`
`Case: Certain Graphics Processing Chips, Systems on a Chip, and
`Products Containing the Same
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`THIS DOCUMENT CONTAINS CONFIDENTIAL
`INFORMATION
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`EXHIBI
`1009
`McALEXANDER
`gza16
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`Anne Toneano, CSR to5ãt
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`Ace-Federal Repofters, Inc.
`Phone: 202-347-3700
`Fax: 202-737-3638
`Email : info@acefederal.com
`Internet: www. acefedera l.com
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`Ex. 1009-0001
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`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`UNITED STATES OF AMERICA
`
`BEFORE THE
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`INTERNATIONAL TRADE COMMISSION
`
`Page2Tl
`
`Investigation Number
`337-TA-941
`
`IN THE MATTER OF:
`
`CERTAIN GRAPHICS PROCESSING CHIPS'
`SYSTEMS ON A CHIP, AND PRODUCTS
`
`CONTAINING THE SAME
`
`-x
`
`-x
`
`HEARfNG, VOLUME 2
`
`Wednesday, August 19, 2075
`Courtroom A
`U.S. International Trade
`Commi s s ion
`500 E Street SW
`Washington, DC
`
`The hearing commenced, pursuant to notice of the Judge' at
`10 : 00 â.ITt. r bef ore the Honorable David P. Shaw,
`Administrative Law Judge for the United States
`International- Trade Commission.
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`OPEN SESSION CONTINUED
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`Page 349
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`It provides the
`
`initiates
`A
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`formattíng
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`initiate
`initiate
`
`BY MR. GRANT:
`You were asked a couple of questions about page
`O
`and some other
`2-2. You were asked here about arbitration
`It. also says here that the SCU, that's what
`things.
`the L2 accesses; right?
`the accesses, yes.
`It
`initj-ates
`for the AXI bus.
`the
`It doesn't say the processors initiate
`O
`function' one of the
`access; it says the SCU, one of its
`the AXI accesses?
`is to initiate
`listed
`four functions
`InLerfaces
`V'Ielcome to the worf d of interf ace.
`A
`the command. They
`init.iate
`access. They don't
`the access.
`Now l-etts go to table 2-7I , which is on page
`O
`that the
`2-iJ4 of the same document. Am I correct, sir,
`ARID Lransacti-ons, those are defined in the chapLer of this
`exhibit, 3915, that describe the functions of the SCU;
`right ?
`A
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`Yes.
`
`Vühil-e this
`
`is an exemplary tabfe that provides
`O
`if we really want to know and be 100
`us some descriptions,
`percent sure how this process works, we would look at the
`source code, wouldn't we?
`If you wanted to have another way to identify
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`1
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`2
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`Page 350
`ye S, Source code \^rould provide some coll-aborative
`that,
`information about it.
`review the source code to
`3
`And you didn't
`Q
`4 determine how the SCU generates t.he ARID signal, did you?
`No. The generation of the content came from the
`5
`A
`formaLting.
`6 CPU, as defined. The SCU does the final
`7 That's what an inLerface did.
`review the source
`My question was, You didn't
`8
`Q
`9 code that actually explains how this ARTD is generated' did
`l0
`
`you ?
`
`review the
`
`No, how it's generated, oor I didn't
`11
`A
`12 source code.
`Let's see if we can pull up RDX-4, page 3, which
`13
`O
`bus. You l^/ere asked some questions
`is that point-to-point
`and shared buses.
`15
`i-n co]umn 1 about the point-to-point
`16 Let's see if we can quickly wrap that up. This is that
`17 portion of column 1 descrlbing how you have to require
`for bus devices to
`18 point-to-point
`buses to communicate
`19 communicate \^/ith each other; right?
`is a part of the description on the
`20
`Yes, this
`A
`2r point-to-point.
`Okay. Now, part of what you said on redirect,
`22
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`is you said
`r,¡/rote it down verbatim to make sure I have it,
`23
`information on a
`"you canrt have both partíes providing
`line at the same time", end quote, and thatts why,
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`Page 35 I
`
`right ?
`than two
`
`isntt used
`
`that arbj-tration
`
`O
`only for shared buses?
`I'm not sure what you mean.
`A
`For example, a poinL-to-point bus requires
`1
`Q
`it?
`doesn't
`8 arbitration
`it's bidirectional,
`if
`gANo.That'sjustamatterofraisingalineofa
`10 voltage, and the voltage tells you \nrhether you have access
`it doesn't require
`It doesnrt require grants or
`l1 or not.
