
`
`09:10:02
`
`22
`
`Mr. Moreno?
`
`09:10:04
`
`23
`
`I guess maybe we don't have that ability.
`
`09:10:08
`
`24
`
`BY MR. BUDWIN:
`
`09:10:09
`
`25
`
`Q
`
`So the first four elements you've already shown us?
`
`RPX-Farmwald Ex. 1015, p 10
`
`
`
` 11
`
`09:10:12
`
` 1
`
`09:10:13
`
` 2
`
`A
`
`Q
`
`Yes.
`
`And that's the same evidence that you've shown us and
`
`09:10:16
`
` 3
`
`explained to us yesterday?
`
`09:10:17
`
` 4
`
`09:10:17
`
` 5
`
`09:10:19
`
` 6
`
`09:10:20
`
` 7
`
`A
`
`Q
`
`A
`
`Q
`
`Yes.
`
`And what do you have to show us now?
`
`The final elements of the claim.
`
`And what's the final element of the claim?
`
`09:10:23
`
` 8
`
`MR. BUDWIN: Oh, I should have asked you, in
`
`09:10:24
`
` 9
`
`advance, to slide 109, Mr. Moreno. Sorry. And put the
`
`09:10:29
`
`10
`
`checks in. There we go.
`
`09:10:32
`
`11
`
`BY MR. BUDWIN:
`
`09:10:32
`
`12
`
`Q
`
`And so what do you have left to show us, just the last
`
`09:10:35
`
`13
`
`element?
`
`09:10:36
`
`14
`
`A
`
`Yes.
`
`09:10:36
`
`15
`
`MR. BUDWIN: Can I see slide 110, please,
`
`09:10:38
`
`16
`
`Mr. Moreno?
`
`09:10:39
`
`17
`
`BY MR. BUDWIN:
`
`09:10:40
`
`18
`
`Q
`
`Dr. Prucnal, this claim recites a means for impedance
`
`09:10:44
`
`19
`
`matching at least one of said first signal and said second
`
`09:10:47
`
`20
`
`signal?
`
`09:10:47
`
`21
`
`09:10:48
`
`22
`
`A
`
`Q
`
`09:10:51
`
`23
`
`term?
`
`09:10:52
`
`24
`
`09:10:52
`
`25
`
`A
`
`Q
`
`Yes.
`
`And are there claim constructions applicable to this
`
`There are.
`
`And which claim constructions?
`
`RPX-Farmwald Ex. 1015, p 11
`
`
`
` 12
`
`09:10:54
`
` 1
`
`A
`
`Impedance matching and means for impedance matching at
`
`09:10:58
`
` 2
`
`least one of said first signal and said second signal.
`
`09:11:01
`
` 3
`
`Q
`
`And has the Court provided us with the definition of
`
`09:11:03
`
` 4
`
`means for impedance-matching term?
`
`09:11:05
`
` 5
`
`09:11:06
`
` 6
`
`A
`
`Q
`
`Yes.
`
`It says, has the function of impedance matching the
`
`09:11:09
`
` 7
`
`first or second signal such that the desired power is
`
`09:11:12
`
` 8
`
`transferred and the structure is an arrangement of
`
`09:11:17
`
` 9
`
`circuitry to transfer the desired power.
`
`09:11:19
`
`10
`
`A
`
`Yes.
`
`09:11:20
`
`11
`
`MR. BUDWIN: Can we advance to slide 111, please,
`
`09:11:23
`
`12
`
`Mr. Moreno?
`
`09:11:23
`
`13
`
`BY MR. BUDWIN:
`
`09:11:25
`
`14
`
`Q
`
`Now, Dr. Prucnal, what evidence do you have that the
`
`09:11:29
`
`15
`
`accused products have a means for impedance matching at
`
`09:11:32
`
`16
`
`least one of said first signal and said second signal?
`
`09:11:36
`
`17
`
`A
`
`That would be contained in the circuit diagrams in the
`
`09:11:39
`
`18
`
`technical documents.
