`IPR2015-00159
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC., HTC CORPORATION, HTC AMERICA, INC., SAMSUNG
`ELECTRONICS CO. LTD, SAMSUNG ELECTRONICS AMERICA, INC.,
`SAMSUNG TELECOMMUNICATIONS AMERICA, LLC AND
`AMAZON.COM, INC.
`Petitioners
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`v.
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`MEMORY INTEGRITY, LLC
`Patent Owner
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`U.S. Patent No. 7,296,121
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`Inter Partes Review Case No. 2015-00159
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`PATENT OWNER MEMORY INTEGRITY, LLC’S RESPONSE TO
`PETITIONERS’ MOTION FOR OBSERVATION
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`Response to Observation #1: Petitioners’ Observation #1 is improper because
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`rather than addressing the deponent’s testimony, Petitioners seek to clarify
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`ambiguities in their own opposition to the motion to amend. In particular,
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`Petitioners now argue that their opposition has an “application of the individual
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`R10000 processor in the Origin system to the claimed ‘processing node.’”
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`Petitioners also mischaracterize Dr. Oklobdzija’s opinions and testimony as
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`demonstrating that such application is “valid.” Dr. Oklobdzija said nothing of the
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`sort—he merely said either scenario could be considered. Ex. 1032 at 21:3-13.
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`Indeed, Dr. Oklobdzija substantively addressed both scenarios—(1) where the
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`“processing node” was limited to the SGI Origin’s processors (Ex. 2042 ¶¶ 12-15),
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`and (2) where the “processing node” also included the local hub chip (Ex. 2042 ¶¶
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`10-11). Dr. Oklobdzija’s opinions demonstrate each scenario fails to render the
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`proposed substitute claims unpatentable.
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`Response to Observation #2: Petitioners’ Observation #2 mischaracterizes Dr.
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`Oklobdzija’s opinions and testimony as “not consider[ing] ‘where the probe in a
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`hub-to-hub transmission originates from.’” To the contrary, Dr. Oklobdzija
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`testified that the probe comes from the hub chip itself. Ex. 1032 at 29:14-16,
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`38:10-16, 161:21-162:13. Moreover, the question’s implied suggestion that a
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`requesting node’s hub chip’s probes must have originated from elsewhere made no
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`sense in light of Dr. Oklobdzija’s opinions, which noted that (1) “[t]he processor in
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`the requesting node is connected to a hub in the requesting node via a ‘SysAD
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`bus.’ . . . [while], the hubs in SGI Origin communicate with each other via a
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`‘Craylink’ interface,” (Ex. 2042 ¶ 13); (2) “the hub chip has significant logic
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`between these interfaces, which among other things, ‘hides the processors from the
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`rest of the world, so any other interface must only know the behavior of the PI
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`[processor interface] and not of the processor and SysAD bus themselves,’” (id.)
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`(3) “in some instances, there is not even a one-to-one relationship between the
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`processor’s outgoing messages and the outgoing messages from the hub” (id.), and
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`(4) that the “processors are ignorant about” “at least some details of the cache
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`coherent protocol” for “which the hub is responsible for implementing” (id.). This
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`is consistent with Dr. Oklobdzija’s deposition testimony. Ex. 1032 at 26:25-28:7.
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`Thus, there is no “alternative source” for a probe that need to be identified and
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`nothing in Dr. Oklobdzija’s testimony suggests that the probes received by a home
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`node’s hub chip are the same as sent by a processor.
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`Response to Observation #3: Petitioners mischaracterize Dr. Oklobdzija’s
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`testimony as somehow demonstrating that “a change in a probe’s message format
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`is not relevant to the limitations of the substitute claims.” However, just because
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`the ’121 Patent does not describe or claim a “specific” message format, that does
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`not imply that the format of messages (i.e. of an alleged probe) is not “relevant” in
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`determining whether the probe received by the alleged probe filtering unit (i.e. the
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`hub chip of the home node) is the same probe as sent by a processor. Dr.
