Date: August 2L,20L5
`
`Case: Certain Graphics Processing Chips, Systems on a Chip, and
`Products Containing the Same
`
`Ace-Federal Repofters, Inc.
`Phone: 202-347-3700
`Fax: 202-737-3638
`Email : info@acefederal.com
`Internet: www.acefederal.com
`
`) f
`
`ltt Ft[tfiflt
`
`Ex. 1011-0001
`
`
`
`Case: Certain Graphics Processing Chips, Systems on a Chip, and
`Products Containing the Same
`
`Ace-Federal Repofters, Inc.
`Phone: 202-347-3700
`Fax: 202-737-3638
`Email : info@acefederal.com
`Internet: www.acefederal.com
`
`) f
`
`ltt Ft[tfiflt
`
`Ex. 1011-0001
`
`
`
`Page844
`
`UN]TED STATES OF AMERICA
`
`BEFORE THE
`
`INTERNATIONAL TRADE COMMTSSTON
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`-x
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`1
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`2
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`J 4 5
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`6
`
`IN THE MATTER OF:
`7 CERTAIN GRAPHICS PROCESSING CHIPS, : 337-TA-941-
`
`Investigation Number
`
`8
`
`SYSTEMS ON A CHIP, AND PRODUCTS
`
`9 CONTATN]NG THE SAME
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`r0
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`-X
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`HEAR]NG, VOLUME 4
`
`Friday, August 21, 201,5
`
`Courtroom A
`U.S. International Trade
`
`Commi s s íon
`
`500 E Street SVü
`
`V'lashington, DC
`
`2t
`22 The hearing commenced., pursuant to notice of the Judge, at
`l-0:00 4.m., before the Honorable David P' Shaw,
`23
`24 Administrative Law ,Judge for the United States
`International Trade Commission.
`25
`202-347-3700
`Ace-Federal Reporters, Inc'
`
`866-928-6509
`
`Ex. 1011-0002
`
`
`
`APPEARANCES
`
`Page 845
`
`For Complainants Samsung Electronics Co.
`Samsung Austin Semiconductor, LLC:
`
`and
`
`Lrd.
`
`GREG AROVAS, ESQ.
`
`,JAMES MARINA, ESQ.
`
`JON CARTER, ESQ.
`
`CHRISTOPHER DE CORO, ESQ.
`
`Kirkland & Ellis LLP
`601- Lexington Avenue
`New York, New York 1-0022
`
`2L2 - 446 - 487 7
`
`greg . arovas@kirkland. com
`
`BAO NGUYEN, ESQ.
`
`Kirkl-and & Ellis LLP
`555 California Street
`San Francisco, CaIífornia 94L04
`
`4L5-439-L424
`
`bao. nguyen@kirkland com
`
`continued
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`1
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`202-347-3700
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`Ace-Federal Reporters, Inc
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`866-928-6509
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`Ex. 1011-0003
`
`
`
`APPEARANCES (CONIiNUCd):
`
`Page 846
`
`EDWARD DONOVAN, ESQ.
`F. CHRTSTOPHER VITZZO, ESQ.
`D . SEAN TRATNOR, ESQ .
`ABIGATL LAUER, ESQ.
`Kirktand & Ellis LLP
`655 Fifteenth Street Northwest
`Washington, DC 20005
`202-879-5289
`edward . donovan@ki rkl-and . com
`
`ERTC HAYES, ESQ.
`Kirkland & Ellis LLP
`300 North LaSalle Street
`Chicago, Illinois
`60654
`31,2-862-2480
`eric . hayes@kirkland. com
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`202-347-3700
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`Ace-Federal Reporters, Inc.
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`cont.inued
`866-928-6509
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`Ex. 1011-0004
`
`
`
`APPEARANCES (CONTiNUCd)
`
`I
`
`2
`
`Page847
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`-t
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`For Respondents NVIDIA Corporation; Biostar
`4 Mícrotech International Corp.; Biostar Mícrotech (usA)
`5 Corp.; El-íteGroup Computer Systems Co. Ltd; E1íteGroup
`,faton CorP. ;
`6 Computer Systems , Inc . ,' EVGA Corp; Fuhu, Irtc
`7 Mad Catz, Inc.; Ouya, frtc.¡ Sparkle Computer Co. Ltd';
`(lvtCO) Ltd. ; and ZOTAC
`
`8 Toradex, Inc. ,' ZOTAC International
`
`9 USA, Inc
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`202-347-3700
`
`RON SHULMAN, ESQ
`
`RICHARD FRENKEI,, ESQ.
`
`BRETT SANDFORD, ESQ.
`
`Latham & Watkins LLP
`
`1,4O Scott Drive
`
`Men]o Park, Caf ifornia
`
`94025
`
`650-328-4600
`
`ron. shulman@fw. com
`
`CLEMENT NAPLES, ESQ.
`
`MICHAEL DAV]D, ESQ.
`
`Latham & Watkins LLP
`
`885 Third Avenue
`New York, New York 10022
`
`2L2-906-r-200
`
`clement . naples@lw. com
`Ace-Federal RePorters, Inc
`
`continued
`866-928-6509
`
`Ex. 1011-0005
`
`
`
`I
`
`AppEARANCES (Continued):
`
`Page 848
`
`BERT RETSER, ESQ.
