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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ---o0o---
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________________________
`
`APPLE INC., HTC CORPORATION, HTC )
`
`AMERICA, INC., SAMSUNG ELECTRONICS)
`
`CO. LTD, SAMSUNG ELECTRONICS )
`
`AMERICA, INC., AND AMAZON.COM, )
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`INC., )
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` Petitioners, ) Case Nos.
`
`vs. ) IPR2015-00163
`
`MEMORY INTEGRITY, LLC, ) IPR2015-00159
`
` Patent Owner. ) IPR2015-00158
`
`__________________________________) Patent 7,296,121
`
` VIDEOTAPED DEPOSITION OF VOJIN OKLOBDZIJA, Ph.D.
`
` Redwood City, California
`
` Friday, January 8, 2016
`
` Volume I
`
`Reported by:
`
`CATHERINE A. RYAN
`
`CSR No. 8239
`
`Job No. 2211885
`
`PAGES 1 - 183
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`Page 1
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`

`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ---o0o---
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________________________
`
`APPLE INC., HTC CORPORATION, HTC )
`
`AMERICA, INC., SAMSUNG ELECTRONICS)
`
`CO. LTD, SAMSUNG ELECTRONICS )
`
`AMERICA, INC., AND AMAZON.COM, )
`
`INC., )
`
` Petitioners, ) Case Nos.
`
`vs. ) IPR2015-00163
`
`MEMORY INTEGRITY, LLC, ) IPR2015-00159
`
` Patent Owner. ) IPR2015-00158
`
`__________________________________) Patent 7,296,121
`
` Videotaped Deposition of VOJIN OKLOBDZIJA,
`
`Ph.D., Volume I, taken on behalf of Petitioners, at
`
`500 Arguello Street, Suite 500, Redwood City,
`
`California, beginning at 9:57 a.m. and ending at
`
`5:22 p.m., on Friday, January 8, 2016, before
`
`CATHERINE A. RYAN, Certified Shorthand Reporter No.
`
`8239.
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`

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`APPEARANCES:
`
`For Patent Owner Memory Integrity, LLC:
`
` FARNEY DANIELS P.C.
`
` BY: MICHAEL D. SAUNDERS
`
` Attorney at Law
`
` 411 Borel Avenue, Suite 350
`
` San Mateo, California 94402
`
` (424) 268-5200
`
` (424) 268-5219 Fax
`
` msaunders@farneydaniels.com
`
`For Petitioners Apple Inc., HTC Corporation, HTC
`
`America, Inc., Samsung Electronics Company Limited,
`
`Samsung Electronics America, Inc., and Amazon.com,
`
`Inc.:
`
` FISH & RICHARDSON P.C.
`
` BY: MICHAEL RUECKHEIM
`
` Attorney at Law
`
` 1221 McKinney Street, Suite 2800
`
` Houston, Texas 77010
`
` (713) 654-5343
`
` (713) 652-0109 Fax
`
` rueckheim@fr.com
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`APPEARANCES (Continued):
`
`For Petitioners Apple Inc., HTC Corporation, HTC
`
`America, Inc., Samsung Electronics Company Limited,
`
`Samsung Electronics America, Inc., and Amazon.com,
`
`Inc.:
`
` FISH & RICHARDSON P.C.
`
` BY: DAVID L. HOLT
`
` Attorney at Law
`
` 1425 K Street, N.W., 11th Floor
`
` Washington, D.C. 20005
`
` (202) 783-5070
`
` (202) 783-2331 Fax
`
` david.holt@fr.com
`
`For Petitioners Sony Corporation, Sony Electronics,
`
`Inc., Sony Mobile Communications AB, and Sony Mobile
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`Communications U.S.A., Inc.:
`
` KENYON & KENYON
`
` BY: ZAED M. BILLAH (appearing telephonically)
`
` Attorney at Law
`
` One Broadway
`
` New York, New York 10004-1007
`
` (212) 425-7200
`
` (212) 425-5288 Fax
`
` zbillah@kenyon.com
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`

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` A P P E A R A N C E S ( C o n t i n u e d ) :
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` A l s o P r e s e n t :
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` R O B E R T W . H O R S T , P h . D .