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`Oklobdzija’s declaration explained how “transport formats,” in addition to
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`“protocols, and speeds,” relate to the claim limitation “the probe filtering unit
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`being operable to receive probes corresponding to memory lines from the
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`processing nodes,” Ex. 2042 ¶¶ 12-13. In particular, he opined that “if the hub is
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`not within a processing node, then the hub at the home node is not receiving probes
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`from the processing nodes, it is receiving a request from another hub.” Id. ¶ 12.
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`The discussion of message formats relate to addressing the potential
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`counterargument that “Petitioners may argue that the hub in the home node is
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`receiving a probe ‘from the processing node’ because ultimately a request sent by
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`the requesting node’s hub is due to a processor’s cache miss.” Id. ¶ 13. The
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`questions in the cited deposition testimony wholly failed to attempt to address
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`those opinions. Thus, there is nothing inconsistent between Dr. Oklobdzija’s
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`testimony that he was not relying on a particular message format from the ’121
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`Patent’s specification, and his discussion of message formats in the context of his
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`opinion that, in SGI Origin, probes sent by a requesting node’s processor are not
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`the same “probe” as received by a home node’s hub chip.
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`Response to Observation #4: Observation #4 is a misleading non-sequitur.
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`Petitioners cite testimony of Dr. Oklobdzija acknowledging that the ’121 Patent
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`allegedly describes an embodiment using different point-to-point protocols on
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`different point-to-point links. Petitioners conclude that this demonstrates that “a
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`change in a probe’s message format is not relevant to the limitations of the
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`substitute claims.” To the contrary, Dr. Oklobdzija expressly noted that it would
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`“not necessarily” be the case that “two different point-to-point protocols” would
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`even cause “the probe [to] change.” Ex. 1032 at 75:10-19. Moreover, Petitioners’
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`argument is entirely divorced from the language of the substitute claims, and
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`improperly attempts to read in one potential embodiment into all of the claims
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`contrary to their plain language. Dr. Oklobdzija explained in his declaration how a
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`change in message formats was one of several factors (including protocols and
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`speeds) that demonstrates that SGI Origin’s home node hub chip is not “operable
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`to receive probes corresponding to memory lines from the processing nodes” (Ex.
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`2042 ¶¶ 12-13) and the cited testimony does not attempt to substantively discuss
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`those opinions or the claim language upon which Dr. Oklobdzija relied.
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`Response to Observation #5: Again Petitioners mischaracterize Dr. Oklobdzija’s
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`testimony and opinions. Rather than testifying that read requests are “passed
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`through the hub,” Dr. Oklobdzija expressly disagreed with that characterization
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`and testified that the PI (processor interface) “passes them to the buffers, and the
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`buffers have coherence protocols or coherence control that keeps track of
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`outstanding transactions and controls the flow of messages” which “indicates . . . it
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`has perhaps a little bit of a different and more complex protocol in handling those
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`requests.” Ex. 1032 at 78:17-79:4. Moreover, Petitioners’ conclusory statement
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`that “Dr. Oklobdzija’s Reply Declaration does not present any evidence that the
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`read request received by the hub in the home node is substantively different from
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`the read request sent by the processor” is plainly false. Dr. Oklobdzija’s
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`declaration identified the teachings in Culler and Laudon that (1) “[t]he router
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`[between hubs] and the Hub internals use different data transport formats
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`protocols, and speeds” (Ex. 2042 ¶ 13), (2) “[t]he processor in the requesting node
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`is connected to a hub in the requesting node via a ‘SysAD bus.’ . . . [while], the
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`hubs in SGI Origin communicate with each other via a ‘Craylink’ interface” (id.)
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`(3) “the hub chip has significant logic between these interfaces, which among other
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`things, ‘hides the processors from the rest of the world, so any other interface must
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`only know the behavior of the PI [processor interface] and not of the processor and
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`SysAD bus themselves,” (id.) (4) “in some instances, there is not even a one-to-one
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`relationship between the processor’s outgoing messages and the outgoing messages
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`from the hub” (id.), and (5) that the “processors are ignorant about” “at least some
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`details of the cache coherent protocol” for “which the hub is responsible for
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`implementing” (id.). Furthermore, that Dr. Oklobdzija could not identify specific
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`changes in the format of a read request is entirely consistent with his declaration ,
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`where he noted that “neither Culler or Laudon discuss the message format of any
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`of the messages sent by the processors, or sent or received by the hubs.” Id.