`
`MAXIMILIAN GRANT, ESQ.
`
`MATTHEW AICHEI-.,E, ESQ.
`Latham & Watkins LLP
`555 El-eventh Street, NW,
`Washington, DC 20004
`
`202- 637 -2200
`bert . reiser@lw. com
`
`suite 1000
`
`,fuI,rE HoLLOWAY, ESQ .
`Latham 6. Watkins LLP
`Street, Suite 2000
`California
`94'l,LI
`
`505 Montgomery
`San Francisco,
`
`4l.5-391--0600
`j ulie . holloway@lw. com
`
`PHILIP WANG, ESQ.
`
`BRÏAN LEWTS, ESQ.
`Latham & Watkins LLP
`355 South Grand Avenue
`Los Angeles, Cafífornia 90071
`
`2:l3-485-1-234
`phitip . wang@lw. com
`Ace-Federal Reporters, Inc.
`
`continued
`866-928-6509
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`202-347-3700
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`Ex. 1011-0006
`
`
`
`1 APPEARANCES (CONTiNUCd) :
`
`Page849
`
`KRISTOPHER DAV]S, ESQ
`
`DALE CHANG, ESQ.
`
`Latham & Watkins LLP
`330 North Wabash Avenue, Suite 2800
`
`Chicago, fllinois
`
`6061-l-
`
`3t2-876-7100
`
`kris . davís@1w. com
`
`On behalf of the International Trade Commission,
`Office of Unfair Import Investigations:
`
`YONCHA KUNDUPOGLU, ESQ
`
`ANNE GOALWIN, ESQ
`
`DAVID LLOYD, ESQ.
`United States fnternational Trade Commission
`Office of Unfair Import Investigations
`500 E Street, SW
`
`l,rtrashington, DC 20436
`
`202-205-3323
`yoncha . kunduPoglu@us itc . gov
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`866-928-6509
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`Ex. 1011-0007
`
`
`
`PROCEEDINGS
`
`Page 850
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`2
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`.J
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`4
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`9
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`JUDGE SHAW: Good morning
`We remain on the publíc record
`We were in the midst of examination of
`5 Mr. McAlexander
`And whaÈ other news do you have for me this
`6
`7 morning, Mr. Arovas?
`MR. AROVAS: Nothing interesting, which I guess
`8
`is probably good ne\¡/s. I can teLl your Honor
`\^Ie can do
`it at the end of all of the examinations, but all of the
`exhibit and other issues have been worked out \^/ith the
`ll
`reafly effectively worked
`12 exception of one, although it's
`13 out .
`There was that one CDX that your Honor may
`14
`15 recall that your Honor talked about welI, we didn't want to
`it
`16 get into it, we wouLd provisionally admit it, and if
`rea]ly mattered for someone to make a motion or somethíng,
`l7
`they could.. We have all agreed to provisionally admít it,
`18
`lg and as the record goes forward, people will- decide if they
`is a CDX, not CX. It ís
`20 want to raise any issues. But it
`2l a demonstrative, in anY event.
`f can say there's agreement on
`With that,
`to close the record
`JUDGE SHAÍü: And the court reporter has all the
`we need to give her?
`Ace-Federal RePorters, Inc.
`
`22
`
`23 everythíng
`
`24
`
`25 1ísts that
`202-347-3700
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`866-928-6509
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`Ex. 1011-0008
`
`
`
`Page 851
`
`MR. AROVAS: I think at the end we wi]].
`2 have not actually handed them up, but we will when
`3 Mr. McAl-exander is done.
`,JUDGE SHAW: Before I say the magic words that
`the record ís c]osed?
`
`4
`
`5
`
`We
`
`6
`
`7
`
`MR. AROVAS: Exactly.
`
`JUDGE SHAW: Okay.
`
`MR. AROVAS: So with that, Mr. McAlexander's
`
`9 witness statements, since they \¡/ere combined between the
`t\^ro patents, they're already in f ront of hím and identíf ied
`l0
`into
`
`11 and moved in. So I think we can move directly
`12 cross-examination.
`
`13
`
`14 Whereupon,
`
`,JUDGE SHAW: Sounds very good. Let ' s do so
`
`.]OSEPH C. MC ALEXANDER
`l5
`16 resumed the stand and, having been previously duly sworn,
`further as follows:
`17 was examined and testified
`
`CROSS - EXAMINAT]ON
`
`BY MS. HOLLOWAY:
`
`Good morning, Mr. McAl-exander
`
`o A
`
`18
`
`19
`
`20
`
`2l
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`22
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`Good morning
`I don't expect to keep you very long. We shal1
`o
`23 see. But in order to keep the testimony focused, Itm not
`24 going to ask you anything about claim construcÈion. We've
`on the Lai
`25 already covered that. And I'm going to focus
`202-347-3700
`866-928-6509
`Ace-Federal Reporters, Inc.
`
`Ex. 1011-0009
`
`
`
`1 patent and the seo patent, Rx-24 and 32, with which you're
`familiar. And I'm just going to focus on the features that
`2
`3 are relevant to independent claim 1-. Okay?
`4
`A
`
`Page 852
`
`Yes.