`
`09:11:20
`
`19
`
`MR. BUDWIN: Well, let's -- if I could have the
`
`09:11:42
`
`20
`
`ELMO briefly, please, I'd like to go back to some of the
`
`09:11:46
`
`21
`
`circuit diagrams.
`
`09:11:41
`
`22
`
`BY MR. BUDWIN:
`
`09:11:20
`
`23
`
`Q
`
`So this is PX-847.
`
`09:11:57
`
`24
`
`And in particular -- in particular, schematic page
`
`09:12:02
`
`25
`
`1999.
`
`RPX-Farmwald Ex. 1015, p 12
`
`
`
` 13
`
`09:12:07
`
` 1
`
`Now, Dr. Prucnal, this is one of the pages you showed
`
`09:12:09
`
` 2
`
`us yesterday. What do we see here as related to the means
`
`09:12:13
`
` 3
`
`for impedance matching in the claim limitation?
`
`09:12:19
`
` 4
`
`A
`
`Well, we see the capacitors at the output, for
`
`09:12:23
`
` 5
`
`example.
`
`09:12:29
`
` 6
`
`Q
`
`And you're talking about these capacitors here that
`
`09:12:33
`
` 7
`
`you described to us yesterday?
`
`09:12:35
`
` 8
`
`09:12:36
`
` 9
`
`A
`
`Q
`
`Yes.
`
`Now, Dr. Prucnal, if we look to schematic page 2003
`
`09:12:40
`
`10
`
`from the same exhibit, do we see additional evidence
`
`09:12:46
`
`11
`
`related to the means for impedance-matching term?
`
`09:12:49
`
`12
`
`09:12:51
`
`13
`
`09:12:53
`
`14
`
`A
`
`Q
`
`A
`
`Yes.
`
`What do we see?
`
`We see the transimpedance amplifiers which have the
`
`09:13:00
`
`15
`
`feedback circuit that I described yesterday.
`
`09:13:04
`
`16
`
`09:13:08
`
`17
`
`09:13:08
`
`18
`
`Q
`
`A
`
`Q
`
`So that's TIA I and TIA Q?
`
`Yes.
`
`And are those separate transimpedance amplifiers for
`
`09:13:11
`
`19
`
`each in phase in --
`
`09:13:11
`
`20
`
`09:13:12
`
`21
`
`A
`
`Q
`
`Yes.
`
`Now, you mentioned feedback. What was the feedback,
`
`09:13:14
`
`22
`
`just to refresh your memory?
`
`09:13:15
`
`23
`
`A
`
`That's the path from the output of the amplifier back
`
`09:13:20
`
`24
`
`to the input of the amplifier.
`
`09:13:22
`
`25
`
`Q
`
`And what does that feedback path mean with respect to
`
`RPX-Farmwald Ex. 1015, p 13
`
`
`
` 14
`
`09:13:26
`
` 1
`
`the impedance?
`
`09:13:27
`
` 2
`
`A
`
`Well, this is a transimpedance amplifier. And the
`
`09:13:30
`
` 3
`
`feedback path provides low impedance at the input of the
`
`09:13:35
`
` 4
`
`TIA.
`
`09:13:36
`
` 5
`
`Q
`
`Now, remind us, what's the significance of low
`
`09:13:39
`
` 6
`
`impedance?
`
`09:13:42
`
` 7
`
`A
`
`The significance of low impedance is this is a path
`
`09:13:43
`
` 8
`
`through which current can flow.
`
`09:13:45
`
` 9
`
`MR. BUDWIN: And, Mr. Moreno, can we see JX-62 at
`
`09:13:49
`
`10
`
`page 17, please?
`
`09:13:50
`
`11
`
`BY MR. BUDWIN:
`
`09:13:50
`
`12
`
`Q
`
`This is one of the documents that you showed us
`
`09:13:52
`
`13
`
`yesterday.
`
`09:13:53
`
`14
`
`BY MR. BUDWIN:
`
`09:13:54
`
`15
`
`Q
`
`Now, Dr. Prucnal, remind us what we're seeing here.
`
`09:13:56
`
`16
`
`And can we make sure to get the first line here?