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`Response to Observation #6: Petitioners mischaracterize Dr. Oklobdzija’s
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`testimony as purportedly setting forth some opinion as to the degree or nature of
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`modifications of the probe between what is sent by a requesting processor and
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`what is received by the hub at the home node in SGI Origin (i.e. the alleged probe
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`filtering unit) such that it would no longer be operable to receive a probe from the
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`processing nodes. To the contrary, Dr. Oklobdzija repeatedly noted that the
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`references do not provide any disclosure of the specific message formats used for
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`such transmissions, and as such, he was unable to perform such an analysis and
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`that Petitioner’s questions, divorced from a particular example, asked for
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`“speculation” as he had “no data to . . . conclude either way.” Ex. 1032 at 55:8-
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`55:20, 56:17-23, 57:17-24, 65:22-66:5, 67:15-68:4, 69:12-21; 167:22-169:14.
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`Thus, there is no relevance to the fact that “Dr. Oklobdzija’s Reply Declaration
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`does not assert that the read request received by the hub in a home node does not
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`solicit the same response as the read request issued by the requesting processor.”
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`No such specific analysis could be performed. Additionally, Dr. Oklobdzija did
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`not testify, as Petitioners argue, “that as long as any modification to a probe does
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`not affect the response solicited from the system, it is the same probe for purposes
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`of the substitute claims.” Rather, in the context of a “hypothetical” and
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`“speculative” example, Dr. Oklobdzija identified changing the response solicited
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`as sufficient to cause the probe to not be the same. However, that does not imply
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`the inverse statement, as argued by Petitioners, that not changing the response is
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`sufficient to cause the probe to be the same. Thus, there is no inconsistency in Dr.
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`Oklobdzija’s testimony.
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`Response to Observation #7: Petitioners again misconstrue Dr. Oklobdzija’s
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`opinions. Petitioners cite to testimony where Dr. Oklobdzija acknowledged that, in
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`certain multi-cluster embodiments depicted in the figures of the ’121 Patent,
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`communications between different clusters would be sent through each cluster’s
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`cache coherence controller. As a threshold issue, Dr. Oklobdzija opined that a
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`point-to-point architecture requires multiple processors which are directly
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`connected to each other, not that all processors are directly connected. Ex. 2042 ¶
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`14 (citing ’121 Pat. at 4:38-40). Thus, there is nothing inconsistent with that
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`opinion and an embodiment having processors in different clusters not being
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`directly connected, as long as multiple processors within a cluster are directly
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`connected. Additionally, the testimony that cache coherence chips interconnect the
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`clusters of such embodiments is not inconsistent with Dr. Oklobdzija’s declaration.
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`Dr. Oklobdzija’s declaration expressly states that his opinion that SGI Origin’s
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`processors are not directly connected “is not meant to indicate that the mere
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`presence of some physical components between individual processors is
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`inconsistent with those processors being directly interconnected by a point-to-point
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`architecture” but rather “the description of the SGI Origin’s hub’s as ‘hiding’
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`processors and using ‘different . . . protocols’ to communicate within hubs as
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`opposed to between hubs demonstrates that Origin’s processor-to-hub and hub-to –
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`hub communications are separate architectures (e.g. a SysAD bus and a ‘Craylink’
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`network) rather than the claimed single point-to-point architecture which
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`interconnects a plurality of processing nodes.” Ex. 2042 at 14, ¶ 14, n. 4. The
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`cited testimony did not discuss that portion of Dr. Oklobdzija’s declaration, which
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`demonstrates that his deposition testimony is consistent with the opinions in his
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`declaration.
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`Response to Observation #8: The cited portion of the testimony of Dr.