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` S E A N G R A N T , V i d e o g r a p h e r , V e r i t e x t
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`

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` INDEX
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`WITNESS EXAMINATION
`
`VOJIN OKLOBDZIJA, Ph.D.
`
`Volume I
`
` BY MR. RUECKHEIM 10
`
` BY MR. SAUNDERS 157
`
` BY MR. RUECKHEIM 175
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` EXHIBITS
`
`NUMBER DESCRIPTION PAGES
`
`Exhibit 1 "Declaration of Vojin Oklobdzija, 13
`
` Ph.D. in Support of Patent Owner's
`
` Replies in Support of Motions to
`
` Amend"; 18 pages
`
`Exhibit 2 "Directory-Based Cache Coherence"; 127 14
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` pages
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`Exhibit 3 "The SGI Origin: A ccNUMA Highly 15
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` Scalable Server"; 11 pages
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`

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` EXHIBITS (CONTINUED)
`
`NUMBER DESCRIPTION PAGES
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`Exhibit 4 "Memory Integrity, LLC's Appendix of 22
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` Claims in Support of Its Motion to
`
` Amend [37 CFR 42.121(b)]"; 8 pages
`
`Exhibit 5 "Opposition Declaration of Dr. Robert 29
`
` Horst"; 18 pages
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`Exhibit 6 "United States Patent, Patent No.: US 44
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` 7,296,121 B2, Morton et al., Date of
`
` Patent: Nov. 13, 2007"; Bates APPLE
`
` 1001; 43 pages
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`

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` Redwood City, California; Friday, January 8, 2016
`
` 9:57 a.m.
`
` THE VIDEOGRAPHER: Good morning. We're on
`
`the record. The time is 9:57 A.M., and the date is 09:57:32
`
`January 8th, 2016. This begins the videotaped
`
`deposition of Dr. Vojin Oklobzija. My name is Sean
`
`Grant, here with our court reporter Catherine Ryan.
`
`We're here from Veritext Legal Solutions at the
`
`request of counsel for Petitioner. This deposition 09:57:50
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`is being held at Fish & Richardson, P.C., in Redwood
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`City, California.
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` The caption of this case is Apple Inc.,
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`HTC Corporation, HTC America, Inc., Samsung
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`Electronics Company Limited, Samsung Electronics 09:58:06
`
`America, Inc., and Amazon.com, Inc., versus Memory
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`Integrity, LLC, Case No. IPR-2015-00163.
`
` Please note that audio and video recording
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`will take place unless all parties have agreed to go
`
`off the record. Microphones are sensitive and may 09:58:27
`
`pick up whispers, private conversations or cellular
`
`interference.
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` At this time will counsel please identify
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`themselves and state whom they represent.
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` MR. RUECKHEIM: Michael Rueckheim from 09:58:40
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`Fish & Richardson. With me today is David Holt and 09:58:42
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`Dr. Robert Horst, and I am representing Apple Inc.,
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`HTC Corporation, HTC America, Inc., Samsung
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`Electronics Company Limited, Samsung Electronics
`
`America, Inc., and Amazon.com, Inc. 09:58:57
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` And one correction before we go on. This
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`deposition is in relation to IPR2015-00163 in
`
`addition to IPR2015-00159 and IPR2015-00158.
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` THE VIDEOGRAPHER: Thank you.
`
` MR. RUECKHEIM: And then we have counsel 09:59:24
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`on the phone. Zaed, do you --
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` MR. BILLAH: Hello. Zaed Billah from
`
`Kenyon & Kenyon, representing Sony Corporation, Sony
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`Electronics, Inc., Sony Mobile Communications AB,
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`and Sony Mobile Communications U.S.A., Inc. 09:59:40
`
` MR. SAUNDERS: And I'm Michael Saunders of
`
`Farney Daniels. I am representing Patent Owner
`
`Memory Integrity, LLC, and also the witness.
