throbber
Tingler, Robert Neal
`
`Case IPR2015-01292
`
`July 13, 2016
`
`1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`----------------------------------------x
`WANGS ALLIANCE CORPORATION
`d/b/a WAC LIGHTING CO.,
` Petitioner,
` -against- Case IPR2015-01292
`PHILIPS LIGHTING HOLDING B.V., Patent 6,586,890
` Patent Owner.
`----------------------------------------x
`
` VIDEOTAPED DEPOSITION OF:
` ROBERT NEAL TINGLER
` Wednesday, July 13, 2016
` New York, New York
` 9:06 a.m. - 10:22 a.m.
`
` Reported in stenotype by:
` Rich Germosen, CCR, CRCR, CRR, RMR, CCRR
` NCRA, NJ and CA Certified Realtime Reporter
` NCRA Realtime Systems Administrator
`
`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`
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`Page 1 of 41
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`PHILIPS EXHIBIT 2011
`WAC v. PHILIPS
`IPR2015-01292
`
`

`
`Tingler, Robert Neal
`
`Case IPR2015-01292
`
`July 13, 2016
`
`2
`
` Videotaped Deposition of ROBERT NEAL TINGLER,
`Ph.D., taken in the above-entitled matter before RICH
`GERMOSEN, Certified Court Reporter, (License No.
`30XI00184700), Certified Realtime Court Reporter-NJ,
`(License No. 30XR00016800), California Certified
`Realtime Reporter, NCRA Registered Merit Reporter, NCRA
`Certified Realtime Reporter, NCRA Realtime Systems
`Administrator, taken at the offices of RADULESCU, LLP,
`350 Fifth Avenue, New York, New York 10118, on
`Wednesday, July 13, 2016, commencing at 9:06 a.m.
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`

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`Tingler, Robert Neal
`
`Case IPR2015-01292
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`July 13, 2016
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`3
`
`A P P E A R A N C E S:
`
`RADULESCU, LLP
`BY: MICHAEL SADOWITZ, ESQ.
`The Empire State Building
`350 Fifth Avenue, Suite 6910
`New York, New York 10118
`(646) 502.5858
`michael@radulescullp.com
`Attorneys for the Petitioner
`
`FINNEGAN HENDERSON FARABOW GARRETT & DUNNER, LLP
`BY: KENIE HO, ESQ.
`901 New York Avenue, N.W.
`Washington, D.C. 20001-4413
`(202) 408.4000 / (202) 408.4400 (FAX)
`kenie.ho@finnegan.com
`Attorneys for the Patent Owner
`
`ALSO PRESENT:
`MARCELO RIVERA, Legal Video Specialist
`JOSHUA MATTHEWS, ESQ., Phillips Lighting
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`4
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` I N D E X
`WITNESS EXAMINATION
`ROBERT NEAL TINGLER
` BY MR. HO 7
`
`(No exhibits were marked at this deposition.)
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`5
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`PRODUCTION OF DOCUMENTS AND/OR INFORMATION
` Page Line
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`DIRECTION TO WITNESS NOT TO ANSWER
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`QUESTIONS MARKED FOR LATER RULING
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`--------------------------------------------------
` P R O C E E D I N G S
` 9:06 a.m.
` New York, New York
`--------------------------------------------------
` THE VIDEOGRAPHER: Stand by, please.
` This is DVD number one of the video
`deposition of Mr. Robert Tingler in the matter Wangs
`Alliance Corp. versus Philips Lighting Holding B.V.
`This deposition is being held at Radulescu, located
`at 350 Fifth Avenue, New York, New York, on July 13,
`2016 at approximately 9:06 a.m.
` My name is Marcelo Rivera from the
`firm of Henderson Legal Services. The court
`reporter is Rich Germosen in association with
`Henderson Legal Services.
` Will present counsel please introduce
`themselves for the record.
` MR. SADOWITZ: Michael Sadowitz with
`Radulescu, LLP on behalf of the Petitioner and the
`witness.
` MR. HO: Kenie Ho with Finnegan
`Henderson on behalf of Philips. With me is Josh
`Matthews also with Philips.
` THE VIDEOGRAPHER: Will the court
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`7
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`reporter please swear in the witness.