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`Oklobdzija’s deposition merely reflects that Dr. Oklobdzija admits that the claims
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`do not expressly recite that multiple processors are “directly” connected in a point-
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`to-point architecture. Ex. 1032 at 80:3-8 (“It doesn’t say ‘directly.’”). However,
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`this is not inconsistent with Dr. Oklobdzija’s declaration, which addresses the
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`construction and meaning of the term “point-to-point architecture” in the ’121
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`Patent and cites the ’121 Patent’s statement that “‘[i]n a point-to-point
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`architecture,’ there are ‘multiple processors directly connected to each other
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`through point-to-point links.” Ex. 2042 ¶ 14 (citing ’121 Pat. at 4:38-40). The
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`cited portions of the deposition do not discuss claim construction or the meaning of
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`the term point-to-point architecture. Moreover, the cited portions of the deposition
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`discussing Figure 2 of the ’121 Patent merely reflect that Dr. Oklobdzija
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`acknowledges that Figure 2 of the ’121 Patent depicts an embodiment of a point-
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`to-point architecture in which fewer than all processors are directly connected.
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`Contrary to Petitioners’ argument, this is consistent with the opinions of Dr.
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`Oklobdzija’s declaration—which notes that the ’121 Patent describes that, in point-
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`to-point architectures, “multiple” processors are “directly” connected. Ex. 2042 ¶
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`14 (citing ’121 Pat. at 4:38-40). The ’121 Patent’s teaching that “multiple”
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`processors are directly connected in a point-to-point architecture does not mean
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`that “all” processors are directly connected.
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`Response to Observation #9: Petitioners mischaracterize Dr. Oklobdzija’s
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`testimony and opinions. Petitioners cite testimony from Dr. Oklobdzija
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`acknowledging that the bus used in SGI Origin is a multiplexed bus that does not
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`perform snooping. However, neither Dr. Oklobdzija nor the ’121 Patent identify
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`snooping as the sole basis for distinguishing between buses and point-to-point
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`architectures. Contrary to Petitioners’ characterization, Dr. Oklobdzija testified
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`that a bus is not a point-to-point connection and that point-to-point connections
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`require a point-to-point protocol. Ex. 1032 at 73:7-16, 152:7-20.
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`Response to Observation #10: Petitioners again mischaracterize Dr. Oklobdzija’s
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`testimony and opinions. Petitioners cite testimony where Dr. Oklobdzija
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`acknowledged that, in an embodiment of SGI Origin with only one processor per
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`node, there are only two endpoints to the SysAD bus connecting the processor and
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`the hub chip. However, that does not support Petitioners’ conclusion that such
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`testimony “demonstrates that the SysAD bus in Origin is a point-to-point link, as
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`opposed to a snooping-based shared medium.” Contrary to Petitioners’
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`implication, Dr. Oklobdzija did not testify that having “two endpoints” or the
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`absence of snooping is sufficient for a bus to be rendered into a point-to-point link.
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`Indeed, Dr. Oklobdzija testified that bus is not a point-to-point connection and that
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`point-to-point connections require a point-to-point protocol. Ex. 1032 at 73:7-16,
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`152:7-20.
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`Response to Observation #11: Petitioners mischaracterize Dr. Oklobdzija’s
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`testimony as “demonstrate[ing]” that “the SysAD bus in Origin serves the same
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`goals as the point-to-point architecture in the ’121 Patent.” Dr. Oklobdzija merely
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`noted that the ’121 Patent describes reducing latency and improving bandwidth as
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`two benefits of its point-to-point architecture, and that Laudon has a “general
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`discussion” also describing reducing latency and improving bandwidth as two
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`benefits of its overall architecture. But, the portions of Laudon referenced in the
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`cited testimony focused on SGI Origin’s overall decision to not use an SMP
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`design—including limiting the number of processors per node to a small number
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`(“one or two”) Ex. 1032 at 96:9-13; Ex. 1030 at 242 (“Local memory latency is
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`reduced because the bus can be run at a much higher frequency when it needs to
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`support only one or two processor [sic] than when it must support large number
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`[sic] of processors.”). That discussion was not specifically tied to the design
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`decision to use the multiplexed SysAD bus. To the contrary, the reason identified
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`by Laudon for the decision to use a multiplexed bus was “to save Hub pins.” Ex.