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` THE VIDEOGRAPHER: Thank you. Will the
`
`certified court reporter please swear in the 09:59:54
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`witness.
`
` VOJIN OKLOBDZIJA, Ph.D.,
`
`having been administered an oath, was examined and
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`testified as follows:
`
` THE VIDEOGRAPHER: Counsel. 10:00:10
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` EXAMINATION 10:00:10
`
`BY MR. RUECKHEIM:
`
` Q Dr. Oklobdzija, good morning.
`
` A Good morning.
`
` Q Would you please state and spell your name 10:00:15
`
`for the record.
`
` A My name is -- first name is Vojin,
`
`V-o-i-n. It's phonetic spelling. And last name is
`
`Oklobdzija. The phonetic would be O-k-l-o-b-j-i-a.
`
` Q And can you also provide the nonphonetic 10:00:30
`
`spelling, I guess, the actual spelling.
`
` A V-o-j-i-n. The last name is
`
`O-k-l-o-b-d-z-i-j-a.
`
` Q And do you understand that you're under
`
`oath -- under oath today to tell the truth? 10:00:43
`
` A I do.
`
` Q Is there any reason why you couldn't
`
`provide full and accurate, truthful testimony today?
`
` A No.
`
` Q And so you and I met in November of last 10:00:52
`
`year for a deposition; correct?
`
` A October.
`
` Q Was it October? We met in either October
`
`or November of last year for a deposition; correct?
`
` A Okay. Oh, it was -- yeah, it was, I 10:01:04
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`think, end of November. That's right. 10:01:06
`
` Q Okay.
`
` A Correct.
`
` Q And we went over some -- some general
`
`ground rules for depositions at that point, but I'm 10:01:14
`
`just going to restate them here so we're both clear.
`
`Does that makes sense?
`
` A Yes.
`
` Q Okay. So generally if -- if I ask a
`
`question and -- which is unclear, please let me know 10:01:21
`
`that the question is unclear or if there's a certain
`
`part that you don't understand. Is that okay?
`
` A Yes, I will.
`
` Q Okay. And, again, if you need a break for
`
`any reason, let me know. Is that okay? 10:01:33
`
` A I may need more breaks because I'm ill,
`
`obviously, so ...
`
` Q It shouldn't be a problem. At any time --
`
` A Thank you. Appreciate it.
`
` Q Are you -- you know, you mentioned that 10:01:46
`
`you're ill. Are you taking any medication today
`
`that you think would affect your ability to give
`
`truthful testimony?
`
` A I'm taking Tylenols, but I don't think it
`
`will affect the truthful testimony. 10:01:59
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` Q Okay. 10:02:02
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` A It may affect my thinking, but --
`
` Q Okay. Well, I mean, so that's -- that's a
`
`concern. I mean, do you -- I want to make sure that
`
`you don't believe that the medication that you're 10:02:11
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`taking right now is going to somehow affect your
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`thinking as far as responding to questions and
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`providing accurate testimony. Do we need a break
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`today and rejoin at a different time?
`
` A I didn't get it. Do I need a break? 10:02:27
`
` Q Well, I -- you said that you were taking
`
`Tylenol --
`
` A Right.
`
` Q -- just over-the-counter Tylenol.
`
` A Yeah, I'm taking some. 10:02:33
`
` Q Okay. And you said that it might affect
`
`your --
`
` A I've got the flu. Right.
`
` Q You said it might affect your thinking.
`
` A I may be a little bit slow, but I think 10:02:39
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`the correctness of my thinking should not be
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`affected.
`
` Q Okay. And if there's any -- at any time
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`you believe that the medication is affecting you in
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`a way that you can't provide accurate testimony, 10:02:48
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`will you let me know? 10:02:51
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` A Yes, I will let you know. I will ask for
`
`a break.
`
` MR. RUECKHEIM: Great.
`
` THE VIDEOGRAPHER: Mark it again? 10:03:19
`
` MR. RUECKHEIM: Yes, please.
`
` (Exhibit 1 was marked for identification
`
` by the court reporter.)