` (Whereupon, the court reporter
`administered the oath to the witness.)
`
`R O B E R T N E A L T I N G L E R,
`residing at 469 North Waterway Drive, Satellite
`Beach, Florida 32937, having been first duly sworn
`or affirmed, was examined and testified as follows:
`EXAMINATION BY MR. HO:
` Q. Good morning, Mr. Tingler.
` A. Good morning.
` Q. You've been deposed before; is that
`correct?
` A. That's correct.
` Q. So you understand that you're under
`oath at this time to speak truthfully under penalty
`of perjury?
` A. I do.
` Q. Since you're familiar with the
`process, I'm just going to go over some very high
`level things about the depo, okay?
` A. (Indicating.)
` Q. If you need a break at any time, just
`let me know. I normally like to break every hour or
`so, but if you need one earlier for a bio break or
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`just whatever reason, just let me know and we'll
`finish the pending question and then we can just do
`a break at that point.
` A. Okay.
` Q. Now, are you under any medication
`that would prevent you from speaking and testifying
`truthfully today?
` A. No.
` Q. Is there any other reason that would
`prevent you from testifying truthfully today?
` A. No.
` Q. So I'm just going to go through some
`preliminary things just to put together some
`exhibits in front of you. So we've got --
` MR. HO: Here.
` MR. SADOWITZ: Thank you.
` Q. And the last one. Here we go.
` So, Mr. Tingler, I've just given you
`a document previously marked as exhibit 1006 and
`that's your original declaration that went with the
`petition for this case.
` A. (Indicating.)
` Q. Do you recognize the document?
` A. I do.
` Q. Okay. When I refer to the petition
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`declaration in this case, will you understand that
`I'm referring to exhibit 1006?
` A. I will.
` Q. I've also handed you a document
`marked as exhibit 1018. This is another declaration
`you provided in this case. This is the reply
`declaration.
` Do you recognize the document?
` A. I do.
` Q. And if I refer to the reply
`declaration in this case, will you understand that
`I'm referring to exhibit 1018?
` A. I will.
` Q. Also, I've handed you a document
`marked as exhibit 1001. And that's U.S. Patent
`number 6586890.
` Do you recognize the document?
` A. I do.
` Q. And if I refer to this as the '890
`patent, will you understand I'm referring to exhibit
`1001?
` A. I will.
` Q. Okay. Last two documents. I've
`handed you a document marked as exhibit 1003. And
`this is U.S. Patent number 6400101 issued to Biebl.
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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` When I refer to Biebl, will you
`understand that I'm referring to exhibit 1003?
` A. I will.
` Q. The last document is exhibit 1005.
`This is the ST Micro Datasheet for UC2842/3/4/5,
`UC3842/3/4/5, current mode PWN controller.
` Do you recognize the document?
` A. I do.
` Q. And when I refer to the ST Micro
`Datasheet, will you understand that I'm referring to
`exhibit 1005?
` A. I will.
` Q. Okay. Let's turn your attention to
`exhibit 1018, the reply declaration. Specifically
`let's turn to page two, paragraph one.
` Are you there?
` A. I'm there.
` Q. So you state in paragraph one that
`you reviewed the patent owner's, Philips' response
`to Petitioner; is that correct?
` A. That's correct.
` Q. Did you review the entirety of that
`response?
` A. I believe so.
` Q. Okay. Now, you state that you also
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`reviewed Dr. Regan Zane's declaration which is
`exhibit 2006 listed in your paragraph one and all
`the exhibits cited within Dr. Zane's declaration; is
`that correct?
` MR. SADOWITZ: Objection.
`Mischaracterizes.
` A. I believe that's correct. Yes.
` Q. And did you review the entirety of
`Dr. Zane's declaration and all the exhibits?
` A. I believe that I did. I'm not
`100 percent confident on all the exhibits cited
`within though.
` Q. But at least for the declaration
`itself you reviewed the entirety of that
`declaration; is that correct?
` A. That's correct.
` Q. For the exhibits, you believe you
`reviewed all the exhibits that's part of his
`declaration. You're just not 100 percent confident,
`but is that --
` A. Not 100 percent confident that I
`reviewed them in their entirety.