`
`09:14:05
`
`17
`
`09:14:08
`
`18
`
`A
`
`Q
`
`This is a high-level diagram of the receiver circuit.
`
`Is this the high-level diagram of the same circuit you
`
`09:14:11
`
`19
`
`were showing us in the schematics?
`
`09:14:13
`
`20
`
`09:14:14
`
`21
`
`A
`
`Q
`
`Yes.
`
`Now, what's the -- where is the transimpedance
`
`09:14:20
`
`22
`
`amplifier in this figure?
`
`09:14:22
`
`23
`
`A
`
`The transimpedance amplifier is located inside the box
`
`09:14:26
`
`24
`
`that says signal pull.
`
`09:14:31
`
`25
`
`Q
`
`Here and here?
`
`RPX-Farmwald Ex. 1015, p 14
`
`
`
` 15
`
`09:14:33
`
` 1
`
`09:14:33
`
` 2
`
`A
`
`Q
`
`Yes.
`
`Can you determine by looking at this page what the
`
`09:14:35
`
` 3
`
`significance of the low impedance is?
`
`09:14:37
`
` 4
`
`09:14:38
`
` 5
`
`09:14:39
`
` 6
`
`A
`
`Q
`
`A
`
`Yes.
`
`Can you explain that, please?
`
`Well, the low impedance and the transimpedance input
`
`09:14:45
`
` 7
`
`to the transimpedance amplifier enables the flow of current
`
`09:14:50
`
` 8
`
`out of the transmit filter, which is the capacitor, and
`
`09:14:56
`
` 9
`
`into the next stage.
`
`09:14:58
`
`10
`
`09:15:00
`
`11
`
`Q
`
`A
`
`And how do you know that?
`
`That's indicated by -- that's indicated by the flow of
`
`09:15:05
`
`12
`
`current right here we have from the mixer output to the
`
`09:15:08
`
`13
`
`transmit filter output. And the transmit filter output is
`
`09:15:11
`
`14
`
`going into the baseband filter or TIA.
`
`09:15:18
`
`15
`
`Q
`
`Now, by looking at the schematic pages you just showed
`
`09:15:21
`
`16
`
`us, and by looking at this design document, can you
`
`09:15:23
`
`17
`
`conclude whether the means for impedance matching at least
`
`09:15:27
`
`18
`
`one of said first signal and said second signal limitation
`
`09:15:30
`
`19
`
`of claim 90, the '518 patent, is met?
`
`09:15:34
`
`20
`
`09:15:34
`
`21
`
`09:15:36
`
`22
`
`A
`
`Q
`
`A
`
`Yes.
`
`And what did you determine?
`
`That it is met.
`
`09:15:37
`
`23
`
`MR. BUDWIN: Can I see slide 114, please,
`
`09:15:40
`
`24
`
`Mr. Moreno?
`
`09:15:41
`
`25
`
`BY MR. BUDWIN:
`
`RPX-Farmwald Ex. 1015, p 15
`
`
`
` 16
`
`09:15:42
`
` 1
`
`09:15:44
`
` 2
`
`Q
`
`A
`
`So can I check that box, Dr. Prucnal?
`
`Yes.
`
`09:15:44
`
` 3
`
`MR. BUDWIN: And can I have slide 115, Mr. Moreno?
`
`09:15:46
`
` 4
`
`BY MR. BUDWIN:
`
`09:15:47
`
` 5
`
`09:15:50
`
` 6
`
`Q
`
`A
`
`And can we go ahead and check claim 90?
`
`Yes.
`
`09:15:50
`
` 7
`
`MR. BUDWIN: So I'd like to move on now to claim
`
`09:15:52
`
` 8
`
`91 of the '518 patent, and in particular slide 116.
`
`09:15:59
`
` 9
`
`BY MR. BUDWIN:
`
`09:16:00
`
`10
`
`Q
`
`Now, Dr. Prucnal, the first limitation I see here is
`
`09:16:02
`
`11
`
`the apparatus of claim 90.