`
`BY MR. RUECKHEIM:
`
` Q Dr. Oklobdzija, the videographer has 10:03:46
`
`handed you what is Oklobdzja deposition Exhibit 1.
`
`It's the -- Exhibit 1 is -- bears a title
`
`"Declaration of Vojin Oklobdzja, Ph.D., in Support
`
`of Patent Owner's Replies in Support of Motions to
`
`Amend," and it looks like the last page of Exhibit 10:04:08
`
`1, which is numbered 18, bears the signature of
`
`yourself and bears the date of December 31st, 2015.
`
` Do you have Exhibit 1 in front of you?
`
` A Yes, I do.
`
` Q And what is Exhibit 1? 10:04:28
`
` A This is my declaration in support of the
`
`motion to amend.
`
` Q And on top of Exhibit 1 it references case
`
`numbers IPR2015-00158, IPR2015-00159, and
`
`IPR2015-00163. 10:04:50
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` A That's correct. 10:04:54
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` Q Okay. Can you please turn to paragraph 9
`
`in Exhibit 1. And if I refer to Exhibit 1 as your
`
`motion to amend reply declaration, would that
`
`terminology make sense? 10:05:17
`
` A If you -- if you refer to this as Exhibit
`
`1? Yes.
`
` Q Well, if I refer to Exhibit 1 as your
`
`motion to amend reply declaration, will that
`
`terminology make sense? 10:05:29
`
` A Yes. Yes.
`
` Q All right. Okay. So in paragraph 9 of
`
`your motion to amend reply declaration you mentioned
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`SGI's Origin system; correct?
`
` A Correct. 10:05:48
`
` Q When you refer to the Origin system, are
`
`you referring to the description of the Origin
`
`system as provided in the Culler and Laudon
`
`references that are part of the pending IPR
`
`proceedings? 10:06:04
`
` A I am referring to that one as well as the
`
`paper published by Laudon and Dan Lenoski, I
`
`believe.
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` MR. RUECKHEIM: Okay.
`
` (Exhibit 2 was marked for identification 10:06:38
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` by the court reporter.) 10:06:38
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` THE VIDEOGRAPHER: 2.
`
` THE WITNESS: Thank you.
`
`BY MR. RUECKHEIM:
`
` Q Dr. Oklobdzja, the videographer has handed 10:06:48
`
`you deposition Exhibit 2. It's a paper that bears
`
`the No. 8 at the top, and the title on the first
`
`page of "Directory-Based Cache Coherence" and
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`appears to be -- well, on the second page on the top
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`it bears the title "Chapter 8, Directory-Based Cache 10:07:17
`
`Coherence," page 554, and on the last page of this
`
`exhibit the top of the page bears the title "8.12
`
`Exercises," page 677.
`
` Do you have deposition Exhibit 2 in front
`
`of you? 10:07:35
`
` A Yes, I do.
`
` Q And does this relate to the Culler,
`
`spelled C-u-l-l-e-r, reference that is part of the
`
`IPR proceedings?
`
` A Yes, I recognize this as the chapter 8 10:07:46
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`from David Culler's book, which I own. So I do
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`recognize that chapter.
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` (Exhibit 3 was marked for identification
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` by the court reporter.)
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` THE VIDEOGRAPHER: 3. 10:08:11
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` THE WITNESS: Thank you. 10:08:13
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`BY MR. RUECKHEIM:
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` Q Dr. Oklobdzja, the videographer has handed
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`you deposition Exhibit 3, which is a paper that
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`bears the title "The SGI Origin, a ccNUMA Highly 10:08:21
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`Scalable Server."
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` A Yes, I recognize the paper. That's the
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`paper I just mentioned by Laudon and Lenoski.
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` Q Have you reviewed deposition Exhibit 2
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`prior to preparing your motion to amend reply 10:08:44
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`declaration?
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` A Yes, I did review the Exhibit 2 and
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`Exhibit 3.
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` Q Does Exhibit 2 discuss the Origin system
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`that is referenced in Petitioner's motion to amend 10:09:06
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`opposition?
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` MR. SAUNDERS: Objection. Form.