` Q. Okay. Is there a particular one
`where one of the exhibits in Dr. Regan's -- excuse
`me, Dr. Zane's declaration, a specific exhibit that
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`you recall you did not review in its entirety?
` A. No, there is not.
` Q. Now, you also state in paragraph one
`that you reviewed Dr. Zane's June 9, 2016 deposition
`transcript labeled as exhibit 1019 in paragraph one;
`is that correct?
` A. That's correct.
` Q. Did you review the entirety of
`Dr. Zane's June 9, 2016 deposition transcript?
` A. I did.
` Q. I'd like to turn your attention to
`the '890 patent, exhibit 1001. And specific I'd
`like to turn your attention to claim 23 which is at
`the bottom column six, bridging over to the top of
`column seven.
` Are you there?
` A. I'm there.
` Q. So in, let's see, claim 23 at column
`six, line 62 or so there is a claim element recited
`as: A power supply, 52, comma, the power supply 52
`supplying current to the LED array 54 and being
`responsive to a drive signal.
` Do you see that?
` A. I do.
` Q. Okay. Also in claim 23 towards the
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`end of the claim at column seven, line six or so it
`recites: The element, a PWM control IC56,
`responsive to the feedback signal, the PWM control
`IC56 generating the drive signal.
` Do you see that?
` A. I do.
` MR. SADOWITZ: I'm just going to
`object to this question and the last question as
`scope. I'm not really sure where you're going here,
`but I'm just going to object to the questions
`regarding claim 23 as scope.
` MR. HO: Okay.
` MR. SADOWITZ: We'll see where you
`go.
`BY MR. HO:
` Q. So in claim 23 the PWM control IC
`generates its drive signal; correct?
` MR. SADOWITZ: Objection. Scope.
` His declaration is limited to claims
`seven and 31. I'll allow you to answer, but I'm
`cautioning you that I will stop and call the board.
`This is not within the scope of his reply
`declaration.
` MR. HO: And my response is that
`claim 31 depends on claim 23 and includes all
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`limitations of claim 23.
` MR. SADOWITZ: And he did not testify
`specifically to claim 23 in his reply declaration,
`only to the limitations of claim 31.
` MR. HO: We'll just have to disagree
`on that point for now.
`BY MR. HO:
` Q. The PWM control IC generates the
`drive signal; correct?
` A. Per this claim --
` MR. SADOWITZ: Objection. Scope.
` A. -- yes, it generates the drive
`signal.
` Q. And the PWM control IC generates the
`drive signal in response to a feedback signal; is
`that correct?
` MR. SADOWITZ: Objection. Scope.
` A. That's correct.
` Q. In claim 23 at line three of column
`seven it recites: A comparator generates the
`feedback signal; correct?
` MR. SADOWITZ: Objection. Scope.
` A. That is correct.
` Q. And the comparator generates a
`feedback signal by comparing a sensed current signal
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`to a reference signal; correct?
` MR. SADOWITZ: Objection. Scope.
` A. That is what it states, correct.
` Q. Now, this comparator is part of a
`current base feedback loop for controlling supply of
`current --
` MR. SADOWITZ: Objection. Scope.
` MR. HO: I'll repeat it.
` Q. So this comparator in claim 23 is
`part of a current base feedback loop for controlling
`the supply of current to the LED array in claim 23;
`correct?
` MR. SADOWITZ: Objection. Scope.
` A. That is correct.
` Q. So the power supply in claim 23
`regulates the current in the LED array using this
`current base feedback loop; is that correct?
` MR. SADOWITZ: Objection. Scope.
` A. That is correct.
` Q. Claim 23 doesn't recite the word
`voltage at all; is that correct?
` MR. SADOWITZ: Objection. Scope.
` A. That is correct.
` Q. And you understand that claim 31,
`since it depends on claim 23, includes all the
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`limitations of claim 23; is that correct?
` A. That would be my understanding.
` Q. I'd like to turn your attention to
`claim seven of the '890 patent. And that's at
`column five, lines 39 through 53. Are you there?
` A. I'm there.
` Q. So the last element in claim seven,
`which starts at line 51 of column five, recites: A
`means for supplying power responsive to the drive
`signal. Said power supply meaning supplying current
`to the LED array.