`Let's start wíth the Lai reference. Let's look
`5
`Q
`6 at f igure IL, please. The Lai patent discl-oses a memory
`7 control]er wíth a data strobe receiver that can interface
`8 with single ended and dífferential- data strobes; right?
`That's correct
`9A
`We tafked about single ended and differential,
`100
`1l .'think, yesterday.
`figure L1., shows one
`This figure,
`data strobe receiver; right?
`of such a
`That is
`correct.
`And I think Lai refers to this as a real-life
`
`I
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`example
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`example?
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`A
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`I believe that is correct, Yês.
`And as we discussed yesterday, in single ended
`O
`mode, the data strobe signal is compared wíth a reference
`voltage; right?
`That ís correct.
`A
`And in differential mode, the data strobe signal
`O
`ís compared with the inverse data strobe signal; right?
`That is correct.
`And in this figure,
`
`the data strobe signal ís
`
`A o
`
`25 DQS, as werve
`202-347-3700
`
`seen before?
`Ace-Federal Reporters, Inc.
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`866-928-6509
`
`Ex. 1011-0010
`
`
`
`Page 853
`
`I
`
`A
`
`That's correct.
`Let's do a comparison of figure 8 from the | 734
`2
`Q
`3 patent and figure 1-1 from the Lai patent. And this slide
`4 we are going to cal-l RDX-0015. Because \,r¡erve focused on
`Irve taken the driver circuits out
`the e1ements of claim l,
`5
`6 of the fígure 8.
`Do you see that there? We have figure 8 with
`7
`removed on one side and figure l-1 from
`8
`the driver circuits
`the Lai patent on the other side?
`
`9
`
`Yes, I see that.
`So l-et's focus on the muLtiplexer and
`differential amplifier features that we see. Okay? Now,
`figure 8A of the '734 patent shows a mul-tiplexer; correct?
`Yes,' that' s correct
`And in f igure 8A of the 1"734 patent, one input
`o
`to the multiplexer is a reference voltage labeled Vref;
`right ?
`
`A o
`
`A
`
`A
`
`Yes; correct.
`And the other input to the multiplexer is data
`o
`strobe bar, an inverse data strobe signal; right?
`That is correct.
`
`A
`
`ís called DQSB-2 in
`
`And that data strobe signal
`a
`this figure; right?
`That is correct.
`figure 8A of the '734 patent, the
`No\¡r, if
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`202-347-3700
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`Ace-Federal Reporters, Inc.
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`866-928-6509
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`Ex. 1011-0011
`
`
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`1 muLtiplexer receíves a selection signal-; correct?
`2
`A
`
`Yes.
`
`Page 854
`
`6
`
`3QAndthatselectionsignaliscalledthemode
`4 signal in the '734 Patent; right?
`That ís correct.
`A
`5
`And based on the selection signal, one of the
`Q
`inputs to the multiplexer is output to one input of the
`7
`8 differential amPlifier; right?
`That ís correct.
`9
`A
`In other words, based on the mode signal, either
`l0
`O
`11 vref or data strobe bar will go to the minus input of the
`12 differentíal amPlifíer; righL?
`13
`A
`Correct.
`And the other input to the dífferential
`14
`O
`15 amplífier is the data strobe signal, labeled DQS-2; right?
`Yes; that's correct.
`16
`A
`Now letrs move over to f igure 1-]- of the I,aí
`17
`a
`18 patent. Figure 1l- of Lai afso shows a mu]tiplexer;
`19 correct ?
`20
`A
`
`Yes, it does.
`And in figure Ll- of Lai, one input to the
`21
`O
`22 multiplexer ís a reference voltage ]abeled vref; right?
`That is correct.
`23
`A
`And the other input to the mul-tiplexer is DQM,
`24
`O
`25 which is the inverse of data strobe DQS; right?
`Ace-Federal Reporters, Inc'
`202-347-3700
`
`866-928-6509
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`Ex. 1011-0012
`
`
`
`Page 855
`
`output
`
`A
`
`A o
`
`A
`
`O
`A
`
`O
`
`Yes, that's correct.
`And in figure 1-l- of Lai, the multiplexer
`o
`receives a seLection signal called MSEL,' correct?
`That's correct.
`And based on that sel-ection signaL MSEL, one of
`the inputs to the multiplexer ís output to one input of the
`6
`7 circuít 1-004; correct?
`That is correct.
`A
`l-004' The
`We have just highlighted circuit
`O
`l-004 is the data strobe sígnal
`other input to the circuít
`DQS; correct?
`That is correct.
`l-004 is cal]ed a buf f er; right?
`And círcuit
`That is correct.
`And the buffer provides a differential
`
`2
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`3
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`5
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`25
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`DQSI; right?
`A
`
`O
`A
`
`A
`
`o
`
`That's correct.
`Okay. And a buffer may amplífy; correct?
`It maY.
`All right. And we can keep that up on the
`O
`talk a litt1e bit more about what Lai
`screen. We will
`discloses. Now, Lai discloses QDR, QER, QBM, and DDR
`memories; right?
`That is correct
`QER, QBM, and DDR are different
`Ace-Federal RePorters, Inc.