`12
`that.
`
`accordíng to you, arbitration means shared bus;
`That is correct, when You have more
`A
`devices, right.
`Isn't
`
`it
`
`true' sir,
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`I have a bidirectional
`if
`so your testimony is,
`t3
`o
`and in
`14 point-Lo-point bus, I don't require arbitratíon,
`that
`there aren't any buses like
`15
`I wouldn't have
`fact,
`Is that your testimony?
`16
`in the worfd, are there?
`f 'm certainly not testif yì-ng that someone
`17
`A
`18 coufdn'L do it, but it's not required. You do not have to
`in point-to-point.
`19 have arbitration
`buses, one of the
`Now, this point-to-point
`20
`O
`2l problems is they take up more space than shared buses,'
`22
`right ?
`yes, on a sysLem that does use point-to-point
`A
`takes up significantly more space '
`its onJ-y mechanism, it
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`Page352
`obviously, would take
`That,
`to connect
`those bus devices with
`right?
`a dlagram,
`
`but the answer ls Yesr
`
`it
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`that exemplary shared bus
`l-ess space than if we had
`six point-to-point
`buses;
`Again, t.his is
`A
`takes less space.
`I can refer
`if
`Let's see if we can very briefly'
`O
`you to column 1, starting at line 28, and l-et's go to 35.
`the discussion of what a point-to-point
`This is right after
`bus is. By the way, it doesn't define what a shared bus
`just describes how it can be used? Right? Thatrs
`is;
`it
`It says shared buses can be
`what happens in column 1.
`It
`is architectural.
`It doesn't define what it
`used.
`says how it can be used; right?
`It does state that, but I think when you look at
`A
`it describes what it. is as compared to the
`the context,
`point-to-point.
`Now, in your view, \^/e can take that
`O
`connection, and that can be a shared bus if
`point-to-point
`right?
`it's being used by many bus devices, three or four;
`in
`there are more than "two bus devices",
`If
`A
`quotes bus slaves/bus masters, t.hat are using that bus for
`communication, yes, I would say itts a shared bus.
`Letrs see if we can highlight where it starts
`a
`wíth "ho\nrever . " Column ! , starting at l-ine 28 .
`the large number of buses used in a point-Lo-point
`
`just
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`"Hohrever,
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`architecture requires a large amount of chip or board
`
`Page 353
`
`area.tt
`
`Did I read that correctlY?
`Yeah' that is correct.
`A
`Do you agree with that?
`O
`Yeah, point-to-point does, because you have to
`A
`have a separate set of buses operate between each of the
`two devices.
`Okay. Then it goes on to say "since only a
`O
`single shared bus can support multiple bus devices, the
`chip or board area required to implement a shared bus
`archítecture ís much less than is required by a
`point-to-point bus architecture."
`Do you see that?
`
`Yes.
`Do you agree with it?
`Yes. So far it's consistent with everything
`
`A
`a
`A
`f fve said.
`true, Mr. McAlexander, that if the
`it
`Isn't
`O
`Court adopts your interpretation of the word "coupledr "
`those statements are false? A point-to-point, a shared bus
`can be just that one connection, and it doesn't take up
`more chíp or board area, does it?
`That' s absol-utelY incorrect.
`A
`Isnft it
`true
`O
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`I haven't
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`No, sir,
`it. true
`
`Isnrt
`
`finished.
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`Page 354
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`A
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`O
`A
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`incorrect.
`Itrs absolutelY
`the Court
`true, Mr. McAJ-exander, if
`it
`Isn't
`O
`of the word "connect, " then a
`adopts your inLerpretation
`bus architecture no longer requires more
`point-to-point
`chip or board area than a shared bus?
`No, it ' s absoluteJ-Y incorrect .
`A
`I adopt
`true, Mr. McAlexander, if
`it
`And isn't
`O
`your construction or the court adopts your construction
`of "shared bus," those two sLatements are afso incorrect?
`If you adopt my construction, which is the
`A
`is not
`it
`t.hat all part.ies have agreed to,
`construction
`
`correct.
`
`Thank you.
`
`MR. GRANT: Those are my questions, your Honor'
`
`Thatrs recross.
`right.
`JUDGE SHAIIí: All
`So
`the end of the examination. Are we going to defer
`t.hat's
`Is Lhat the plan?
`evidence with this witness?
