Transcript of Joseph C. McAlexander, III
`
`Date: March 22, 2016
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`Case: Nvidia Corp. -v- Samsung Electronics Co., Ltd. (PTAB)
`
`Planet Depos, LLC
`Phone: 888-433-3767
`Fax: 888-503-3767
`Email: transcripts@planetdepos.com
`Internet: www.planetdepos.com
`
`Worldwide Court Reporting | Interpretation | Trial Services
`
`Ex. 1013-0001
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`
`
`Date: March 22, 2016
`
`Case: Nvidia Corp. -v- Samsung Electronics Co., Ltd. (PTAB)
`
`Planet Depos, LLC
`Phone: 888-433-3767
`Fax: 888-503-3767
`Email: transcripts@planetdepos.com
`Internet: www.planetdepos.com
`
`Worldwide Court Reporting | Interpretation | Trial Services
`
`Ex. 1013-0001
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`1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` ____________________________
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` ____________________________
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` NVIDIA CORP.
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` Petitioner
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`
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` V.
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` SAMSUNG ELECTRONICS CO., LTD.
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` Patent Owner
`
` ____________________________
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` Case IPR2015-01068
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` U.S. Patent No. 7,804,734 B2
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` ____________________________
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` VIDEO DEPOSITION OF JOSEPH C. McALEXANDER III
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` SAN FRANCISCO, CALIFORNIA
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` TUESDAY, MARCH 22, 2016
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` 9:09 A.M.
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`Job No. 105151
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`Pages 1 - 134
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`Reported by: Anne M. Torreano, CSR, RPR, CCRR, CLR
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`Ex. 1013-0002
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`
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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` Videotaped deposition of JOSEPH C.
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`McALEXANDER III, held at the offices of:
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`2
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` LATHAM & WATKINS LLP
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` 505 Montgomery Street, 20th Floor
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` San Francisco, California 94111
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` (415) 391-0600
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` Pursuant to Notice, before Anne M. Torreano,
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`California Certified Shorthand Reporter #10520,
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`Registered Professional Reporter, California
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`Certified Realtime Reporter, Certified LiveNote
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`Reporter.
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`Ex. 1013-0003
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`3
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` A P P E A R A N C E S
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`FOR THE PETITIONER:
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` LATHAM & WATKINS LLP
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` BY: JULIE M. HOLLOWAY
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` BY: BRETT M. SANFORD
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` 505 Montgomery Street, Suite 2000
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` San Francisco, California 94111
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` (415) 391-0600
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` julie.holloway@lw.com
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` brett.sanford@lw.com
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`FOR PATENT OWNER:
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` KIRKLAND & ELLIS LLP
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` BY: BAO NGUYEN
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` 555 California Street
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` San Francisco, California 94104
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` (415) 439-1425
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` bao.nguyen@kirkland.com
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`ALSO PRESENT:
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` JOSEPH MOURGOS, Videographer
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`PLANET DEPOS
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`Ex. 1013-0004
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`4
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` EXAMINATION INDEX
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`JOSEPH C. McALEXANDER III PAGE
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` BY MS. HOLLOWAY 6
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` REDIRECT BY MR. NGUYEN 98
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` EXHIBIT INDEX
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` McALEXANDER PAGE
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` EXHIBIT 1009 Hearing transcript dated August 16
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` 19, 2015, in re Matter of Certain
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` Graphics Processing Chips
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` EXHIBIT 1010 Transcript of Joseph C. 23
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` McAlexander, Volume 2, July 1
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` 2015
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` EXHIBIT 1011 Partial hearing transcript dated 28
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` August 21, 2015 in re Matter of
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` Certain Graphics Processing Chips
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` EXHIBIT 1012 United States Patent 7,173,871 B2 94
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` (Marked previously as NVIDIA
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` Corp. Exhibit 1004)
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`Ex. 1013-0005
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`
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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` TUESDAY, MARCH 22, 2016; 9:09 A.M.
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` THE VIDEOGRAPHER: Here begins disk No. 1 in
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`5
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`09:08:47
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`09:08:47
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`the videotaped deposition of Joseph C. McAlexander in
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`09:09:07
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`the matter of NVIDIA Corporation versus Samsung
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`Electronics Company Limited in the United States
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`Patent and Trademark Office before the Patent Trial
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`and Appeal Board. The case number is IPR2015-01068.