`
`09:16:05
`
`12
`
`09:16:05
`
`13
`
`09:16:07
`
`14
`
`09:16:09
`
`15
`
`09:16:10
`
`16
`
`09:16:13
`
`17
`
`09:16:15
`
`18
`
`09:16:19
`
`19
`
`09:16:22
`
`20
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`Yes.
`
`Is this a particular type of a claim?
`
`Yes, it is.
`
`What kind of a claim is this?
`
`This is called a dependent claim.
`
`And what does it mean to be a dependent claim?
`
`This claim depends upon everything in claim 90.
`
`And have you already shown us claim 90, Dr. Prucnal?
`
`Yes.
`
`09:16:22
`
`21
`
`MR. BUDWIN: So, Mr. Moreno, if we could advance
`
`09:16:24
`
`22
`
`to slide 117.
`
`09:16:26
`
`23
`
`BY MR. BUDWIN:
`
`09:16:28
`
`24
`
`Q
`
`Does that mean we can go ahead and check the first
`
`09:16:30
`
`25
`
`element because you've already shown us claim 90?
`
`RPX-Farmwald Ex. 1015, p 16
`
`
`
` 17
`
`09:16:33
`
` 1
`
`09:16:34
`
` 2
`
`A
`
`Q
`
`Yes.
`
`Now, this claim adds the requirement wherein the
`
`09:16:37
`
` 3
`
`aperture periods are substantially greater than zero such
`
`09:16:40
`
` 4
`
`that energy transferred is to such an extent that accurate
`
`09:16:44
`
` 5
`
`voltage reproduction of the first signal is prevented?
`
`09:16:47
`
` 6
`
`A
`
`Yes.
`
`09:16:49
`
` 7
`
`MR. BUDWIN: And if we could advance to slide 118,
`
`09:16:51
`
` 8
`
`please, Mr. Moreno.
`
`09:16:53
`
` 9
`
`BY MR. BUDWIN:
`
`09:16:53
`
`10
`
`Q
`
`Are there any claim constructions applicable to this
`
`09:16:56
`
`11
`
`claim element from claim 91?
`
`09:16:58
`
`12
`
`09:16:58
`
`13
`
`09:17:02
`
`14
`
`A
`
`Q
`
`A
`
`No.
`
`Can you remind us what the aperture periods are?
`
`The aperture period is the period during which the
`
`09:17:06
`
`15
`
`switch is closed so that energy is transferred from the
`
`09:17:09
`
`16
`
`carrier signal to the baseband.
`
`09:17:11
`
`17
`
`Q
`
`Now, Dr. Prucnal, what's your understanding about the
`
`09:17:14
`
`18
`
`last part of this limitation where it says energy is
`
`09:17:17
`
`19
`
`transferred to such an extent that accurate voltage
`
`09:17:21
`
`20
`
`reproduction of the first signal is prevented?
`
`09:17:26
`
`21
`
`A
`
`Well, my understanding is that because the switch is
`
`09:17:28
`
`22
`
`closed for a long time, it is allowing the carrier signal
`
`09:17:33
`
`23
`
`to flow in for a long time, and causing it to be smeared
`
`09:17:37
`
`24
`
`out and stored in the capacitor.
`
`09:17:40
`
`25
`
`Q
`
`Can you explain maybe a little bit more what you mean
`
`RPX-Farmwald Ex. 1015, p 17
`
`
`
` 18
`
`09:17:43
`
` 1
`
`with respect to some of the prior art or prior circuits
`
`09:17:46
`
` 2
`
`that we discussed previously?
`
`09:17:52
`
` 3
`
`A
`
`Well, I showed an example yesterday of prior art,
`
`09:17:56
`
` 4
`
`which was a voltage sampler, and the invention, which is an
`
`09:18:01
`
` 5
`
`energy transfer sampler.
`
`09:18:05
`
` 6
`
`And in the voltage sampler, there were very quick and
`
`09:18:08
`
` 7
`
`accurate samples taken of the input signal. The switch
`
`09:18:14
`
` 8
`
`closed and opened very quickly. And during that time, a
`
`09:18:17
`
` 9
`
`very small piece of the input signal was taken so that it
`
`09:18:19
`
`10
`
`was an accurate sample.