`MR. GRANT: Vüith this wítness, wo've worked it
`lVe have an agreed list of
`out overnight, your Honor.
`I believe Mr. Donovan will hand up to t'he
`that
`exhibits
`I apologize-
`Agreed by us.
`court reporter.
`JUDGE SHAI/ü: Have you had a chance to examine
`that, Ms. Kundupoglu?
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`MS. KUNDUPOGLU: No, staff has not, and
`had questions about the demonstratives and slides
`used.
`
`Page 355
`staff
`
`that were
`
`JUDGE SHAIV: Especially since we wiff have the
`witness here throughout the course of the hearing, v/hY
`longer until everything
`don't we just defer it a litt.le
`completely worked out.
`MR. GRANT: I would say, the two demonstratives
`to be
`that we created, RDX-10 and RDX-12' \^/e hrould like
`included with the other demonstratives in the case '
`ready to go' or
`JUDGE SHAVú: Are '^¡e really
`bit more?
`should we defer a little
`Your Honor,
`at the end.
`
`is
`
`your pref erence.
`to have
`I woufd like
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`Vìle
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`MR
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`DONOVAN:
`
`can defer and
`Cx-32 as well.
`
`do it all-
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`JUDGE
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`SHAW: Are
`
`you totally on board with
`Have you had a chance to fook
`
`Kundupoglu?
`
`everyt.hlng, Ms
`at everything?
`MS. KUNDUPOGLU: We could probably just hash ít
`out over lunch.
`JUDGE SHAVü: I think Lhat's a good idea ' We
`wiII do it when we get back from lunch. Although I donft
`to cafl another
`I would like
`want to go to lunch yet.
`Is he Your next witness?
`witness.
`MR. DONOVAN: He is.
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`Page 356
`
`JUDGE SHAW: Okay. So you're recalled.
`MR. AROVAS: Your Honor, as the Court already
`noticed, Mr. McAlexander is talking about, testifying
`about
`two of the three patents. The witness statemenL l^las
`in front of the
`for both. So that's actually
`consolidated
`witness already. He has that with the errata and
`the -- alf of
`that. Since \n¡e I re def erring
`like
`everything
`like we can probably --
`the evidentiary admissions, I feel
`we will simply do that at the end of both examinatíons for
`that's acceptabl-e to
`if
`together,
`both patents and do it
`your Honor.
`
`MR.
`
`AROVAS:
`
`JUDGE SHAW: Yes. Thank you.
`lrTe do have a separate set of
`along with that that were not
`that go
`demonstratives
`examination. Vüith the Court's
`the first
`provided with
`to hand those up.
`woufd like
`permission,
`I
`JUDGE SHAIV: Yes, Please.
`the preliminary questions
`MR. AROVAS: Since atI
`were asked about the witness statement aJ-ready, the witness
`and approved as
`r^ras al-ready tendered and accepted as an
`an expert, and the area of the tenure covers both patents.
`Unless the Court prefers a different procedure, I would
`just
`turn the witness over for cross-examination.
`Thank you very
`JUDGE SHAV'I: That sounds fine.
`
`much.
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`MR. AROVAS: Thank You.
`MS. HOLLOVüAY: Good morning, your Honor, JuJ-ie
`
`Page357
`
`1 2
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`3 Holl-o\^ray.
`
`CROS S -EXAMINAT fON
`
`BY MS . HOT,IOWAY:
`Vfetve met bef ore.
`
`YeS,
`
`we have.
`
`Okay.
`brie fly
`
`Before
`
`about
`
`\^re go into your oPinions, sir,
`your background.
`
`O A a
`
`ì
`
`let's
`
`talk
`
`A
`
`Okay.
`The last
`time you did dynamic
`when you Ieft Texas
`Instruments ín 1986;
`Yes; that's correct.
`A
`And you have never designed DDR SDRAM memories;
`O
`correct ?
`That is correct.
`A
`Okay. Thank you. Letrs talk first about the
`O
`claim construction of "mode" in this case. Thatts a
`disputed topic, of course.
`A
`OkaY.
`Cou1d we have the constructions up on the
`O
`screen, please. Now, you understand that NVIDIA's proposed
`construction is "configuration required by the
`memory-device type"; right?
`A
`
`RAM design t^/as
`
`correct ?
`
`Yes.
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`proposed plain
`
`Page 358
`meaning
`
`right ?