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` Today's date is March 22nd, 2016, and the
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`time on the video monitor is 9:09 a.m. The
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`videographer today is Joseph Mourgos, representing
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`Planet Depos.
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` This video deposition is taking place at
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`505 Montgomery Street, Suite 2000, San Francisco,
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`California.
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` Would counsel please voice identify
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`yourselves and state whom you represent?
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` MS. HOLLOWAY: Julie Holloway from Latham &
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`Watkins for the petitioner, NVIDIA. And with me is
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`Brett Sanford, also from Latham & Watkins, also for
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`Petitioner.
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` MR. NGUYEN: Bao Nguyen from
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`Kirkland & Ellis representing the patent owner,
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`Samsung, and Mr. McAlexander.
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` THE VIDEOGRAPHER: Thank you.
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` The court reporter today is Anne Torreano,
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`Ex. 1013-0006
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`
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`6
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`representing Planet Depos.
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` Would the reporter please administer the
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`oath?
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` JOSEPH C. McALEXANDER III,
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` having been duly sworn to tell the truth,
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`testified as follows:
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` EXAMINATION
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`BY MS. HOLLOWAY:
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` Q. Okay. Good morning, Mr. McAlexander.
`
` A. Good morning.
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` Q. We've met before?
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` A. Yes.
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` Q. Let's start with the patent that's the
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`subject of this inter partes review, U.S. Patent
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`No. 7,804,734. This has been previously marked as
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`Exhibit 1001. And that will be the court reporter
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`copy, what I've given you.
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` Let's call this the '734 patent. Okay?
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` A. Sure.
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` Q. All right. Now, you were Samsung's expert
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`on the '734 patent in an ITC investigation; correct?
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` A. That is correct.
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` Q. And in that ITC investigation, NVIDIA
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`asserted the Lai patent and Kong patent as prior
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`art; correct?
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`Ex. 1013-0007
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`
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`7
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` A. That is correct.
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` Q. And I deposed you in that ITC
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`investigation; correct?
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` A. Yes.
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` Q. And you testified at the hearing in that
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`ITC investigation?
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` A. Correct.
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` Q. Okay. We've got the '734 patent before
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`you.
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` You're familiar with the '734 patent?
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` A. Yes, I am.
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` Q. Have you read it many times?
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` A. Yes, many.
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` Q. How many?
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` A. How many times?
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` Q. Roughly.
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` A. Ten, twelve times.
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` Q. The last time you did dynamic RAM design
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`was when you left Texas Instruments in 1986; right?
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`09:11:56
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` A. Actual design, yes, that's correct.
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`09:11:59
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` Q. Okay. And you've never designed DDR SDRAM
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`09:12:01
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`memories; correct?
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` A. That is correct.
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` Q. You've been involved in a lot of patent
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`cases in your -- in your career; correct?
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`Ex. 1013-0008
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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` A. I have been involved in a few, yes.
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` Q. You've been deposed more than a hundred
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`times; right?
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` A. Yes.
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` Q. Okay. And those were patent cases
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`primarily; right?
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` A. Patent and trade secret.
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` Q. Okay. Now, the '734 patent uses numbers to
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`refer to various components of the embodiments
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`described in the patent; correct?
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` A. It does that, yes.
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` Q. And that's a common practice with patents;
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`right?
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` A. Yes.
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` Q. Okay. And in the '734 patent, like numbers
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`refer to like elements throughout the patent; right?
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` A. That's the intent, yes.
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` Q. Okay. And that's what the patent actually
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`says; right?
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` A. Yes.
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` Q. Okay. And that's, again, a common practice
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`with patents in your experience?
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` A. That's correct.
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` Q. Okay. So in other words, comparator 120 is
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`the same element in each of the drawings; correct?
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`Ex. 1013-0009
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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` MR. NGUYEN: Objection. Vague.
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` THE WITNESS: It is the same functional
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`symbol in each of the drawings where the reference
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`number 120 is used, yes.
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`BY MS. HOLLOWAY:
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`09:13:08
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`09:13:09
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` Q. Okay. And it's referring to the same type
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`of circuit in each of the drawings?
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` A. It's --
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` MR. NGUYEN: Objection. Vague.