`
`09:18:22
`
`11
`
`Whereas, during the -- with the energy sampler, the
`
`09:18:25
`
`12
`
`switch was closed for a long time. That allowed more
`
`09:18:28
`
`13
`
`transfer of energy but smeared out the signal that was
`
`09:18:31
`
`14
`
`being transferred.
`
`09:18:32
`
`15
`
`09:18:36
`
`16
`
`09:18:36
`
`17
`
`Q
`
`A
`
`Q
`
`Dr. Prucnal, the word here is aperture periods?
`
`Yes.
`
`Can we analogize the aperture here to an aperture in
`
`09:18:41
`
`18
`
`something people might be familiar with, like a camera?
`
`09:18:44
`
`19
`
`09:18:44
`
`20
`
`09:18:50
`
`21
`
`A
`
`Q
`
`A
`
`Yes.
`
`Can you explain what you mean?
`
`Well, a camera has a shutter, which is like a switch
`
`09:18:54
`
`22
`
`letting light go into it. And the time during which the
`
`09:18:56
`
`23
`
`switch is open in that case is called the aperture. That
`
`09:18:59
`
`24
`
`allows the images to flow in, the energy from the light to
`
`09:19:03
`
`25
`
`flow in.
`
`RPX-Farmwald Ex. 1015, p 18
`
`
`
` 19
`
`09:19:03
`
` 1
`
`Q
`
`And you mentioned in your answer something about
`
`09:19:05
`
` 2
`
`smearing. Using your camera analogy, can you explain a
`
`09:19:08
`
` 3
`
`little bit more about what you mean by that?
`
`09:19:11
`
` 4
`
`A
`
`Sure. With a camera, for example, if you're operating
`
`09:19:16
`
` 5
`
`at low light levels, you can open up the aperture and cause
`
`09:19:21
`
` 6
`
`the shutter to be open for a long period of time. That
`
`09:19:25
`
` 7
`
`lets more light in.
`
`09:19:27
`
` 8
`
`But if you were taking a picture of a fast-moving
`
`09:19:32
`
` 9
`
`image, say, for example, a picture of a hummingbird with
`
`09:19:36
`
`10
`
`the wings flapping very quickly, if the aperture -- if the
`
`09:19:41
`
`11
`
`shutter is open, if the aperture period is long, then one
`
`09:19:44
`
`12
`
`wouldn't resolve that quick motion. It would just get
`
`09:19:47
`
`13
`
`smeared out, even though one could take that photograph at
`
`09:19:50
`
`14
`
`low light levels.
`
`09:19:52
`
`15
`
`Q
`
`And, Dr. Prucnal, does the patent provide a discussion
`
`09:19:55
`
`16
`
`of this claim limitation?
`
`09:19:58
`
`17
`
`A
`
`Yes.
`
`09:19:59
`
`18
`
`MR. BUDWIN: Can I see PX-2? And maybe we should
`
`09:20:03
`
`19
`
`go first to the front page of PX-2 so it's clear what we're
`
`09:20:08
`
`20
`
`talking about.
`
`09:20:09
`
`21
`
`BY MR. BUDWIN:
`
`09:20:09
`
`22
`
`09:20:11
`
`23
`
`Q
`
`A
`
`Is this the '518 patent?
`
`Yes.
`
`09:20:12
`
`24
`
`MR. BUDWIN: And can we go to column 66 at lines
`
`09:20:16
`
`25
`
`38 to 46, please, Mr. Moreno? It's 38 to 46, column 66.
`
`RPX-Farmwald Ex. 1015, p 19
`
`
`
` 20
`
`09:20:37
`
` 1
`
`BY MR. BUDWIN:
`
`09:20:38
`
` 2
`
`Q
`
`I'll read the first part of this, Dr. Prucnal, and
`
`09:20:39
`
` 3
`
`maybe you can read the second part.
`
`09:20:39
`
` 4
`
`It says, in the energy transfer environment --
`
`09:20:41
`
` 5
`
`THE COURT: Read a little more slowly.