` Do you see that?
` A. I do.
` Q. Just above that starting at line 43
`or so -- excuse me. Let me restart that question.
` So just above that the element
`starting at line 47 of column five it recites: A
`means for modulating pulse width responsive to the
`feedback signal. Said pulse width modulating means
`generating a drive signal.
` Do you see that?
` A. I do.
` Q. And then immediately above that it
`states at line 44 of column five: The means for
`comparing the sensed current signal to the reference
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`signal said comparing means generating a feedback
`signal; is that correct?
` A. That is what it says.
` Q. So that's describing a current base
`feedback loop in claim seven; is that correct?
` MR. SADOWITZ: Objection. Form.
` A. It is operating off of sensing the
`current and controlling the current, that's correct.
` Q. So the power supply means in claim
`seven regulates a current to the LED using this
`current base feedback loop; is that correct?
` MR. SADOWITZ: Objection. Form.
` A. Could you state that again, please?
` MR. HO: Could you just restate the
`question?
` COURT REPORTER: (Complies.)
` (Whereupon, the requested portion is
`read back by the reporter as follows:
` "QUESTION: So the power supply means
`in claim seven regulates a current to the LED using
`this current base feedback loop; is that correct?")
` MR. SADOWITZ: Same objection.
` A. That's correct.
`BY MR. HO:
` Q. Turning to figure one of the '890
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`Tingler, Robert Neal
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`July 13, 2016
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`patent, are you there?
` A. I'm there.
` Q. Figure one shows an exemplary
`embodiment in the '890 patent; is that correct?
` MR. SADOWITZ: Objection. Form.
` A. An exemplary embodiment?
` Q. What parts of the question are you
`having trouble with?
` A. Yes, that is correct. It details it.
` Q. Okay. Figure one shows a current
`regulating feedback loop for supplying current to an
`LED array; is that correct?
` A. That is correct.
` Q. All the elements and structures in
`figure one are being used to illustrate a current
`regulating feedback loop supplying current to an LED
`array; is that correct?
` MR. SADOWITZ: Objection. Form.
`Vague.
` A. That is correct.
` Q. Looking at figures 2A, 2B, 2C and 2D,
`feel free to flip through them if you need to, and
`just let me know when you're ready.
` A. I'm ready.
` Q. So I'm going to ask the same
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`questions. So figure 2A to figure 2D illustrates an
`implementation of an LED -- let's start again.
` So figure 2A to figure 2D illustrates
`an exemplary implementation of the invention in the
`'890 patent; is that correct?
` MR. SADOWITZ: Objection. Form.
`Vague.
` A. That is correct.
` Q. And what figures 2A to 2D illustrates
`is an exemplary circuit showing how current is being
`regulated to the LED array using a current base
`feedback loop; is that correct?
` MR. SADOWITZ: Objection. Form.
`Vague.
` A. It shows regulating current to an LED
`using a current base feedback loop, yes.
` Q. All the structures shown in, for
`example -- actually, strike that. Withdraw the
`question.
` For claim seven, can you please turn
`your attention back to that again and let me know
`when you're there.
` A. I'm there.
` Q. Claim seven doesn't recite the word
`voltage; is that correct?
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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` A. States: Power for supplying to the
`LED array and current. It does not state voltage.
` Q. Just to be clear, it does not state
`voltage, is that what you said?
` A. It states: A system for supplying
`power to an LED array and current to the LED array,
`means for supplying current. It does not state
`voltage.
` Q. So I'd like to turn your attention
`back to your reply declaration which is exhibit
`1018, and specifically I'd like to turn your
`attention to paragraph 13 of your reply declaration.
` A. I'm there.
` Q. Excuse me.
` So at paragraph 13 you state: In
`addition to utilizing the ST Micro IC to drive an
`LED load, a POSA, which is short for a person of
`ordinary skill in the art, would be motivated to
`replace the battery of Biebl with a flyback
`regulator of figure 11 of the ST Micro Datasheet; is
`that correct?
` A. That is correct.
` Q. You then further state in paragraph
`13: I discuss one implementation of such a
`combination below; is that correct?
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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` A. That is correct.