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`09:13:11
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` THE WITNESS: What do you mean by "the same
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`type of circuit"?
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`BY MS. HOLLOWAY:
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` Q. Well, the patent says that like numbers
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`refer to like elements. And there's a comparator
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`120 in each of these drawings. Right?
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` A. That is correct.
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`09:13:21
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` Q. And you understand that that comparator 120
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`09:13:24
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`is the same in each of the drawings; right?
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` MR. NGUYEN: Same objection.
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` THE WITNESS: It is the same functional
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`block called a comparator, and it might be
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`instantiated in different ways, but it is a
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`comparator. That's its function.
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`BY MS. HOLLOWAY:
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` Q. Okay. The same functional block.
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`Ex. 1013-0010
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`
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`10
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` And are you aware of any difference in the
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`09:13:40
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`instantiations between the different comparators?
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`09:13:43
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`Let me reask that question.
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` Are you aware of any difference in the
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`instantiation between the comparators in the
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`drawings of the '734 patent?
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` MR. NGUYEN: Objection. Vague.
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` THE WITNESS: There are differences in
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`terms of inputs, and therefore the decision
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`processing may be different, but it still functions
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`as a comparator.
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`BY MS. HOLLOWAY:
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` Q. Okay. Now, the '734 patent describes a
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`data strobe signal; right?
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` A. It does.
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` Q. Okay. And DQS is the symbol for a data
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`strobe signal; right?
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` A. Yes.
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` Q. The '734 patent also describes an inverse
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`09:14:23
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`data strobe signal; right?
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` A. That is correct.
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` Q. And DQS bar is the symbol for an inverse
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`data strobe signal; right?
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` A. That is common practice, yes.
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` Q. And it is sometimes abbreviated DQSB, or
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`Ex. 1013-0011
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`DQS with a bar over it; right?
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` A. That's correct.
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` Q. A data strobe signal is used to identify
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`when data that's being sent to or from a DDR SDRAM
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`is available to be captured; correct?
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` A. That is one of its uses, yes.
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` Q. So for a reoperation, a data strobe signal
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`is used to capture data that's being sent from the
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`memory; right?
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` A. The data strobe signal is not used to
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`capture. The data strobe signal is to indicate the
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`data's available for capture.
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` Q. Okay. So for a read operation, a data
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`strobe signal is used to indicate that the data is
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`ready to be captured when the data is being
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`sent from the memory; right?
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` A. Yes, it just says data is valid.
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` Q. Okay. And for a write operation, a data
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`strobe signal is used to indicate when data is
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`available to be captured when that data is being
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`sent to the memory; right?
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` A. It coincides with the data being sent.
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` Q. Okay. So to put it more briefly, then, for
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`12
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` A. For read, it's -- coincides with data being
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` Q. Oh, I wrote this wrong. Yes. Let me ask
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`that again.
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` So for a read operation, a data strobe
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`the memory?
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` A. Correct.
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` Q. Okay. All right.
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` Now, let's turn to figure 2 of the '734
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`patent.
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` Now, figure 2 includes a driver 110;
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`correct?
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` A. Yes, it does.
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` Q. Okay. Driver 110 outputs a first data
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`strobe signal during a write operation; correct?
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` A. It does, yes.
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` Q. And that first data strobe signal is
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`labeled DQS_1; correct?
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` A. Yes, that's correct.
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` Q. Okay. And the receiver 140 receives a data
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`strobe signal; correct?
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` A. Yes.
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` Q. And that data strobe signal is DQS_2;
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`correct?
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`13
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` A. In figure 2, yes, that's correct.
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` Q. Okay. So the circuit in figure 2 outputs a
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`during a read operation; correct?
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` A. All except the output is DQS_1, not DQS1.
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`But other than that, yes, it's -- it's true.
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` Q. Okay. So figure 2 shows an input/output
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`data strobe buffer; correct?
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` A. It is -- it can be characterized as such on
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` Q. Okay. Let's focus on the receive or input
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`part.
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` Now, figure 2 includes a comparator which
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`is labeled 120; correct?
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` A. Correct.
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` Q. Okay. And that comparator is a
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` Q. Okay. And figure 2 also includes a MUX
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`labeled 130; correct?
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` A. Yes.
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` Q. MUX is short for multiplexer; correct?