`
`09:20:43
`
` 6
`
`BY MR. BUDWIN:
`
`09:20:45
`
` 7
`
`Q
`
`In the energy transfer environment, the storage module
`
`09:20:48
`
` 8
`
`illustrated in figure 82 as the storage capacitance
`
`09:20:51
`
` 9
`
`preferably has the capacity to handle power being
`
`09:20:54
`
`10
`
`transferred and to allow it to accept a non-negligible
`
`09:20:56
`
`11
`
`amount of power during a non-negligible aperture period.
`
`09:21:00
`
`12
`
`Do you see that?
`
`09:21:01
`
`13
`
`09:21:02
`
`14
`
`09:21:03
`
`15
`
`A
`
`Q
`
`A
`
`Yes.
`
`And what's that describing?
`
`That's indicating that the storage capacitance has to
`
`09:21:05
`
`16
`
`be sufficiently large to handle the charge being
`
`09:21:09
`
`17
`
`transferred in it over a period of time that's
`
`09:21:13
`
`18
`
`non-negligible.
`
`09:21:15
`
`19
`
`Q
`
`And then the second part reads, this allows the
`
`09:21:18
`
`20
`
`storage capacitance to store energy transferred from the
`
`09:21:22
`
`21
`
`input EM signal.
`
`09:21:25
`
`22
`
`What's an EM signal?
`
`09:21:27
`
`23
`
`09:21:28
`
`24
`
`A
`
`Q
`
`That's electromagnetic signal.
`
`Without substantial concern for accurately reproducing
`
`09:21:31
`
`25
`
`the original unaffected voltage level of the input EM
`
`RPX-Farmwald Ex. 1015, p 20
`
`
`
` 21
`
`09:21:36
`
` 1
`
`signal?
`
`09:21:36
`
` 2
`
`09:21:37
`
` 3
`
`A
`
`Q
`
`Yes.
`
`Is this a description of what you just explained to us
`
`09:21:39
`
` 4
`
`with respect to the camera and the aperture periods?
`
`09:21:43
`
` 5
`
`09:21:43
`
` 6
`
`A
`
`Q
`
`Yes.
`
`Now, Dr. Prucnal --
`
`09:21:46
`
` 7
`
`MR. BUDWIN: And, Mr. Moreno, if we could switch
`
`09:21:47
`
` 8
`
`back to the slide deck and advance back to slide 120.
`
`09:21:52
`
` 9
`
`BY MR. BUDWIN:
`
`09:21:52
`
`10
`
`Q
`
`Do you have evidence that the accused products have
`
`09:21:55
`
`11
`
`aperture periods that are substantially greater than zero
`
`09:22:00
`
`12
`
`such that accurate voltage reproduction is prevented?
`
`09:22:05
`
`13
`
`09:22:07
`
`14
`
`A
`
`Q
`
`Yes.
`
`Dr. Prucnal, have you already shown us some of the
`
`09:22:09
`
`15
`
`schematic pages with the capacitors?
`
`09:22:11
`
`16
`
`09:22:11
`
`17
`
`A
`
`Q
`
`Yes.
`
`And was that the PX-847 at 1999?
`
`09:22:17
`
`18
`
`You can consult your deck up there if you need to.
`
`09:22:20
`
`19
`
`A
`
`Yes.
`
`09:22:23
`
`20
`
`MR. BUDWIN: And now, Mr. Moreno, if we can go
`
`09:22:25
`
`21
`
`back to JX-62.
`
`09:22:31
`
`22
`
`BY MR. BUDWIN:
`
`09:22:31
`
`23
`
`Q
`
`And, in particular, let's just look first at page 17.
`
`09:22:34
`
`24
`
`It's the same diagram we've been talking about.
`
`09:22:37
`
`25
`
`A
`
`Yes.
`
`RPX-Farmwald Ex. 1015, p 21
`
`
`
` 22
`
`09:22:40
`
` 1
`
`Q
`
`Can you conclude by looking at this diagram as to
`
`09:22:43
`
` 2
`
`whether this claim limitation is satisfied, in part?