`
`2
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`3
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`4
`Q
`5 operation"
`6
`A
`
`And you support Samsung's
`O
`constructionr "manner of operaLlon";
`Yes; that's correcL.
`A
`Now, j-tts your opinion that "manner of
`is the plain meaning of "mode"; correct?
`That is correct.
`But you agree that there are certain modes, for
`7
`Q
`8 example standby, that would not be covered by the claims;
`9
`right?
`10
`That's right.
`A
`11 as defined by the claim.
`12
`okay. So you agree that the term "mode"
`a
`13 standing on i-ts own could have a number of different
`14 meanings; right?
`Certainly, standing on its otvlln. Itr s a matt'er
`15
`A
`16 of operation.
`tal-k about how the patent uses
`17
`Okay. So letrs
`O
`bit of
`the term "mode." Let's start out with a little
`18
`19 background. The background of the patent describes various
`types of semiconductor memory devices, such as DDR, DDR 2,
`20
`2t and MDDR; right.?
`22
`Yes, it does.
`A
`Letrs take that slide down. Thank you. And the
`23
`O
`24 background of the patent states Lhat each of these
`excuse mer each of these
`25 semiconductor memory devices
`
`The terms of what the mode is is
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`Page 359
`semiconductor memory device types has different properties
`types of memory controflers;
`and may require different
`
`right ?
`A
`
`Thatts correct.
`Okay. So could we fook at the patent, please,
`O
`l-ines 40 to 42. So the patent states
`JX-3, coÌumn I,
`that "a data strobe buffer which can enable the memory
`types of memory devices
`control-lers," plural,
`"9f different
`is needed"; right?
`Yes, that's what it sLates.
`A
`look at the sol-utions that the
`Okay. So let's
`O
`that
`patent. describes. The ''734 patent describes a buffer
`can operate in different modes according to the type of
`memory; right?
`IL describes that, Yes.
`A
`And the '134 patent describes modes that are
`O
`types of memory devices; correct?
`according to different
`It does describe that, Yes.
`A
`Okay. And the embodiments j-n the
`a
`based upon the
`show modes that are different
`correct ?
`
`speci fication
`type of memory
`
`device,'
`
`A
`
`O
`
`Ba sed
`
`Let' s
`
`testimony,
`
`s.Ir,
`
`in part on the types, that's correcL.
`1ook, please, at your dePosition
`page 406. Could You turn to that?
`
`H
`
`Sure
`
`40 6?
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`Uh-huh.
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`Page 360
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`I
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`2
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`e
`A
`
`Okay.
`I woufd like
`
`to focus on line 16. Coufd we have
`
`3
`4
`
`1l
`
`Q
`l-íne 16 through 21, up.
`I'Question: Those are the only modes that the
`5
`is modes of operation that are according
`6 patent describes,
`7 Lo the type of memory device; correct"?
`"Ansr^¡er: The embodiments that are used as
`8
`9 exempl-ar do show modes that are different based upon the
`10
`type of memory device. "
`You gave that testimonY?
`
`12
`
`A
`
`17
`18
`
`O
`A
`
`Yes.
`Okay. But you believe that a mode is not a
`13
`O
`required by the memory device type; right?
`14 configuration
`15 That' s your opinion?
`You're talking about the claimed mode?
`16
`A
`Thatrs right.
`That's correct.
`Okay. Could we have figure 4 of the patent up
`19
`O
`I would l-ike to tal-k about some of the
`20 on the screen?
`2l evidence that you and Samsung rely upon. You understand
`figure 4 shows that both the first
`22
`that Samsung argues that
`23 and second mode operate on the same incoming data strobe
`24 DQS_2; right?
`25
`That is correct.
`A
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`Page 361
`testimony to suPPort
`
`figure 4. That's Lhis
`goes down to the
`
`is
`in, " it basicallY
`at the pad P 1, which
`
`2
`
`3 4
`
`5
`
`6
`
`7
`
`8
`
`9 1
`
`25
`
`And Samsung relies on Your
`O
`that argument; right?
`In Part, Yes.
`A
`LeL's talk about DQS-2 in
`O
`that
`signal coming in from the right
`label-ed 120; right?
`triangle
`l-ittle
`lfhen You saY coming
`Yes.
`A
`that's present and arrives
`the signal
`is the input to the buffer.
`tal-k about DQS
`Thank you. So let's
`0
`Exactly.