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` THE WITNESS: Exhibit 2 discusses the
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`paper published, which is Exhibit 3. So they both
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`talk about the SGI Origin system. 10:09:25
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`BY MR. RUECKHEIM:
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` Q Okay. And have you reviewed any other
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`materials that describe the SGI Origin system?
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` MR. SAUNDERS: Objection. Form.
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` THE WITNESS: I can't testify to that. I 10:09:42
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`may have, but I have no recollection at this point. 10:09:45
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`BY MR. RUECKHEIM:
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` Q So after we met in either October or
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`November of last year for your deposition, how much
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`time have you spent in preparing your motion to 10:10:08
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`amend reply declaration?
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` A Again, on top of my head, I have the
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`answer for the previous question you asked me --
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`November -- because I checked it up, but this one I
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`didn't check, but I would say about 20 hours. 10:10:32
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` Q So just for clarity, you have spent 20
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`hours performing any work relating to the present
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`IPR proceedings since your deposition in October or
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`November of last year?
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` A Okay. So let's make it clear. I think 10:10:53
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`deposition was November.
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` Q Okay. Going with that --
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` A I believe so. Right?
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` Q I'm actually -- I have no idea. I'm not
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`going to lie. 10:11:01
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` A Neither do I.
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` Q Okay. But after the last time we met --
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` A Right.
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` Q -- and you were deposed --
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` A Right. 10:11:07
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` Q -- I want the record to be clear that your 10:11:08
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`testimony is that you have spent 20 hours relating
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`to the present IPR proceedings?
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` A That's correct. Right.
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` Q Okay. 10:11:15
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` A That would be December and part of
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`November.
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` Q Okay. And how much --
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` A And part of January, of course.
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` Q Of that time, how much time would you say 10:11:23
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`was spent in preparing for today's deposition?
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` A If the subject of today's deposition is my
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`declaration, I would say the entire 20 hours.
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` Q How much time of that 20 hours was spent
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`after you prepared your motion to amend reply 10:11:43
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`declaration?
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` A After the Exhibit 1 was filed?
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` Q Correct.
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` A Meaning January. Probably seven -- seven
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`hours. 10:12:05
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` Q Seven. So it's fair to say, if I'm doing
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`the math right, you spent about 13 hours in
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`preparing your motion to amend reply declaration?
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` A Probably not. I think I spent 20 hours in
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`December and part of November and then another seven 10:12:21
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` Q Okay. So I want -- so turning back to
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`paragraph 9 in Exhibit 1, so in this paragraph 9 of
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`Exhibit 1 you state that "Petitioners are vague with
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`respect to whether they contend that the hub is 10:12:53
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`outside of or is subsumed within a processing node."
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`Correct?
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` A That is correct.
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` Q What do you mean by "subsumed"?
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` A What I mean is whether the processing node 10:13:11
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`includes the hub or the hub is outside of the
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`processing node.
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` Q Is it -- would the processing node --
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`strike that.
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` Have you offered an opinion in your 10:13:45
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`declaration as to whether the hub in the Origin
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`system is included in the processing node or is
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`external to the processing node?
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` MR. SAUNDERS: Objection. Form.
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` THE WITNESS: In my declaration? 10:14:01
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`BY MR. RUECKHEIM:
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` Q Correct.
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` A I think that in my declaration I am
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`considering both cases. One is that the processing
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`node is what would be in figure 815, Exhibit 2, 10:14:13
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`page 598, would be the square that is adjacent to 10:14:27
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`interconnection network, which contains two
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`processors, their caches SysAD bus hub, and the four
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`gigabyte of main memory, including a directory. So
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`whether that is a node -- considered a processing 10:14:49
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`node or the processing node is just the processor
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`and the cache, which is part of that piece in
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`there ...
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` Q So my question is a little different. My
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`question was -- well, let me strike that. 10:15:14
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` I understand you to say that in your
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`declaration you addressed both scenarios as to
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`whether the hub is internal or external to the
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`processing node; correct?
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` A Whether the hub is subsumed or part of the 10:15:30
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`processing node or whether the hub is external to
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`the processing node, yeah. I think both scenarios,
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`to my recollection, are considered in my
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`declaration.