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`1030 at 242. Moreover, Dr. Oklobdzija did not testify, as Petitioners imply, that
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`latency and bandwidth are the sole benefits of a point-to-point architecture. At
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`most, Petitioners identify two goals in common, of many, between the design
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`decisions for the overall design of the SGI Origin and the overall design of the
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`inventions of the ‘121 Patent.
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`Response to Observation #12: Contrary to Petitioner’s implication, the cited
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`passages merely dealt with Dr. Oklobdzija’s analysis with whether a “point-to-
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`point architecture” as used in the ’121 Patent, includes “mesh” architectures. Ex.
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`1032 at 177:18-24. Ultimately, he concluded that they did, and thus Dr.
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`Oklobdzija testified that the left portion of Figure 3 of the Laudon references
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`depicts “a cube connected in a point-to-point architecture.” Ex. 1032 at 181:24-
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`182:2. However, none of this discussion related to Dr. Oklobdzija’s underlying
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`opinions as to why SGI Origin is not a point-to-point architecture, in particular, the
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`role of the SGI Origin hub chip in connecting processors in different nodes.
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`Indeed, Figure 3 does not depict any hub chips, and merely shows black boxes.
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`Ex. 1030 at 243, Fig. 3. Petitioners specifically tested this issue, and Dr.
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`Oklobdzija testified that Figure 3 of Laudon depicts “routers” between the
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`processors, not the SGI Origin “hub” chips, and that the “hub” chip is quite
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`different from the “router.” Ex. 1032 at 110:14-113:13. Thus, the cited testimony
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`is entirely consistent about with Dr. Oklobdzija’s declaration, which noted that
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`some components, such as switches (or routers), can be part of a single point-to-
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`point architecture connecting multiple processors, but that the hub chips of SGI
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`Origin have specific functionality which cause the overall system to not be a point-
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`to-point architecture. Ex. 2042 at 14 ¶ 14 n.4.
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`Response to Observation #13: The cited passage referred to an entirely
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`hypothetical scenario of a “system that communicates with a separate memory
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`which is not cached.” Dr. Oklobdzija found the scenario implausible and hard to
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`reconcile with systems that maintain cache coherency, and said he was “not sure
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`[he] kn[e]w what the answer would be” to questions involving such a system. Ex.
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`1032 at 126:17-127:7, 128:7-8. Moreover, the cited passage has no relation to Dr.
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`Oklobdzija’s opinions as to the SGI Origin’s ‘Xbow’ interface. Petitioners cite to
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`nothing, in Dr. Oklobdzija’s testimony or in the references, which describe the
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`Xbow interface as being equivalent to Petitioner’s hypothetical. Indeed,
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`Petitioners did not ask Dr. Oklobdzija about the Xbow interface at all. Thus,
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`Petitioner’s statement that “Dr. Oklobdzija admits that the ‘Xbow’ interface fits
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`‘the words’ of Patent Owner’s proposed definition of a non-coherent interface” is
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`plainly false. Moreover, the cited reference to Dr. Oklobdzija’s declaration
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`discussing Xbow handling “non-coherent ‘uncached’ I/O operations” is not
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`equivalent to the hypothetical that Petitioner’s presented, including because the
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`Xbow also handles both “coherent” and “non-coherent” operations together
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`(without rendering them logically distinct with separate protocols), and there is no
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`discussion of the ‘Xbow’ interface having a “separate memory.” Ex. 2042 ¶ 15
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`(discussing Xbow interface).
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`Response to Observation #14: Petitioners mischaracterize the cited testimony.
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`The question was directed to whether one could hypothetically “add two additional
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`unidirectional wires to the probe filtering unit [of a hypothetical system] and have
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`the drivers direct the noncoherent messages to those wires.” Ex. 1032 at 129:4-
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`130:23. The question was not directed to a particular system, and did not ask Dr.
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`Oklobdzija’s opinion as to whether it would have been obvious to modify any
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`existing system in that manner, or the difficulty or practical feasibility of such a
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`modification.