`O
`is
`11 underscore 2 in figure 4, and let's explore whether it
`true thaL the same data strobe signal, DQS 2, is operated
`12
`13 on by both the first and second mode of the buffer shown in
`figure 4. First off, you agree that the two manners of
`14
`in figure
`15 operation, as you put. it, used by the buffer
`16 are shown in figures 3A and 3B; right?
`17
`A
`Ï
`talk about figures 3A and 38.
`18
`Let's
`O
`t9 understand you l^rerenrt in court during the opening
`20 staLements. Are you aware Mr. Arovas tal-ks about these
`2r
`figures 3A and 38 quite a bit?
`Itm aware that he was going to, but f \n/as not
`22
`A
`23 present for the opening.
`Okay. Fair enough. These figures are pretty
`24
`O
`important. So l-et' s talk about what they are bef ore \^/e
`
`Yes.
`
`4
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`is
`
`it
`
`is.
`
`Page362
`Figures 3A and
`launch into what iL is that they disclose.
`I
`2 3g are \^/hat's calfed equivalent circuit diagrams; right?
`3
`A
`YeS.
`And you wil_l agree that an equivalent circuit
`4
`Q
`theoretical- design that's used to analyze an
`5 ¿ simplified
`6 actual design; right?
`It can be' and in this context,
`7
`A
`Tt is in this context?
`
`8
`
`Q
`A
`
`9
`Yes.
`Okay. And the actual design in quesLion is
`10
`O
`11 what's shown in figure 4; right?
`is -- when you say "the actual, "
`12
`lrlell, even that
`A
`bit more elaboration with regard to the
`13
`it has a little
`the receiver.
`14 driver but not necessarily
`talk about Lhese simpJ-if ied theoretical
`15
`Let's
`O
`that
`16 dì-agrams, f igures 3A and 38, and see if you're right
`17 DQS_2 is the same for figure 3A and figure 38. Now, the
`for figure 3A
`18 DQS 2 daLa strobe that the patent discloses
`19
`is for a DDR-type memory; right?
`That is correct. Column 4 supports that.
`A
`And the DQS 2 daLa strobe the patent discloses
`O
`for figure 3B is for an MDDR-type memory; correct?
`That is correct.
`A
`DDR and MDDR use different data strobes; right?
`Are you talking about the actual memory device
`
`20
`2l
`
`22
`
`23
`
`24
`25
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`Page363
`
`1
`
`itself?
`
`2
`I'm talking about what is used with DDR and
`Q
`3 MDDR. They use different data strobes; right?
`f'm just not undersLanding what your context is
`4
`A
`So it
`5 on "use." This is a memory control-ler buffer.
`6
`IL's not a question of what the memory device
`receives.
`7 uses.
`8
`
`Q
`A
`
`ís different
`
`between
`
`17
`
`The memory device sends a data sLrobe signal?
`9
`Thatrs correct.
`10
`And that data strobe signal
`O
`11 DDR and MDDR; right?
`Based on the MDDR, the J-ow-power spec and the
`12
`A
`13 DDR spec, yes, they're different.
`t4
`And it's your opinion that the different DQS 2
`O
`in figure 3A and figure 3B show that DQS 2 can come
`15 signals
`types of memories; righL?
`16
`from multiple different
`It shows it can, yes.
`A
`to figure 4. Now, you say
`18
`Okay. Let's return
`O
`figure 4 supports your opinion that the '734 patent is
`19
`that
`20 all- about dynamic switching between modes; right?
`21
`rt does enabfe that, yes.
`A
`So l-eL's talk about how the modes are selected
`22
`O
`in figure 4. okay? Now, you claim that figure 4 shows a
`23
`that can switch back and forth between
`24 data strobe buffer
`25
`two modes; right?
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`Page364
`
`second mode is suitable
`memory; right?
`
`same
`
`\nIay.
`are very famil-iar with the
`
`aI¡/a f e that
`the
`in the '134 patent?
`
`Yes, it does.
`A
`And those two modes are the first mode and the
`O
`second mode; right?
`That is correct.
`A
`Okay. And you claim that the first mode ís
`O
`the memory; right?
`suitable for high-speed access to
`Thatrs correct.
`A
`And you claim that the
`O
`for low-speed access to that
`Yes, that is one
`A
`And I take it You
`O
`'734 patent; right?
`A
`Yes.
`I take it you are
`O
`term "high-speed" does not
`appear
`That's correct.
`A
`Nor the term l-ow
`O
`That's correct.