` Q. Turning to paragraph 15 of your reply
`declaration, you then illustrate this
`implementation, is that correct, and paragraph 15
`bridges from the bottom of page nine to page 10?
` A. Yes.
` Q. Specifically on page 10 in paragraph
`15, you illustrate the implementation by providing
`an excerpt of figure 11 from the ST Micro Datasheet
`along with an excerpt of figure five from the Biebl
`document; is that correct?
` A. That is correct.
` Q. With respect to this implementation
`you state at the top of paragraph 15: In such an
`implementation, a POSA would utilize the constant V
`out voltage of an implementation of the figure 11
`flyback regulator of the ST Micro Datasheet, comma,
`where V out replaces the output voltage U batt of
`Biebl, comma, as shown below; is that correct?
` A. That is correct.
` Q. Figure 11 of the ST Micro Datasheet
`in paragraph 15 uses a current mode PWM control
`scheme; is that correct?
` A. That is correct.
` Q. And figure five in paragraph 15's
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`implementation uses a direct duty cycle PWM control
`scheme; is that correct?
` A. Can you say that again, please?
` MR. HO: Can you just repeat the
`question?
` COURT REPORTER: (Complies.)
` (Whereupon, the requested portion is
`read back by the reporter as follows:
` "QUESTION: And figure five in
`paragraph 15's implementation uses a direct duty
`cycle PWM control scheme; is that correct?")
` A. So you're referring to the circuit in
`Biebl?
` Q. The circuit in Biebl in the
`implementation that you describe in paragraph 15.
` A. Yes, the Biebl circuit uses direct
`duty cycle.
` Q. And then in paragraph 16, the last
`sentence of that paragraph you state: Further in
`this implementation as opposed to Dr. Zane's
`opinions, differences in the PWM control schemes
`between Biebl and the ST Micro IC are
`inconsequential, comma, as each of the Biebl circuit
`and the ST Micro flyback regulator operates using
`its own PWM control scheme without affecting the
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`other; is that correct?
` A. That is correct.
` Q. Do you agree with that statement?
` A. Yes, I agree with that statement.
` Q. Where is the PWM drive signal in the
`flyback regulator of the ST Micro Datasheet circuit
`in paragraph 15?
` MR. SADOWITZ: Objection. Vague.
` A. Where is the drive signal from the
`ST Micro Datasheet in paragraph 15?
` Q. No. Where is the -- let me just try
`a different way.
` A. Okay.
` Q. I'll be more specific.
` Is the PWM drive signal in a flyback
`regulator of the ST Micro Datasheet circuit shown in
`paragraph 15? Is the PWM drive signal at the gate
`of the transistor Q1?
` MR. SADOWITZ: Objection. Form.
` A. For the flyback, yes.
` Q. Yes, it is?
` A. Yes, it is. That would be the drive
`signal.
` Q. In this implementation you show in
`paragraph 15 with both the ST Micro Datasheet
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`circuit along with the Biebl circuit, you are not
`proposing outputting the PWM drive signal at the
`gate of transistor Q1 to the Biebl circuit; is that
`correct?
` MR. SADOWITZ: Objection. Form.
`Vague.
` A. That is correct.
` Q. So the Biebl circuit in this
`implementation is not receiving a PWM drive signal
`from the ST Micro circuit; is that correct?
` MR. SADOWITZ: Objection. Form.
`Vague.
` When you refer to PWM drive signal,
`are you talking about a claim limitation?
` MR. HO: I'm just referring to the
`circuit.
` A. So in the implementation shown, when
`Biebl provides a load, the pulse load to the
`ST Micro flyback, that pulse load, the UC38 or shown
`as 3844 in the diagram, but the UC -- the ST Micro
`chipset will be responsive to that pulse load and
`its drive signal will modulate the FET Q1, but it
`will not modulate or drive it to Biebl. It's in
`response to Biebl.
` Q. Thank you. I don't think that's
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`Tingler, Robert Neal
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`Case IPR2015-01292
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`July 13, 2016
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`quite my question. So I'm just going to try again.
` A. Okay.
` Q. So the PWM drive signal at the gate
`of transistor Q1 in the ST Micro Datasheet circuit
`is not being outputted to the Biebl circuit in this
`implementation paragraph 15; is that correct?