`
`types of
`
`866-928-6509
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`202-347-3700
`
`Ex. 1011-0013
`
`
`
`I memories; correct?
`
`Page 856
`
`2
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`A
`
`that
`
`Yes.
`the data strobe signal
`Okay. In Lai, if
`3
`Q
`In Lai, if
`the
`Let me ask that again'
`4 can't be right.
`5 data strobe buffer receives a data strobe from a data
`6 strobe or QDM, it will compare the data strobe signal to a
`reference voltage; correct?
`7
`ít is set up for one or Lhe other'
`In Lai, if
`A
`then it will compare to that one or the other, Yês'
`the memory type is DDR or QBM' then
`Okay. So if
`O
`the data strobe buffer will compare the data strobe sígna1
`with a reference voltage; right?
`it's set up and
`Yes, in one or the other, if
`A
`configured for one, it wí1I compare it according to the one
`is communicating with.
`it
`Why don't we back up a líttle here just so \^¡e
`O
`In DDR- or QBM-type
`are clear what werre talking about.
`memories, the data strobe signal is a single ended signal;
`19 right ?
`
`8
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`9
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`isa
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`23
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`24
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`then?
`
`25
`202-347-3700
`
`A
`
`YeS
`And in QDR-type memory, the data strobe signal
`O
`differential--type data strobe signal; right?
`That is correct, Yes.
`A
`Compared with an inverse data strobe signal,
`
`O
`
`Ace-Federal Reporters, Inc.
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`866-928-6509
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`Ex. 1011-0014
`
`
`
`Page 857
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`A o
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`A o A
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`25
`further
`202-347-3700
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`Now, your opiníon that Lai does not dísclose the
`opinion that,
`configured el-ement is based on your
`866-928-6509
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`That's correct.
`the memory type is either DDR or
`Okay. So if
`3 QBM ín Lai, when the data strobe buffer receives a data
`then compare the data strobe signal to a
`4 strobe, it will
`reference voltage; ríght?
`5
`That is correct, yes.
`the data strobe receiver received
`And in Lai, if
`it's
`8 a data strobe signal from a QDR-type memory, if
`talking to a QDR, ít will compare the data strobe signal
`9
`inverse data strobe signal; right?
`10 with an
`If it's configured that waY, Yes.
`If the memory is a QDR; right?
`it's configured for QDR, if
`Yes, if
`14 QDR, it wíll do the comparison.
`It's your opinion that Lai does not disclose the
`15
`O
`further configured aspects of the claims; right?
`That's correct.
`A
`to be
`And ít's your opinion that the ability
`O
`further confígured, which you believe requires the ability
`19
`is the point of novelty
`to perform dynamic reconfiguration,
`20
`2l of the '734 patent; right?
`Yes, both configured and further configured are
`22
`A
`23 availab]e.
`240
`
`it receives
`
`Ex. 1011-0015
`
`
`
`1
`
`9
`l0
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`11
`
`12
`
`in Laí, the buffer wil-l be connected to only one type of
`2 memory,'correct?
`That is correct.
`3
`A
`that cfaim l- covers a
`But you will agree, sir,
`4
`Q
`5 data strobe buffer designed to include all elements of the
`6 claim, regardless of whether it's connected to only one
`7 memory chip; right?
`Could you rephrase the question, please?
`8
`A
`üfhy don't I ask it again. But you agree that
`Q
`cl-aim 1 covers a data strobe buffer that is designed to
`incfude all el-ements of the claím, regardless of whether it
`is connected to only one memory chip?
`The reason I asked for a clarification,
`13
`A
`is
`14 speaking specifically c1aím l- of the I J34, and it
`it cLaims a structure in which both
`is
`15 designed and it
`16 of two modes are availabLe. And yes, ín order to practice
`that claim and, of course, al-l the el-ements have to be
`17
`
`Page 858
`
`yourre
`
`18
`
`f ound.
`
`Cou1d you, please, answer the question I am
`19
`O
`In your opinion, does claim 1 cover a data strobe
`20 asking.
`2l buffer that is designed to include al-L el-ements of claim 1-,
`is connected to only one memory
`22 regardless of whether it
`23 chip?
`
`The
`
`24
`A
`25 structure has
`202-347-3700
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`claim is designed in such a way
`both configurations available
`Ace-Federal RePorters, Inc.
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`that the
`And so that
`866-928-6509
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`Ex. 1011-0016
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`Page 859
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`I
`
`can be used, whether it's a single memory chip or multiple
`2 memory chips.
`Was that a Yes?
`3
`Q
`I'm trying to answer yes/ but I
`I belíeve
`A
`4
`5 believe that's the qualification of ít, yes'
`Okay. So you do agree that cl"aim l- covers a
`6
`Q
`7 data strobe buffer that is designed to incfude afl elements
`8 of claim 1, regardless of whether ít is connected to only
`9 one memory chiP?
`That's correct, it's a structure claim'
`10
`A
`Exactly. So you agree, of course' that claim l-
`O
`taLk about claim l-'
`nor cl-aim 3, I suppose, but let's
`12
`13 you agree the claim does not requíre that a device actually
`14 operate in both modes; correct?
`15ANo,it.sastructurecfaim.Itrequiresthat
`16 both modes be available.