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`Response to Observation #15: The referenced testimony did not refer to Dr.
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`Oklobdzija’s application of any construction to any particular piece of prior art.
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`Rather, the testimony referred to the hypothetical scenario of “a hundred percent
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`overlap” in “shared components” between two interfaces. Ex. 1032 at 132:11-12.
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`Petitioners do not describe how that is relevant as to any issue in this case.
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`Additionally, Dr. Oklobdzija later testified that the interfaces could be made
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`logically separate through the use of protocols, which is entirely consistent with
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`Petitioners’ proposed constructions. Ex. 1032 at 132:22-133:10. Moreover, during
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`the cited testimony, Dr. Oklobdzija was directly reading and referencing to the
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`portion of his declaration which reiterated Petitioners’ position as to the
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`constructions of these terms, demonstrating that he was aware of and applied the
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`Petitioners’ constructions. Ex. 1032 at 132:5-9; Ex. 2042 at 6 ¶ 6 n.2; Motion to
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`Amend at 24 n.5. Thus, Petitioners do not demonstrate any actual inconsistency in
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`Dr. Oklobdzija’s testimony.
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`Response to Observation #16: Petitioners misconstrue and mischaracterize Dr.
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`Oklobdzija’s testimony. In particular, Petitioners point to disparate parts of
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`testimony where Petitioners’ counsel used the term “logic” in a different context
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`and attempts to equate those different parts of the testimony. In one portion of his
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`testimony, Dr. Oklobdzija stated that logically distinct coherent and non-coherent
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`protocol interfaces could be implemented using protocols. Ex. 1032 at 132:22-
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`133:10. Petitioners’ counsel described this as “logic for performing cached and
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`uncached operations across an interface” in seeking to confirm whether Dr.
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`Oklobdzija believed that such a scenario satisfied the proposed substitute claims.
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`Id. at 133:4-8. In this context, “logic” clearly referred to the prior questions and
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`answers in regards to implementing logically distinct interfaces using protocols.
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`Later in the deposition, in discussing an exhibit, Dr. Oklobdzija acknowledged that
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`SGI Origin must have some “logic” for performing “logic to access the memory
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`for cached and uncached operations.” Ex. 1032 at 134:14-136:23. In this sense,
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`“logic” referred to any mechanism for implementing such operations, but not
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`necessarily implementing them as logically distinct interfaces using separate
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`protocols. Thus, the two portions of deposition testimony that Petitioners cite to
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`are not equivalent—counsel did not ask whether SGI Origin had logically distinct
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`coherent and non-coherent protocol interfaces, or whether SGI Origin used
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`protocols to implement logically distinct cached and uncached interfaces across a
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`physical interface.
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`Date: January 15, 2016
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`Respectfully submitted,
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`
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`/Michael D. Saunders/
`Michael D. Saunders
`Admitted Pro Hac Vice
`Farney Daniels PC
`411 Borel Avenue, Suite 350
`San Mateo, California 94402
`Phone: 424-268-5210
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`E-mail: msaunders@farneydaniels.com
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`CERTIFICATE OF SERVICE
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`Patent No. 7,296,121
`IPR2015-00159
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`Under 37 C.F.R. §§ 42.6(e), this is to certify that I served a copy of the
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`foregoing PATENT OWNER MEMORY INTEGRITY, LLC’S RESPONSE TO
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`PETITIONERS’ MOTION FOR OBSERVATION via email on January 15, 2016
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`to Petitioners’ counsel of record at the following email addresses:
`
`W. Karl Renner, Reg. No. 41, 265
`Roberto Devoto, Reg. No. 55, 108
`Michael Rueckheim, pro hac vice
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`Email:
`IPR39521-0007IP1@fr.com
`IPR39521-0007IP2@fr.com
`IPR39521-0007IP3@fr.com
`IPR39521-0007IP4@fr.com
`renner@fr.com
`devoto@fr.com
`rueckheim@fr.com
`
`
`
`Dated: January 15, 2016
`
`
`
`
`
`/Michael D. Saunders/
`Michael D. Saunders
`Admitted Pro Hac Vice
`
`
`
`16