`A
`Nor any form of
`O
`A
`Correct.
`Nor any form of
`O
`A
`Correct.
`Let's talk about what the '734 patent actual-ly
`O
`says about selecting the two modes used in figure 4. Now,
`figure 4 includes a multiplexer or a MUX numbered 130;
`
`speed?
`
`the verb "sh/itch" ?
`
`the verb "changet'?
`
`2 J 4 5 6 7
`
`8 9
`
`l0
`
`n l
`
`2
`
`l3
`
`t4
`
`15
`
`16
`
`17
`
`18
`
`l9
`
`20
`
`2t
`
`22
`
`23
`
`24
`
`25
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`Page 365
`
`I
`right?
`2
`That is correct.
`A
`3
`And as shown in figure 4, the muftiplexer 130
`Q
`4 has two inputs; right?
`5
`That ís correct.
`A
`6
`Those are labeled T1 and T2?
`Q
`7
`A
`Yes.
`And f believe rrTrr here stands for terminal,
`8
`Q
`9 something l-ike that?
`10
`A
`Yes.
`The multiplexer 130 has one output that goes to
`1l
`O
`12 the comparator 120; ríght?
`13
`That's correct.
`A
`14
`Okay. And the multiplexer 130 receives a
`O
`15 selection signal that is not showni right?
`16
`That is correct.
`A
`talk about that a little bit. Now, the
`17
`So fet's
`O
`18
`'734 patent sometimes cal-ls this multiplexer a selectori
`19 right ?
`20
`rt does.
`A
`2l
`And during a read operation, the multiplexer or
`O
`22 selector 130 will select one of the two input signals, the
`23 signal at terminal T1 or the signal at terminal T2 and
`24 provide the sefect sígnal as its output; right?
`25
`A
`Correct.
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`if
`
`a
`A
`
`2
`
`3 4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`t1
`
`t2
`
`l3
`
`t4
`
`15
`
`16
`
`t7
`
`18
`
`t9
`
`20
`
`2l
`
`22
`
`23
`
`24
`
`25
`
`Page366
`is Vref íf
`Now, in firm 4, the selected input
`O
`is in the first mode; right'?
`the data strobe buffer
`the selection signal has
`If
`That's correct.
`A
`compared to.
`selected T1, then vref would be what it's
`to as the first mode in the
`referred
`And that's
`O
`patent, when the selected mode is Vref?
`And also in the claim.
`A
`Tn figure 4, the selected input is not Vref,
`O
`is in the second mode; right?
`the data strobe buffer
`That's correct.
`A
`What selected in that case is ground; correct?
`Correct.
`t.al-k about how that input is
`Let's
`All right.
`O
`I would like
`and specificatly,
`selected by the multiplexer,
`is based on the memory
`to explore whether this selection
`type or, as you claim, some other requirement' Okay? So
`that we tafked about a
`tal-k about the selector signal
`let's
`f or
`that sel-ects the input
`minute ago, t.he selector signal
`the mult.iplexer 130 shown in figure 4. The patent
`describes a mode signal which is not shown in the figures,'
`right ?
`AYourvealreadyaskedthat,andtheansweristhe
`that ' s correct .
`same, y€s,
`I díd, sir,
`Sorry if
`O
`the case. All right.
`
`but I don't believe
`agree for figure 4,
`
`thaL' s
`in the
`
`Now, You
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`indicating
`
`Page 367
`that
`
`1
`
`2
`
`6
`
`two.
`
`11
`
`O
`
`is described as
`first mode, the mode signal
`second mode,
`Lhe memory device is a DDR SDRAM' and in the
`that the memory
`the mode sì-gnal is described as indicating
`3
`4 device is an MDDR SDRAM; correct?
`between the
`the distinction
`5
`It does indicate
`A
`it based on that, Yes'
`It says it may select
`testimony,
`take a look at your deposition
`7
`Let's
`Q
`8 sir. Cou]d we have page 456? Let me know when you're
`9
`there, please
`lo
`I have it.
`A
`456, lines 8 through 13.
`"Question: Okay. So for figure 4| in the first
`12
`the memory
`is described as indicating
`13 mode, the mode signal
`14 device is a DDR SDRAM, and in the second mode, the mode
`the memory device is an MDDR SDRAM;
`15 signal
`is indicating
`16 correct ?
`17
`
`"
`
`"Ans'^¡er: That is in the description.
`Did you give Lhat testimonY?
`is correcL.