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` Q But you haven't provided an opinion one 10:15:41
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`way or the other as to whether the hub is internal
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`to a processing node or external to a processing
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`node; correct?
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` MR. SAUNDERS: Objection. Form.
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` THE WITNESS: I did not provide the 10:15:53
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`opinion. I -- I considered both scenarios. 10:15:58
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`BY MR. RUECKHEIM:
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` Q Would you consider a hub to be part of a
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`processing node if it was part of the same board
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`that comprised a processing node? 10:16:23
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` MR. SAUNDERS: Objection. Form.
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` THE WITNESS: I... I didn't need to
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`render my opinion about that. One can consider a
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`node to be the one that contains the hub and both
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`processors' main memory or one can consider the 10:17:03
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`processing node just to be the same processor. So I
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`think it's a matter of, you know, how one is going
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`to treat the system.
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`BY MR. RUECKHEIM:
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` Q So you said that one can consider a node 10:17:19
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`to be -- contain a hub or one could consider the
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`node to not contain a hub; it's just a matter of how
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`one is going to treat the system; correct?
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` A Yeah, pretty much.
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` Q By "treat the system," do you mean that 10:17:36
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`whether a hub is internal or external to a
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`processing node is a matter of semantics?
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` MR. SAUNDERS: Objection. Form.
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` THE WITNESS: I think to some extent,
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`right. You know, whether they would consider that 10:17:56
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`to be a node, the whole entire thing, two 10:17:57
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`processors' hub, main memory and directory, or just
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`the individual processor, it's -- yeah, it's a
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`matter of definition, I guess.
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`BY MR. RUECKHEIM: 10:18:14
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` Q Let's turn to the paragraph 12 in your
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`motion to amend reply declaration, which is
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`deposition Exhibit 1. So the very bottom line on
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`page 10, which is part of this paragraph 12 of the
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`Exhibit 1, states: "However, if the hub is not 10:19:16
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`within a processing node, then the hub at the home
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`node of the SGI Origin is not receiving probes from
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`the processing nodes. It is receiving a request
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`from another hub."
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` Did I read that correctly? 10:19:37
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` A That is correct, right.
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` (Exhibit 4 was marked for identification
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` by the court reporter.)
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` THE WITNESS: Thank you.
`
` THE VIDEOGRAPHER: 4. 10:20:06
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`BY MR. RUECKHEIM:
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` Q Dr. Oklobdzja, the videographer has handed
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`you deposition Exhibit 4, which is a document that
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`bears the title "Patent No. --" well, at the top of
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`Exhibit 4 it says "Patent No. 7,296,121 10:20:21
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`IPR2015-00159," and it bears the title on the first 10:20:23
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`page "Memory Integrity LLC's Appendix of Claims in
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`Support of Its Motion to Amend."
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` Do you have deposition Exhibit 4 in front
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`of you? 10:20:42
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` A I do.
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` Q Do you know what deposition Exhibit 4 is?
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` A It's appendix of claims --
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` Q Do you --
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` A -- in the -- in the motion to amend -- 10:20:50
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` Q Do you understand --
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` A -- so new claims.
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` Q So you understand that these are the
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`substitute claims that Memory Integrity are -- is
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`proposing in the present IPR proceedings? 10:20:59
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` A That is correct.
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` Q So with regards, again, to your paragraph
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`12 in your motion to amend reply declaration, when
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`you reference the hub not receiving probes from the
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`processing nodes, is there any specific language in 10:21:29
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`the substitute claims that you're referring to?
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` A Okay. Let me just ... Is there any
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`substitute language referring to the hub?
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` Q So you said "substitute." I said
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`"specific." So let me try it again. 10:22:04
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` In this paragraph 12 of your motion to 10:22:06
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`amend reply declaration you state -- you reference
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`the SGI Origin not receiving probes from the
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`processing nodes, and I'm wondering if you -- it's
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`your opinion that that relates to certain claim 10:22:21
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`language in the substitute claims.