`Is it
`Okay. Perhaps my question hlasn't clear'
`17
`O
`true that the claim does not require that a devíce actually
`1g
`19 operate in both modes?
`That's correct.
`20
`A
`
`11
`
`2l
`
`Thank You.
`
`O
`22okay.So]-et'stalkaboutwhetherthememory
`23 controll-er in Laí can operate in two different modes ' Now,
`in Laí can be moved
`24 you agree that the memory controfler
`from one type of memory system to another; correct?
`25
`Ace-Federal Reporters, Inc'
`202-347-3700
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`866-928-6509
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`Ex. 1011-0017
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`
`
`A
`
`Yes. You can take the buffer controlLer
`
`Page 860
`in Lai,
`
`2 put it
`
`into a different system.
`Okay. So in a first system, the memory
`O
`in Lai, the data strobe buffer' can be
`4 controfler
`5 configured to operate in a first mode; right?
`They can be, Yês.
`is moved to a different system wíth a
`it
`And if
`O
`then be confígured to
`s different kind of memory, it will
`9 operate in a different mode; right?
`It can be, Yês.
`It will be, wonrt it?
`Wel1, that's up to the designer, but it can be
`just see what you say at your
`Wel1, let's
`d.eposition, sir. Could we have page 647, íf you coul-d turn
`to that, please. Line 20, through the next page at líne 5
`Do you have it?
`I'm getting there.
`Yes, 647, starting
`O
`page 648, l-ine 5.
`A
`
`f rm at 647
`Okay.
`aÈ line 20, and going on to
`
`Okay.
`
`A
`
`A o A o
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`A
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`J
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`6 ,
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`7
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`l0
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`11
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`17
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`20
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`2t
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`22
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`23
`
`24
`
`So if the memory controfler
`O
`"Question: OkaY.
`configured to be oPerated
`of Lai is in a first
`system and
`to a different sYstem with a
`it's moved
`if
`in a first mode,
`memory it will- then be configured to
`type of
`different
`a different mode; is that correct?
`25 operate in
`Ace-Federal RePorters, Inc.
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`Ex. 1011-0018
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`Page 861
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`5
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`A
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`'Answer: Yeah, which is outside the scope of
`I
`for being
`1734 identífies
`2 what the claim of the 76
`3 configured and further configured. "
`That was Your testimonY; right?
`4
`You started reading at line l-0?
`No, ûo, ro, l-ine 20. V'lould you 1íke me to read
`
`6
`
`Q
`7 again?
`8
`
`Oh, excuse me. f 'm with you no\¡I . Yes, that is
`A
`9 what I said.
`That is what you said? Okay, good. Sorry about
`O
`the confusion. Let's turn to the seo reference, RX-0032.
`talk about what Seo discloses. Can we focus on
`And we will
`figure 2 of Seo. Figure 2 of Seo shows a data strobe
`signal, DQS; correct?
`Yes; that's correct.
`A
`And. afso a data strobe bar signal, DQSB; right?
`Correct.
`
`l0
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`l1
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`12
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`O
`A
`
`And a voltage, a reference voltage,
`All-righty.
`O
`a reference voftage Vref; right?
`Also correct.
`A
`No\^/, there ís a control signal which the patent
`O
`caf l-s CNT/CNTB f or short; ríght?
`That is correct.
`A
`Okay. And CNTB is basically the inverse of CNT;
`
`Ace-Federal Reporters, Inc
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`24
`
`O
`25 right?
`202-347-3700
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`Ex. 1011-0019
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`
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`Page862
`
`That is correct.
`Using the bar terminology that we see sometimes?
`That is correct.
`rrBrr standing for bar?
`
`A
`
`O
`A
`
`O
`A
`
`Yes.
`Okay. Because inverse in engineering is
`O
`sometimes shown as the name with a bar on top?
`That ís correct.
`A
`Okay. In the embodiment of figure 2 of Seo, if
`it will pass DQSB and
`the controL signal is at one level,
`not Vref to the differential- amplífíer; right?
`
`Yes
`
`And that's
`
`these two switches operating here?
`
`Correct.
`And then in that case, DQS and DQSB wi]l be
`o
`compared by the differentíal amplifier; correct?
`
`A
`
`Yes.
`Okay. If the control signal is at another
`O
`levef, Vref and not DQSB will be passed to the differential
`right?
`
`amplifier;
`
`A o A
`
`2
`
`J
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`4
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`5
`
`6
`
`7
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`9
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`10
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`20
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`22
`
`23
`
`24
`
`Yes.
`And then DQS will be compared wíth Vref; ríght?
`That is correct
`In other words, in response to the control
`di fferential 1y
`data strobe input buffer
`Ace-Federal RePorters, Inc.
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`A o A o
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`25 signal, the
`202-347-3700
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`Ex. 1011-0020
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`Page 863
`or the
`
`A
`
`J
`
`4
`
`5
`
`I amplifies the data strobe and the reference voltage
`2 ð,aLa strobe and. an inverse data strobe; right?
`Correct.
`Okay. Let's talk about that controf signal, how
`O
`Í{e've tal-ked about your opinion about the point
`it works .