`
`09:22:48
`
` 3
`
`09:22:49
`
` 4
`
`09:22:51
`
` 5
`
`09:22:56
`
` 6
`
`A
`
`Q
`
`A
`
`Q
`
`Yes, in part.
`
`Okay. Why?
`
`Because this shows energy transfer into the capacitor.
`
`And do you also need to know some additional
`
`09:22:58
`
` 7
`
`information?
`
`09:22:59
`
` 8
`
`A
`
`Yes.
`
`09:23:00
`
` 9
`
`MR. BUDWIN: And can we go to page 26 of the same
`
`09:23:02
`
`10
`
`document, Mr. Moreno?
`
`09:23:04
`
`11
`
`BY MR. BUDWIN:
`
`09:23:06
`
`12
`
`Q
`
`And I believe you described this figure and the
`
`09:23:08
`
`13
`
`diagram next to it to us yesterday. But can you just
`
`09:23:12
`
`14
`
`refresh our memory briefly?
`
`09:23:15
`
`15
`
`A
`
`This shows the arrangement of the transistor switches
`
`09:23:18
`
`16
`
`inside of the mixer. And the switches are controlled to
`
`09:23:23
`
`17
`
`close during aperture periods which are defined by the
`
`09:23:27
`
`18
`
`local oscillator waveform at the upper right.
`
`09:23:30
`
`19
`
`Q
`
`Now, what on this page shows the aperture periods are
`
`09:23:33
`
`20
`
`substantially greater than zero?
`
`09:23:36
`
`21
`
`A
`
`The shape of a local oscillator waveform, as well as
`
`09:23:39
`
`22
`
`the 25 DC that describes their shape.
`
`09:23:43
`
`23
`
`Q
`
`And by looking at the prior page that you showed with
`
`09:23:47
`
`24
`
`the current transfer, can you determine as to whether
`
`09:23:49
`
`25
`
`energy is transferred to such an extent that voltage
`
`RPX-Farmwald Ex. 1015, p 22
`
`
`
` 23
`
`09:23:52
`
` 1
`
`reproduction is prevented?
`
`09:23:56
`
` 2
`
`A
`
`Of the original signal, yes.
`
`09:24:00
`
` 3
`
`MR. BUDWIN: Can we see slide 124 please,
`
`09:24:04
`
` 4
`
`Mr. Moreno?
`
`09:24:05
`
` 5
`
`BY MR. BUDWIN:
`
`09:24:06
`
` 6
`
`Q
`
`Dr. Prucnal, have you proven that the additional
`
`09:24:07
`
` 7
`
`requirement of claim 91 is satisfied?
`
`09:24:10
`
` 8
`
`09:24:10
`
` 9
`
`09:24:12
`
`10
`
`09:24:14
`
`11
`
`A
`
`Q
`
`A
`
`Q
`
`Yes.
`
`Can we check this box?
`
`Yes.
`
`And if we can move on to slide 125, now we've shown
`
`09:24:18
`
`12
`
`claim 91.
`
`09:24:24
`
`13
`
`And I'd like to move on to claim 27 of the '518
`
`09:24:28
`
`14
`
`patent, which should be slide 126.
`
`09:24:32
`
`15
`
`09:24:33
`
`16
`
`09:24:35
`
`17
`
`09:24:36
`
`18
`
`A
`
`Q
`
`A
`
`Q
`
`09:24:39
`
`19
`
`yet?
`
`09:24:46
`
`20
`
`09:24:47
`
`21
`
`A
`
`Q
`
`Okay.
`
`And it starts, the method according to claim one?
`
`Yes.
`
`Now, have you shown us claim one of the '518 patent
`
`Can I go back to the checklist?
`
`Let me help you out. You haven't shown us claim one
`
`09:24:50
`
`22
`
`of the '518 patent, have you?
`
`09:24:52
`
`23
`
`09:24:53
`
`24
`
`A
`
`Q
`
`No, I didn't think so.
`
`Okay. And do you have an understanding as to whether
`
`09:24:55
`
`25
`
`claim one of the '518 patent is individually asserted?