`Yes; that
`Letrs t.ake a l-ook at how the t'/34 patent
`20
`a
`2I describes the mode signal- for figure 4. could we have
`22 column 5, l-ines 13 through 76, and column 5, lines 28
`23
`through 30, up on the screen? okaY.
`the select'or
`So according to the '734 patent,
`24
`25 130 may sefecL the reference voltage Vref in response to a
`
`18
`
`19
`
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`A
`
`5
`
`6
`
`Page 368
`that the memory device
`1 mode signal not sho\^/n, indicating
`the ground
`2OO is DDR SDRAM, or the sefector 130 may select
`2
`3 vol-tage in response to a mode signal not shown, indì-cating
`4
`that the memory device 200 is an MDDR SDRAM.
`Do you see that?
`I see t.hat.
`And these tl^ro passages/ 513 to 16 and 528 to 30'
`7
`Q
`in the
`these are the only descriptions of the mode signal
`8
`9 discussion of figure 4; correct?
`10
`Yes; thatt s correct.
`A
`Okay. So according to the '134 patent, Lhe
`l1
`O
`the reference voltage Vref in
`12 sefector 1-30 may select
`response to a mode signal which is not sholn/n' indicating
`13
`that the memory device is a DDR SDRAM' or the selecLor may
`14
`the ground voltage in response to a mode signal not'
`15 select
`the memory device is a MDDR SDRAM;
`16 shol^In, indicaLing
`that
`17
`right?
`Wel-l-, you've again read exactly, but in both
`18
`A
`the word "or, " which is not in the
`19 cases you inserted
`20 statements here. But both of these particular
`senLences
`2l are present in column 4 -- col-umn 5, rather.
`to figure 4, please. And the MUX
`22
`Let' s return
`O
`right'
`23 here, the multiplexer 130, that has only two inputs,
`24 vref and ground?
`25
`That's \^rhatrs shown, yes.
`A
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`Page 369
`So it wif t onJ-y sel-ect one of these t\^/o inputs;
`
`O
`
`2
`
`right?
`
`shown, yes
`patent describes only these two modes,
`for figure 4; correct?
`the second
`the first mode
`it shows in this
`These are the two
`7 embodiment, yes
`
`mode,
`
`modes
`
`AS
`
`And
`
`the
`
`and
`
`A o
`
`3 4
`
`65
`
`
`
`8
`
`9
`
`10
`
`11
`
`t2
`
`13
`
`t4
`
`15
`
`t6
`
`t7
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`O
`
`And
`
`and the
`
`second
`
`these are Lhe onlY two modes,
`mode, that are described for
`
`the first mode
`figure 4;
`
`They are the two modes that are described.
`And they are the onlY ones; right?
`the two that are described.
`Yeah, they're
`So we've talked about the first and second
`only example the '134 patent describes of a
`is interfacing either with DDR 2 or DDR 3;
`
`correct ?
`
`A o A O
`
`modes. The
`
`third mode
`
`correct ?
`
`That is shown in another figure, and thaL's
`another mode, yes.
`the only example of a third mode,
`And thatrs
`O
`interfacing with either DDR 2 or DDR 3; right?
`Again, it uses the word rrmayr " but
`A
`is what is described.
`that that
`the fact
`Tt is the ontY examPle, sir,
`IL is; an embodiment ís an examPle.
`
`AS
`
`I will accept
`
`isn't
`
`ir?
`This is
`
`A
`
`O
`A
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`
`didn't
`
`2
`
`3 4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`I whatts sho\^/n.
`This is t.he only example of a third mode, either
`O
`interfacing with DDR 2 or DDR 3; right?
`What is shown in the fi-gure as supported by the
`A
`spec is what is sho\^/n.
`Thatts not really much of an ans\^/er. Let's see
`O
`what you said at your deposition, because you did manage to
`I will sâY, you
`then . 462, lines 13 through 13.
`ansr/ìrer it
`l-ike the questlon too much then.
`"Question: But I'm saying the only example the
`patent describes of a third mode is interfacing with DDR 2
`or DDR 3; right?
`"Ansh¡er: The only -- the example that is given
`that might be from that thírd mode is
`as to the indication
`DDR 2 and DDR 3.
`"Question: Right. And that's
`
`10
`
`l1
`
`t2
`
`13
`
`t4
`
`l5
`
`I6
`
`the only example;
`
`17
`
`18
`
`t9
`
`20
`
`2l
`
`22
`
`23
`
`r ight ?