`of novelty of the 1734 patent. so f want to focus on that,
`how Seo coul-d be reconf igured. And again, that's a
`function of the control signal; right?
`That is correct.
`A
`Okay. Now, as we've already díscussed, that
`O
`control signal is what determines whether DQS, the data
`strobe, is compared with Vref or wíth DQSB, the inverse
`data strobe sígnal; right?
`A
`
`6
`
`7
`
`8
`
`9
`
`10
`
`1l
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`t2
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`r3
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`
`16
`
`t7
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`18
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`l9
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`20
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`2l
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`22
`
`23
`
`Yes.
`that Seo wíl-I be
`Okay. Now, you've testified
`O
`set to use one mode and not use the other, and it can't be
`taken off l-íne; right?
`set differently unless it's
`A
`Correct.
`that the control signal ín
`And you've testifíed
`O
`Seo cannot be changed from an external command; right?
`That is correct.
`A
`Okay. But you agree that the control signal is
`O
`generated by receiving an external command; right?
`That is correct.
`
`24A
`2so
`
`202-347-3700
`
`in the Seo
`is,
`Okay. And the fact
`Ace-Federal RePorters, Inc.
`
`| 602 patent,
`866-928-6509
`
`Ex. 1011-0021
`
`
`
`Page 864
`the modes of the data strobe buffer are easily configured
`externally; right?
`They are easily confígured externally, yes.
`A
`Now, you read Seo carefully before you offered
`O
`your opínions in this case; right?
`I believe so, yes.
`A
`But at your deposition, you had not seen whether
`O
`Seo teaches using an external command to determine the
`operation mod.e of the semíconductor memory buffer; right?
`ro.
`I don't recall sPecificallY,
`A
`But Seo d.oes say that the levef of the control
`O
`signal is generated by receivíng an external- command;
`right?
`
`That is shown in fígure 4. An external command
`A
`activates the mode register set that's been previously
`
`conf igured .
`
`Running right ahead of me, sir. So you agree
`O
`that the control signal in Seo can be generated by a mode
`regíster set; right?
`Yes. That's one of the three ways that's
`A
`
`covered.
`
`I
`
`2
`
`3
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`4
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`5
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`6
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`7
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`
`16
`
`17
`
`18
`
`19
`
`20
`
`2l
`
`22
`
`23
`
`And this is the one I want to talk about. But
`O
`in your opinion, the mode register set is set and can only
`24 operate one way; right?
`It can only oPerate the waY it
`Ace-Federal RePorters, Inc.
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`25
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`A
`
`202-347-3700
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`is set, yes.
`866-928-6509
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`Ex. 1011-0022
`
`
`
`Page 865
`In your opinion,
`\^/hat I asked.
`That's not quite
`o
`the mode register is set and can only operate one way;
`right?
`
`2
`
`3
`
`4
`
`5
`
`It has to operate ín accordance with the way
`A
`it's set. So it can only be one way in accordance with the
`6 way ít is set.
`Is it your opinion that once the mode register
`0
`is set it will not be changed and wiLl only operate one
`9 way?
`
`7
`
`8
`
`is taken out of the operation and
`Yes, unless it
`A
`11 reset, ít can be changed or configured.
`The mod.e regíster set is something that is set
`12
`O
`13 by f irmware,' correct?
`It can be.
`14
`A
`Let's take a look at your deposition, please,
`15
`O
`16 page 606,lines 5 to L7, if you coufd turn to that page'
`I have it
`Okay.
`And the mode register set is
`by firmware; right?
`Which means it's set and it can onlY
`2l operate that way. And that's borne out in figure 6, which
`is a set of bond pads, and the controf signal can either be
`22
`23 hard-wíred to ground., firmware wired to ground, or
`firmware wired to VDD. It's one or the other.
`24
`to
`capability
`And so Seo has a buiLt in
`866-928-6509
`Ace-Federal Reporters, Inc.
`
`20
`
`firmware
`
`25
`It is not
`202-347-3700
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`both.
`
`A o
`
`t0
`
`t7
`
`r8
`
`" Quest ion :
`19 something that ís set
`trAnswer
`
`Ex. 1011-0023
`
`
`
`work with one system
`different system in
`cannot operate in a
`
`in one configuration and work with a
`a different configuration, but it
`system where both are operative.
`
`It's
`
`Page 866
`
`impossibfe. "
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`2
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`J 4
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`A
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`866-928-6509
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`Okay.
`
`rrQuestion:
`
`A o
`
`Okay. So are you saYing thaL
`a control- signal?
`firmware cannot change
`rrAnsv/er: This is a
`when you talk about a
`the answer is no."
`in a register,
`25 configuration
`Ace-Federal Reporters, Inc.
`202-347-3700
`
`that testimony; right?
`You gave
`Yes,' that ' s correct .
`Okay. But yourve already agreed, ín the Seo
`Q
`r602 patents, the modes of the daÈa strobe register are
`8
`9 easily configured externallY?
`For a different sYSEem, Yês.
`A
`And you've testif ied that f irmware could not
`O
`change a control signal; correct?
`I'm not sure of the context. Firmware cannot
`A
`change the control signal?
`You've testified
`
`that
`
`O
`a control signal?