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` A. Correct.
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`Ex. 1013-0014
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`14
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` Q. The '734 patent sometimes refers to the
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`multiplexer 130 as a selector; correct?
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` A. I believe that that is correct. That is --
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`that is one of the functions that a multiplexer
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`does, is to select.
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` Q. Why don't we just take a look at the
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`patent, because I -- I have an impeachment on that,
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`but it seems silly to trot out the transcript for
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`this. I don't think there's any real dispute here.
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` A. It calls it a selector at column 4, line
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`18.
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` Q. Okay. Let me just ask the question again,
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`then.
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` The '734 patent sometimes refers to the
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`multiplexer 130 as a selector; correct?
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` A. Correct.
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` Q. And as you said, selection -- being a
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`selector is one of the functions that's performed by
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`a multiplexer; right?
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` A. Yes, correct.
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` Q. Okay. Now, the comparator 120 has two
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`inputs, one labeled plus and one labeled minus;
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`correct?
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` A. That is correct.
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` Q. And the comparator 120 has one output which
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`Ex. 1013-0015
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`
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`outputs the signal DQS_3; correct?
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` A. Also correct.
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` Q. Okay. The comparator 120 receives a second
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`data strobe signal, DQS_2, during a read operation;
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`correct?
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` A. That is correct.
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` Q. And the comparator 120 receives that second
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`data strobe signal at the input labeled "plus";
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`correct?
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` A. That is correct.
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` Q. The other input of the comparator 120 is
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`the output of the MUX; correct?
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` A. That is correct.
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` Q. The MUX 130 has only two inputs; correct?
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` A. That is correct.
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` Q. The two inputs on the multiplexer 130 are
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`labeled T1 and T2; correct?
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` A. That is correct.
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` Q. And T here stands for terminal; right?
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` A. Correct.
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` Q. Okay. The MUX 130 will only select one of
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`the two inputs shown; correct?
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` MR. NGUYEN: Objection. Vague.
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` THE WITNESS: Not correct.
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` MR. NGUYEN: Foundation.
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`Ex. 1013-0016
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`
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`BY MS. HOLLOWAY:
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` Q. It is not correct that the MUX 130 will
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`only select one of the two inputs shown?
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`16
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` A. That's correct.
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` Q. Okay.
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` A. It may select none.
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` MS. HOLLOWAY: Let's mark the next exhibit
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`Exhibit 1009.
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` Let me just take a look at this.
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` (McALEXANDER EXHIBIT 1009 MARKED.)
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`BY MS. HOLLOWAY:
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` Q. Exhibit 1009 is an excerpt from a hearing
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`of the ITC proceeding dated August 19th, 2019 [sic].
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`09:21:07
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`The case was Certain Graphics Processing Chips,
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`Systems on a Chip and Products Containing the Same,
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`Investigation No. 337-TA-941.
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` The document is marked as this document
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`09:21:11
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`contains confidential information. However, all the
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`09:21:22
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`pages included in this excerpt are from what is
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`called an open session, which is public information.
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` Just double-checking because we had to pull
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`a couple of pages out.
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` MR. NGUYEN: So I -- I'll -- I'll -- I
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`mean, is it your position that this doesn't have
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`Ex. 1013-0017
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`
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`17
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` MS. HOLLOWAY: That's correct.
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` Brett, could you just flip through it and
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`make certain we didn't leave any pages in.
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` But yes, it's all about claim construction
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`and invalidity. And if we look through it, we
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`pulled out all the pages.
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` If you look at the first page where the
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`text begins, it's page 349, and begins "Open session
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`continued." So this was in open court, not the
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`confidential session. And all the subsequent pages
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`also were during the public session.
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` Okay. Bao, you have a copy; right?
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` MR. NGUYEN: Yeah. So I'll just make an
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`objection for the record in case this has
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`information that is --
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` MS. HOLLOWAY: If anything is --
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` MR. NGUYEN: -- subject --
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` MS. HOLLOWAY: -- confidential, we will
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`either remove it or redact it. We certainly did not
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`intend to put any confidential information into the
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`BY MS. HOLLOWAY:
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` Q. Okay, Mr. McAlexander. You testified at
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`the ITC hearing?
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` A. Yes, I did.