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` A In which particular substitute claims?
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` Q Let's say substitute claim 26.
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` A Let me read it --
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` Q Okay. 10:22:35
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` A -- if I may.
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` (Pause.)
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` So your question is whether that paragraph
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`12, the cited sentence, has any relation with
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`substitute claim 26? 10:23:30
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` Q Correct.
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` A I don't see much relation because there is
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`no hub in the substitute claim 26.
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` Q Do you understand that Petitioners are
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`asserting that the hub in the SGI Origin system 10:23:42
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`relates to the probe filtering unit in the
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`substitute claims?
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` A Do I understand that Petitioner --
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` Q Are asserting that the hub --
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` A Hub -- 10:23:56
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` Q -- in the SGI Origin system relates to the 10:23:56
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`probe filtering unit in the substitute claims?
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` A I do understand that the petitioner does
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`what you say, assert that the hub relates to probe
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`filtering unit. I do. 10:24:14
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` Q Okay. Actually, let me -- I can make this
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`more clear.
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` So in paragraph 12 the second sentence
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`says that "As a threshold issue, the claims require
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`that the probe filtering unit being operable to 10:24:35
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`receive probes corresponding to memory lines from
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`the processing nodes."
`
` Did I read that correctly?
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` A Yes.
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` Q So for the opinions you're offering in 10:24:46
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`paragraph 12, do they relate to this claim language
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`of the probe filtering unit being operable to
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`receive probes corresponding to memory lines from
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`the processing nodes?
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` A Yes, if I can read, "the probe filtering 10:25:05
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`unit being operable to receive probes corresponding
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`to memory lines from the processing nodes and to
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`transmit the probes only to selected ones of the
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`processing nodes with reference to the probe
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`filtering information representative of the states 10:25:19
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`associated with" et cetera, et cetera. That's -- 10:25:23
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`I'm reading the substitute claim 26.
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` Q Okay. So is it -- are you offering the
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`opinion in paragraph 12 that the SGI Origin system
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`does not meet the substitute claims because the hub 10:25:42
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`in the SGI origin system receives a probe from a hub
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`as opposed to a processing node?
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` A That is correct. What I said is the hub
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`is not within the processing mode -- node and
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`receives probes not from the processing node, but 10:26:16
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`from another hub. So it's a hub-to-hub
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`communication, not internal processing node.
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` Q But the Origin system does describe that
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`the probe coming from the first hub in this
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`hub-to-hub transmission comes from a processor; 10:26:36
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`correct?
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` MR. SAUNDERS: Objection. Form.
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` THE WITNESS: Can you point to me where
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`does it say so?
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`BY MR. RUECKHEIM: 10:26:56
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` Q You don't remember from your review of the
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`materials discussed in the Origin system?
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` A I don't remember off -- on the top of my
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`head, you know, exactly where.
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` Q So from your memory of the Origin system 10:27:12
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`the hub in one processing node can send a probe to 10:27:15
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`another hub without it resulting from transmission
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`from a processor?
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` MR. SAUNDERS: Objection. Form.
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` THE WITNESS: My recollection is the hub 10:27:26
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`is more complex and contains several interfaces, et
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`cetera. So it's a different communication protocol.
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`BY MR. RUECKHEIM:
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` Q Well, if you look at your paragraph 12 --
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`so this is on -- the portion of this paragraph 10:27:48
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`that's on page 11 of your declaration --
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` A Okay.
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` Q -- you state that "This is because
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`processors in the SGI Origin can only communicate
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`with each other through hubs." Do you see that? 10:28:03
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` A I -- I do.
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` Q So are you saying here that a processor in
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`one processing node will send a probe to a hub and
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`that hub will only be able to communicate that probe
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`to another processor by sending the probe to another 10:28:19
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`hub?
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` A What I'm saying here in the continuation
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`of that sentence in parentheses, that the PI hides
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`the processors from the rest of the world. So any
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`other interface must only know whether the behavior 10:28:39
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`themself.
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` So this is a communication -- hub-to-hub
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`communication which hides the processor -- isolates
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`the processor. I think that

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