`l-ocked in,
`once it's
`A
`changed, and the control signal
`Let's take a look at
`
`O
`L4 to L7.
`
`firmware could not change
`
`It can be
`
`it can't.
`can be changed
`your testimony, 607, Iines
`
`5
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`6
`7
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`10
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`23
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`24
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`Ex. 1011-0024
`
`
`
`Page867
`
`in
`
`ftrs
`
`A
`
`A o A o A o
`
`You gave that testimonY; ríght?
`Yes, and I've clarified, not in an operation'
`So you're adding something to your testimony?
`Q
`If you l-ook at it
`No. I'm reading 1íne l-9.
`4
`A
`5 context, it says withín an operation youtre not going to
`in
`6 change it. You can go back and reconfigure stuff
`firmware, but not during operatíon.
`7
`You can talk about that with your counsel.
`o
`in a practical DRAM system firmware
` your opinion that
`dynamically change modes in an
`cannot be used to
`implementation that uses DDR DRAMs; ríght?
`In the context I said that, Yês, correct.
`lVhat did You saY?
`I 'm sorry.
`In the context that I say that, Yes.
`In the context that what?
`Repeat the question, Please.
`It's your opiníon that in a practical DRAM
`to dynamically change modes
`system, firmware cannot be used
`DDR DRAMs; ís that true or
`in an implementation that uses
`
`1
`
`2
`
`3
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`8 9
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`25
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`not ?
`
`A
`
`A
`
`That's correct.
`that one actuallY can
`Okay. But You agree
`O
`change modes using firmware, although it's your opinion
`ít will be very slow?
`that
`It will be slow and be during nonoperation.
`Ace-Federal Reporters, Inc.
`866-928-6509
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`202-347-3700
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`Ex. 1011-0025
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`Page 868
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`Okay. No\À/, one more point, the type of data
`O
`2 strobe buffer as discl-osed in Seo. It's your opinion that
`the Seo '602 patent discfoses and covers only data strobe
`3
`4 buffers that are used wíthin a DRAM; correct?
`I believe I made t.hat statement.
`
`5
`
`A
`
`I believe that
`
`is correct, yês
`That is your opinion?
`I believe that's what it supports. Yes, thatrs
`
`o A
`
`6
`
`7
`
`8
`
`9 my opinion
`
`ilm sorry. You changed your language a little
`o
`Is it your
`to make sure l¡/e're cf ear.
`bit here. So I want
`and covers only
`| 602 patent díscloses
`opínion that the Seo
`that are used within a
`data strobe buffers
`
`l0
`
`1l
`
`12
`
`13
`
`14
`
`DRAM?
`I was just
`think it's
`
`I
`
`is correct.
`that
`I believe
`that
`A
`15 rereading some of the sections here, and I
`that position's correct.
`is
`that
`be]ieve
`Okay. So what I said is true, that is your
`
`16 stíll
`
`17
`
`O
`18 opinion?
`
`A
`
`19
`
`20
`
`Yes.
`And ít's your opinion that the Seo '602 patent
`o
`is not directed to any type of buffer in a memory
`21
`right?
`22 controller;
`
`23
`
`24
`
`A
`
`O
`
`25 believes
`202-347-3700
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`Correct
`that Samsung
`Okay. But you are aware, sir,
`to a buffer
`the Seo '602 patent is directed
`866-928-6509
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`
`that
`
`Ex. 1011-0026
`
`
`
`Page 869
`
`right ?
`tn a memory controLler;
`I'm not aware. If you can point me to that.
`You're an expert in a case that Samsung has
`filed against NVIDIA in the Eastern District of Virginia;
`right?
`
`A O
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`16
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`f am, yes.
`Okay. And ín that case Samsung has asserted the
`O
`8 Seo '602 patent. You know that, don't you?
`I know that theY have, Yês.
`9
`A
`Okay. And you are aware, aren't you, that
`l0
`O
`l1 Samsung has accused NVIDIA's memory contro11ers of
`the Seo '602 patent, aren't you?
`12
`infringing
`I honestly have not done any work ín that case
`13
`A
`14 yet. So I can't state one way or the other.
`15
`So you don't know?
`As I sit here, I don't recaff.
`Okay. But if Samsung was accusíng memory
`17
`O
`the Seo '602 patent, that would
`18 controflers of infringing
`19 be, in your view, outside the claíms of the 1602 patent;
`20 right?
`I 'd have to go back and rel-ook at the claims.
`21
`A
`22 haven't studied those.
`But it's your opinion that Seo discloses and
`23
`O
`24 covers only data strobe buffers that are used within a
`25 DRAM; right?
`202-347-3700
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`I
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`Ace-Federal Reporters, Inc.
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`866-928-6509
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`Ex. 1011-0027
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`Page 870
`That is my opinion based upon the description
`
`that I
`
`read, y€s.
`Okay. And you are al^/are that NVIDIA does not
`
`IA
`
`2
`
`3Q
`
`4 make DRAMs?
`
`5
`
`6
`
`7
`
`8
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`9
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`A
`
`Say again? Yes, f am aware of that.
`
`MS. HOLLOWAY: Thank You.
`that I have.
`That's all
`JUDGE SHAW: Thank you, Ms. Holloway.