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`Ex. 1013-0018
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`
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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` Q. Okay. Let me ask this question slightly
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`differently.
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`18
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`09:22:45
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` During a read operation, the MUX 130 will
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`only select either T1 or T2 but not both; is that
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`correct?
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` A. That's correct.
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` Q. Okay. I don't think we need this at the
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`moment.
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` The MUX 130 has one output that goes to the
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`comparator 120; correct?
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` A. That is correct.
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`09:23:31
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`09:23:32
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` Q. And the MUX 130 receives a selection signal
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`09:23:33
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`that is not shown; correct?
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` A. I believe the patent describes that as
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`such, yes.
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` Q. Do you need to confirm that?
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` A. No. I know it does.
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`09:23:37
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` Q. Okay. I wasn't sure if the "I believe" was
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`a qualifier.
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` So the MUX -- the multiplexer 130 receives
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`a selection signal that is not shown; correct?
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` A. Correct. It says it may receive, I
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`believe.
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` Q. Okay. Please turn to Exhibit 1001, the
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`hearing transcript.
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`09:23:54
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`Ex. 1013-0019
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`
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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` MR. NGUYEN: Exhibit 1001 or Exhibit 1009?
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`09:24:19
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`19
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` MS. HOLLOWAY: Exhibit 1009, the hearing
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`transcript.
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` THE WITNESS: Okay.
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`BY MS. HOLLOWAY:
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` Q. Okay? Page 365, lines 14 through 16.
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` A. 365?
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` Q. Okay. "Question" --
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` A. Okay.
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` Q. -- "And the multiplexer 130 receives a
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`selection signal that is not shown; right?
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` "Answer: That is correct."
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` Did you give that testimony, sir?
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` A. Yes, I did.
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` Q. Thank you.
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`09:24:21
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` Okay. Specifically the patent describes a
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`mode signal which is not shown in the figures;
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`correct?
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` A. It does that, yes.
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` Q. Okay. During a read operation, the
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`multiplexer or selector 130 will select one of the
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`two input signals, the signal at terminal T1 or the
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`signal at terminal T2, and provide the selected
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`signal as its output; correct?
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` MR. NGUYEN: Objection. Vague.
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`09:25:09
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`Ex. 1013-0020
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`
`
`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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` THE WITNESS: In the read mode, yes, that
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`would be correct.
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`BY MS. HOLLOWAY:
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` Q. Yes.
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` The comparator 120 compares the second data
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`strobe signal with the signal provided by the
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`selector 130; correct?
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` A. Yes, that's correct.
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` Q. Okay. And the third data strobe signal is
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`provided based on the result of that comparison;
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`correct?
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` A. That's correct.
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` Q. Okay. In other words, the third data
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`strobe signal, DQS_3, is the output of the
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`comparison between the two inputs of comparator 120?
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` MR. NGUYEN: Objection. Vague.
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` MS. HOLLOWAY: I didn't ask that quite
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`right.
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`BY MS. HOLLOWAY:
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` Q. In other words, the third data strobe
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`signal, DQS_3, is the result of the comparison
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`between the two inputs of comparator 120?
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` A. That statement is correct.
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` Q. Okay. All right.
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` Let's turn to figure 4 of the '734 patent.
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`Ex. 1013-0021
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`21
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` Figure 4 of the '734 patent includes a
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`multiplexer or MUX that's numbered 130; correct?
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` A. Yes, that is correct.
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` Q. The multiplexer 130 shown in figure 4 has
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`one output that goes to the comparator 120; right?
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` A. Yes.
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` Q. During a read operation, the multiplexer
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`130 will select one of the two input signals, the
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`signal at terminal T1 or the signal at terminal T2,
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`and provide the selected signal as its output;
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`correct?
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` A. Correct.
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` Q. Okay. So in figure 4 of the '734 patent,
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`if the data strobe buffer is in the first mode, then
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`the selected input is Vref; correct?
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` A. For T1, yes, that's correct.
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` Q. Okay. And in figure 4 of the '734 patent,
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`if the data strobe buffer is in the second mode,
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`then the selected input is not Vref; correct?
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` A. That is correct.
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` Q. In figure 4 of the '734 patent, if the data
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`strobe buffer is in the second mode, then the
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`selected input is ground; correct?
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` A. Correct.