`
`RPX-Farmwald Ex. 1015, p 23
`
`
`
` 24
`
`09:25:00
`
` 1
`
`09:25:02
`
` 2
`
`A
`
`Q
`
`I believe it is not.
`
`But, nonetheless, do we still have to show that its
`
`09:25:05
`
` 3
`
`elements are met to prove claim 27?
`
`09:25:08
`
` 4
`
`A
`
`Yes.
`
`09:25:08
`
` 5
`
`MR. BUDWIN: And can I see slide 127?
`
`09:25:10
`
` 6
`
`BY MR. BUDWIN:
`
`09:25:11
`
` 7
`
`Q
`
`Now, there's several elements here for claim one of
`
`09:25:13
`
` 8
`
`the '518 patent?
`
`09:25:15
`
` 9
`
`09:25:16
`
`10
`
`A
`
`Q
`
`Yes.
`
`Now, again, have you prepared a demonstrative that
`
`09:25:18
`
`11
`
`will help us see which of these elements have already been
`
`09:25:21
`
`12
`
`proven by the other evidence?
`
`09:25:23
`
`13
`
`A
`
`Yes.
`
`09:25:24
`
`14
`
`MR. BUDWIN: And can I see slide 128?
`
`09:25:26
`
`15
`
`BY MR. BUDWIN:
`
`09:25:26
`
`16
`
`Q
`
`This is probably going to be one of our favorite
`
`09:25:29
`
`17
`
`slides of the day.
`
`09:25:30
`
`18
`
`What are you showing us here, Dr. Prucnal?
`
`09:25:32
`
`19
`
`A
`
`We're going to show correspondence between claim 82,
`
`09:25:34
`
`20
`
`which I've already discussed, and claim one. And color
`
`09:25:37
`
`21
`
`coded are the elements of claim one that are similar or
`
`09:25:43
`
`22
`
`identical to claim 82.
`
`09:25:45
`
`23
`
`Q
`
`And so by proving claim 82 of the '518 patent, have
`
`09:25:48
`
`24
`
`you also proven all of the elements of claim one of the
`
`09:25:51
`
`25
`
`'518 patent?
`
`RPX-Farmwald Ex. 1015, p 24
`
`
`
` 25
`
`09:25:52
`
` 1
`
`A
`
`Yes.
`
`09:25:53
`
` 2
`
`MR. BUDWIN: Can we see slide 129, Mr. Moreno?
`
`09:25:57
`
` 3
`
`BY MR. BUDWIN:
`
`09:25:57
`
` 4
`
`09:25:59
`
` 5
`
`09:26:00
`
` 6
`
`Q
`
`A
`
`Q
`
`So can we check the first limitation?
`
`Yes.
`
`Now, the next limitation is further comprising the
`
`09:26:03
`
` 7
`
`step of transferring energy to a load during the off-time?
`
`09:26:09
`
` 8
`
`A
`
`Yes.
`
`09:26:09
`
` 9
`
`MR. BUDWIN: And if we advance to slide 130.
`
`09:26:12
`
`10
`
`BY MR. BUDWIN:
`
`09:26:13
`
`11
`
`Q
`
`Are there any claim constructions that are applicable
`
`09:26:15
`
`12
`
`to this term?
`
`09:26:16
`
`13
`
`09:26:18
`
`14
`
`A
`
`Q
`
`No.
`
`Now, if we look back to the patent, which is PX-2 at
`
`09:26:24
`
`15
`
`figure 82A, can you explain to us briefly what it means,
`
`09:26:28
`
`16
`
`transferring energy to a load during the off-time?
`
`09:26:35
`
`17
`
`A
`
`Yes. When the switch is closed, the energy is
`
`09:26:40
`
`18
`
`transferred into the capacitor and that's the on-time.
`
`09:26:45
`
`19
`
`During the off-time, the switch is open. And during
`
`09:26:47
`
`20
`
`that time, the capacitor is discharged into the load. And
`
`09:26:52
`
`21
`
`that's transferring energy.
`
`09:26:54
`
`22
`
`Q
`
`And is that con
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