`MS. KUNDUPOGLU: Staff has no questions' your
`
`10 Honor.
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`,IUDGE SHAVü: VerY wel-I.
`
`REDIRECT EXAMINATÏON
`
`BY MR. AROVAS:
`Good morning, Mr. McAl-exander.
`
`Good morning.
`MR. AROVAS: And your Honor, RâY I proceed?
`,JUDGE SHAW: Yes, Please.
`MR. AROVAS: Thank You.
`
`o
`actually to
`
`maybe we can
`
`t9
`
`20
`
`2t
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`22
`
`23
`
`24
`
`is
`to start
`common ground, so
`
`BY MR. AROVAS:
`So where I think I would like
`establish where therers some
`the actual
`identify with precísion what
`between the parties on the issues in your
`disputes are
`rebuttal- witness statement. Okay?
`25
`A
`202-347-3700
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`Okay.
`
`Ace-Federal Reporters, Inc.
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`Ex. 1011-0028
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`
`1
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`o
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`2 before
`3 at the
`
`Page 871
`I know, because you've been asked this question
`about whether You were
`when you testif ied l-ast time,
`the opening, but Irm
`opening, I know You weren't at
`for the
`opening solelY
`to show you one slíde from the
`4 going
`art
`what the Prior
`5 purposes of identifying an issue of
`6 covers and doesn't cover and see if we can identify where
`in your
`the parties agree and where the parties don't,
`7
`8 opinion. Okay?
`9
`A
`
`l0
`
`16
`
`17
`
`I¡lerre
`just
`
`Okay.
`so what f'm putting on the screen is one of the
`o
`I d.on't see a number on it . But j-t' s the
`11 opening slíd.es.
`12 slid.e titled nt734 patent's static confíguration versus
`I'm going to cover up
`13 NVID]A's dynamic configuration"
`the NVIDIA side, because I'm not asking about that.
`14
`I read the title
`okay.
`just focusing on ínvalidity.
`15
`for identification.
`So what the Respondents said in the opening is
`that the prior art Lai buffers static configuration based
`18
`19 on memory device type. Do you see that?
`f see that.
`20
`A
`Do we alL agree with the discl-osure of the prior
`21
`O
`22 art in that regard?
`My understanding is we do.
`23
`A
`24 with that.
`
`I certainly agree
`
`25
`
`o
`
`202-347-3700
`
`And when you vtere resPonding to
`Ace-Federal RePorters, Inc.
`
`Dr. Jacobs, was
`866-928-6509
`
`Ex. 1011-0029
`
`
`
`Page872
`
`I
`
`2
`
`3
`
`that your understanding of his reading as well?
`is.
`Yes, it
`A
`in the oPening
`the 1734 buffers,
`Now, for
`o
`a static configuration based
`4 statement NVIDIA said that is
`5 on memory device type. Do the sides agree on that point?
`
`No.
`So this is a point where and you Dr. Jacobs
`o
`8 disagree; right?
`That's correct.
`And we also heard about the Lai
`l0
`true, for the Seo reference as
`11 Seo reference. And is it
`is an architecture that
`that both parties agree it
`12 we11,
`to a static configuration based on memory device type?
`That is correct, Yês.
`A
`Okay. So we have basic agreement on the core
`O
`16 disclosure of the prior art; right?
`Yes, that the core d.j-scl-osure of the príor art
`
`6
`
`7
`
`9
`
`l3
`
`14
`
`15
`
`t7
`
`goes
`
`I mean the
`
`A
`
`A o
`
`A
`
`18
`
`is static.
`
`19
`
`So what I woufd l-ike to do is I would like to
`o
`talk for a moment about this concept of static versus
`20
`2l multiple availabl-e modes with regard to operation, take a
`look at a couple of the references, and then see how that
`22
`than the claims that werre dealing with in
`is different
`this case. Okay?
`
`23
`
`24
`
`A
`
`Okay
`
`25
`
`202-347-3700
`
`Ace-Federal Reporters, Inc.
`
`866-928-6509
`
`Ex. 1011-0030
`
`
`
`Page 873
`
`I
`2
`
`just be for a moment'
`and this wíIl
`So f i-rst
`Q
`lrm not going to put the c1aím on the screen, but you \^¡ere
`shown a question and an answer from your deposition from
`3
`ft
`4 pages 647 to 648. I will put that on the screen.
`5 started at line 20.
`t'Question: Okay. So if
`the memory controLler
`6
`7 of Laí is ín a first system and configured to be operated
`j-t's moved to a different system with a
`in a first mode, if
`8
`then be configured to
`type of memory it will
`9 different
`operate in a different mode; is that right?
`I'Answer: Yeah, which ís outside the scope of
`what the cl-aim of the ,734 identifies
`for being configured
`and further configured. "
`Do you remember seeing that testimony?
`
`t0
`
`l1
`
`t2
`
`l3
`
`t4
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`A
`
`werre getting
`
`Yes, f do.
`No\¡/, ín the very next question, whích you were
`O
`not shown, you were asked and why ís it outsíde the scope
`of what is in the cfaim of the '734 with regard to this
`that we wifl
`configured and. further configured limitation
`look at a little bit Later. And you províded an ans\^Ier.
`Can you explain for us what the dif
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