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` Q. Okay. And that little triangle we see in
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Ex. 1013-0022
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`
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
`
`22
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`figure 4, that's a common signal for ground; right?
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`09:27:21
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` A. Correct.
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`09:27:24
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` Q. Okay. For figure 4 of the '734 patent, in
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`09:27:25
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`the first mode the mode signal is described as
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`09:27:27
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`indicating that the memory device is a DDR SDRAM,
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`and in the second mode the mode signal is described
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`09:27:34
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`as indicating that the memory device is an MDDR
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`SDRAM --
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` MR. NGUYEN: Objection.
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`BY MS. HOLLOWAY:
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` Q. -- correct?
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` MR. NGUYEN: Misstate the record.
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` THE WITNESS: That is the -- that is the
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`embodiment description, yes.
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`BY MS. HOLLOWAY:
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` Q. And the patent describes only two modes for
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`09:27:49
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`the data strobe buffer in figure 4, the first mode
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`09:28:30
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`and the second mode; correct?
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`09:28:33
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` A. That is the embodiment. There's two modes
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`09:28:35
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`that are shown.
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`09:28:38
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` Q. And the patent describes only two modes for
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`09:28:38
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`the data strobe buffer in figure 4, the first mode
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`09:28:41
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`and the second mode; correct?
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` MR. NGUYEN: Objection. Vague.
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` THE WITNESS: Embodiment --
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`09:28:44
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`09:28:46
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Ex. 1013-0023
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`
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`23
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` MR. NGUYEN: Foundation.
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`09:28:47
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` THE WITNESS: Embodiment has to describe
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`something, so yes, they are describing, by way of
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`example, two modes.
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` MS. HOLLOWAY: Okay. Let's mark the next
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`09:29:07
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`exhibit 1010.
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` (McALEXANDER EXHIBIT 1010 MARKED.)
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`BY MS. HOLLOWAY:
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`09:29:09
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` Q. Okay. Exhibit 1010 is excerpts from the
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`09:29:16
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`transcript of the deposition of Joseph McAlexander
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`09:29:44
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`on July 1st, 2015 in the case of Certain Graphics
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`09:29:47
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`Processing Chips, 337-TA-491. This particular
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`exhibit is excerpts from the deposition that the
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`parties have agreed are non-confidential, and some
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`of it therefore has been -- some of the testimony
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`therefore has been redacted.
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` MR. NGUYEN: Okay. I'll object to the use
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`of this exhibit as to relevance. A lot of the
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`issues in the ITC are not at issue here.
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`09:30:13
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` MS. HOLLOWAY: I think we'll be sticking
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`09:30:21
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`with relevant portions, Counsel.
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`BY MS. HOLLOWAY:
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`09:30:24
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` Q. Okay, Mr. McAlexander. Do you recognize
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`09:30:26
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`this transcript as your deposition transcript from
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`09:30:28
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`the ITC case?
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`09:30:32
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Ex. 1013-0024
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`Videotaped Deposition of Joseph C. McAlexander, III
`Conducted on March 22, 2016
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`24
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` A. It appears to be. I do note that there's a
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`09:30:33
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`number of places in here that have been redacted.
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` Q. Yes, that's correct. Thank you.
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`09:30:46
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` Okay. Mr. McAlexander, please turn to page
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`456, lines 14 through 18.
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` MR. NGUYEN: What's the line? Okay.
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` MS. HOLLOWAY: 456, lines 14 through 18.
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`BY MS. HOLLOWAY:
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`09:30:54
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` Q. "Question: Okay. And the patent describes
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`only two modes, the first mode and the second mode,
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`for the data strobe buffer figure 4; correct?
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`09:31:13
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` "Answer: I believe it only describes the
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`two modes for figure -- with regard to figure 4."
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` Did you give that testimony?
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` A. Yeah, that's correct. That is correct.
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` Q. Thank you, sir.
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`09:31:19
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` All right. Now, I'd like to focus on two
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`09:31:27
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`passages in the '734 patent, at 5-13 through -16.
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`09:31:30
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`I'll let you get to that.
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` A. Column 5?
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` Q. Yes, column 5, lines 13 through 16, and
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`column 5, lines 28 through 30.
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` Give you a minute --
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` A. Okay.
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` Q. -- to read those and then I'll ask the
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`PLAN
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