` A. The PWM drive signal is controlling
`FET Q1.
` Q. That PWM drive signal controlling FET
`Q1 is not being outputted as a signal to the Biebl
`circuit; is that correct?
` A. Its only direct connection is to Q1.
` Q. In the Biebl circuit of this
`implementation is the PWM drive signal for the
`direct duty cycle PWM control scheme at the gate of
`transistor T?
` A. It is.
` Q. The PWM drive signal at the gate of
`transistor T in the Biebl circuit is not being
`outputted to the ST Micro flyback regulator circuit;
`is that correct?
` A. That's correct.
` Q. Mr. Tingler, do you have an
`understanding of a flyback converter topology?
` A. I do.
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`Case IPR2015-01292
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` Q. In a flyback converter how many PWM
`drive signals would it normally have?
` MR. SADOWITZ: Objection. Vague.
` A. In a --
` MR. SADOWITZ: Just let me get my
`objection.
` MR. HO: Wait for his objections
`first.
` MR. SADOWITZ: There was a relevance
`objection as well. Thanks.
`BY MR. HO:
` Q. Do you need me to repeat the
`question?
` A. No. There is synchronous
`applications where the output rectifier diode can be
`replaced with a MOSFET for better efficiency
`performances and that would have two PWM drive
`signals, but in a standard nonsynchronous
`implementation, as shown in the ST Micro Datasheet,
`there is one PWM drive signal.
` Q. In the circuit implementation that
`you illustrate at paragraph 15 on the lower
`right-hand side you show the Biebl circuit; correct?
` A. That is correct.
` Q. At the upper right corner of the
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`Case IPR2015-01292
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`Biebl circuit you have labeled a node as V out; is
`that correct?
` A. That's correct.
` Q. Next to that node labeled as V out
`there is a capacitor going from the node V out to
`ground; is that correct?
` A. That is correct.
` Q. What's the purpose of that capacitor?
` MR. SADOWITZ: Objection. Relevance.
` A. To store energy.
` Q. What's the purpose of having that
`capacitor there to store energy?
` MR. SADOWITZ: Objection. Relevance.
` Go ahead.
` A. To help source current.
` Q. Is that a decoupling capacitor?
` MR. SADOWITZ: Same objection.
` A. I'm not sure in the Biebl
`implementation if they reference if it's the
`coupling capacitor or not. I'd like to look through
`that.
` Q. Sure.
` A. I don't know that I see it referenced
`in Biebl. It's maybe a decoupling capacitor since
`the Biebl invention is an IC and that is the VCC
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`Case IPR2015-01292
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`July 13, 2016
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`connection for the IC, but I'm not 100 percent
`positive.
` Q. Assuming it's a decoupling capacitor,
`what's the purpose of a decoupling capacitor?
` MR. SADOWITZ: Objection. Relevance.
` A. To filter noise onto the IC pins and
`to provide mostly noise filtering.
` Q. And that's to prevent interference
`between one part of a circuit's operation from
`another part of the circuit's operation?
` A. That's correct.
` Q. Assuming that that's a decoupling
`capacitor, is the effect in this implementation in
`paragraph 15 of that decoupling capacitor to prevent
`interference between the circuit in ST Micro and the
`Biebl circuit?
` MR. SADOWITZ: Objection. Vague.
`Relevance.
` A. Well, it would be common practice to
`maintain a decoupling capacitor on an IC to localize
`it and prevent noise interference.
` Q. I suppose going by the name of the
`capacitor, a decoupling capacitor, the purpose of
`such a capacitor is to decouple one part of a
`circuit from another; is that correct?
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`Case IPR2015-01292
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` MR. SADOWITZ: Objection. Relevance.
` A. That's correct.
` Q. I'd like to turn your attention to
`exhibit 1006, which is your original petition
`declaration. You never -- in -- let me start again.
` In your original petition
`declaration, exhibit 1006, you never mentioned
`replacing the battery U batt in Biebl with a flyback
`regulator of the ST Micro Datasheet; is that
`correct?
` MR. SADOWITZ: Objection. Scope.
` A. I don't believe I specifically called
`out that implementation.
` Q. In your reply declaration, exhibi

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