`
`A
`
`O
`
`24 describes
`25 GDDRSDRAM;
`
`is the examPle given.
`"Ans\rrer: It
`"Question: The onlY one?
`is the onJ-y nonexcl-usive
`It
`"Ansv/er:
`You gave that. testimonY?
`Yes, I did.
`Okay. And the onlY examPle that the
`of a fourth mode is interfacing with a
`correct ?
`
`example. tt
`
`'134 patent
`graphic
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`A
`
`Page 37 1
`is given' Yes'
`
`is the example that
`Again, that
`the onlY examPle; right?
`And it's
`O
`Agai-n, the word is "may be." That's what is
`A
`described. That's the embodiment that is shown.
`is described;
`that
`the only thing
`And it's
`O
`right?
`A
`
`it
`
`Again, it says "may be. " So it could'
`this using this as the exemplar
`is describing
`certainly
`example, using the graPhics DDR.
`testimony
`LeL's take a look at your deposition
`O
`took quite a
`It
`agai-n, page 463, startíng at l-ine 10.
`while to get to this, buL okaY.
`Vlhich fine?
`A
`Líne 10, 463.
`In the description of figure
`"Question: Okay.
`g, the patent describes a fourth mode when the data sLrobe
`is in
`j-nterfaces with GDDR; correct? And this
`buffer
`column 7, Iines 58 through 60." And then your counsel
`asked some questions. And your ansr^rer hlas "it does
`It says' again, as you said,
`describe a -- an example.
`fourth mode may be an operating mode of the data strobe
`interfaces wj-th a
`buffer, when the data strobe buffer
`graphic DDR GDDR SDRAM. So yes, the same tanguage, it may
`
`O
`
`the
`
`2
`
`J 4 5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`t2
`
`13
`
`l4
`
`15
`
`16
`
`t7
`
`l8
`
`t9
`
`20
`
`2l
`
`22
`
`23
`
`24
`
`25
`
`be.
`
`"Question: Okay. And this
`
`is the only example
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`detail-ed
`itrs done.
`the patent
`with the
`
`of a fourth mode that is described; correct-
`"Ans'¡/er: That's the only additional
`example that's provided, Yês, of a way in which
`"Question: And other than that, all
`is that the fourth mode may are interfacing
`right ?
`"Ansvler: I¡trell, it does say the fourth mode may
`
`says
`
`GGDR;
`
`be.
`
`It
`
`It doesn't describe any
`"Question: Right.
`other specific fourth mode; right?
`'Answer: It doesn't go into more specifíc.
`does -- it does say fourth mode. In terms of what the
`operating mode may represent, there is one example given. "
`Did you give that testimonY?
`Correct' consistent with what I just said.
`A
`Okay. Thank you, your Honor. I think this is a
`O
`good time for a break,
`JUDGE SHAI¡tr: Very good. VÙhy don't I^/e come back
`at 1: 30, then.
`(Whereupon, at L2zt7 P.û., the hearing was
`recessed, to be reconvened at 1:30 p.m. this same day.)
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`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`AFTERNOON SESSION
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`Page373
`(1:30 P'm')
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`T,rtrhereupon,
`
`We
`
`h/ere rn
`
`Vùe can
`
`JOSEPH C. MC ALEXANDER
`resumed the stand and, having been previously duly sI^Iorn,
`further as follows:
`tú¡as examined and testified
`JUDGE SHAI¡ü: Good afternoon.
`the middle of cross-examination by
`if nothing came uP
`go back to that
`Ms. Holloway.
`need to talk about right aütay.
`during l-unch
`that we
`MR. AROVAS: No' Your Honor.
`JUDGE SHAW: Vüe remain on the public record
`CROSS-EXAMINATION (Continued)
`BY MS . HOLLOVÍAY:
`Okay, Mr. McAlexander, welcome back.
`Thank you.
`I hope you had a ni-ce lunch.
`
`Yes.
`
`O A u A
`
`MS . HOLLOVüAY:
`going to have
`
`UnfortunatelY, Your Honor, with
`to go back on Lhe confidential
`
`that,
`I^Ie are
`minute.
`record for a
`JUDGE SHAI,'I: Very qood.
`(Confidential session follows. )
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`Ex. 1009-0027
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`THIS DOCUMENT CONTAINS CONFIDENTIAL INFORMATION
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`Page 377
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`1
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`OPEN SESSIO