`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`HTC CORPORATION, HTC AMERICA, INC., and
`LG ELECTRONICS, INC.,
`Petitioners,
`
`v.
`
`PARTHENON UNIFIED MEMORY ARCHITECTURE LLC,
`Patent Owner.
`____________
`
`Case IPR2015-01502
`Patent 7,542,045
`____________
`
`
`
`PATENT OWNER’S OBSERVATIONS ON THE CROSS-XAMINATION
`OF HAROLD S. STONE, PH.D.
`
`
`
`
`
`
`
`Patent Owner’s Observations
`IPR2015-01502
`
`
`
`
`1.
`
`In Ex. 2013 (18:8-19:13), Dr. Stone testified that at the time of
`
`the invention, there were decoders that had dedicated memory and there were
`
`decoders that did not have dedicated memory. However, Dr. Stone could not say
`
`which was the typical configuration at the time of the invention. This testimony is
`
`relevant to and contradicts paragraph 3 of Dr. Stone’s Reply Declaration, Ex. 1032
`
`(“Declaration”), where Dr. Stone opined that “[t]here is no support” for Dr.
`
`Thornton’s opinion that at the time of the invention, a typical decoder required its
`
`own dedicated memory.
`
`2.
`
`In Ex. 2013 (50:9-54:16), Dr. Stone testified that the DSP3210
`
`included a local RAM block that could be dedicated to the DSP3210. This
`
`testimony is relevant to and contradicts the statement in paragraph 35 of the
`
`Declaration, where Dr. Stone opined that the DSP3210 did not include a dedicated
`
`local RAM.
`
`3.
`
`In Ex. 2013 (54:17-23; 55:23-56:18), Dr. Stone testified that he
`
`does not offer an opinion on whether Dr. Thornton’s interpretation is consistent
`
`with the specification of the `368 Patent, the `045 Patent and the `753 Patent. This
`
`testimony is relevant to and contradicts the statement in paragraph 47 of the
`
`Declaration where Dr. Stone states that “Prof. Thornton’s opinion is in conflict
`
`with the specifications of the `368, `753, and `045 patents.”
`
`
`
`1
`
`
`
`Patent Owner’s Observations
`IPR2015-01502
`
`
`4.
`
`In Ex. 2013 (77:12-19), Dr. Stone testified that Table 3 in
`
`Exhibit 2008 (“Kitson”) states that the MIPS requirement for MPEG-2 is 524
`
`MIPS. This testimony is relevant to and contradicts the statement in paragraph 21c
`
`of the Declaration where Dr. Stone states that “[t]he requirement of 524 MIPS in
`
`Ex. 2008 at 8 is specious.”
`
`5.
`
`In Ex. 2013 (79:9-24, 80:16-81:8; 12:20-13:1; 13:15-14:4), Dr.
`
`Stone testified that the MIPS requirement he pointed to in Konstantinides related to
`
`the Px64, not the MPEG-2. He further testified that Px64 is a low resolution, low
`
`repetition rate standard for video conferencing and that a Px64 decoder generally
`
`cannot decode an MPEG-2 or MPEG-1 bit stream. This testimony is relevant to
`
`and contradicts the statement in paragraph 21c of the Declaration where Dr. Stone
`
`relies on Konstantinides to suggest that “[t]he requirement of 524 MIPS in Ex.
`
`
`
`2
`
`2008 at 8 is specious.”
`
`
`
`
`
`
`
`
`
`Patent Owner’s Observations
`IPR2015-01502
`
`Dated: August 15, 2016
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/Masood Anjom
`Masood Anjom, Lead Counsel
`Reg. No. 62,167
`Attorney for Patent Owner
`Parthenon Unified Memory
`Architecture, LLC
`
`AHMAD, ZAVITSANOS, ANAIPAKOS,
`ALAVI &MENSING, P.C.
`1221 McKinney Street, Suite 2500
`Houston, TX 77010
`Telephone: 713-655-1101
`
`
`
`
`
`3
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Patent Owner’s Observations
`IPR2015-01502
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that the foregoing Patent Owner’s Observations on Cross-
`
`Examination of Harold S. Stone, Exhibit 2013, and an updated Exhibit List for this
`proceeding were served on this Monday, August 15, 2016 by electronic mail to the
`following:
`
`Lead Counsel for LG Electronics, Inc.
`
`Rajeev Gupta
`Reg. No. 55,873
`Finnegan, Henderson, Farabow, Garrett
`& Dunner, L.L.P.
`901 New York Avenue, N.W.
`Washington, D.C. 20001-4413
`Tel: (202) 408-4000
`Fax: (202) 408-4400
`Email: raj.gupta@finnegan.com
`
`Lead Counsel for HTC Corporation
`Joseph A. Micallef
`Reg. No. 39,772
`Sidley Austin LLP
`1501 K Street, N.W.
`Washington, DC 20005
`Tel: (202) 736-8492
`Email: jmicallef@sidley.com
`
`Back-up Counsel for LG Electronics,
`Inc.
`Darren M. Jiron
`Reg. No. 45,777
`Finnegan, Henderson, Farabow, Garrett
`& Dunner, L.L.P.
`11955 Freedom Drive
`Reston, VA 20190-5675
`Tel: (571) 203-2700
`Fax: (202) 408-4400
`Email: Darren.jiron@finnegan.com
`
`Back-up Counsel for HTC Corporation
`Stephen M. Everett
`Reg. No. 30,050
`Sidley Austin LLP
`555 California Street, Suite 2000
`San Francisco, CA 94104
`Tel: (415) 772-7482
`Email: Stephen.everett@sidley.com
`
`
`
`4
`
`
`
`
`
`
`
`
`
`
`
`Patent Owner’s Observations
`IPR2015-01502
`
`Dated: August 15, 2016
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By: /s/ Masood Anjom
`
`Masood Anjom, Lead Counsel
`
`Reg. No. 62,167
`Attorney for Patent Owner
`Parthenon Unified Memory
`Architecture, LLC
`
`AHMAD, ZAVITSANOS, ANAIPAKOS,
`ALAVI &MENSING, P.C.
`1221 McKinney Street, Suite 2500
`Houston, TX 77010
`Telephone: 713-655-1101
`
`
`
`
`
`
`
`4811‐4856‐7600, v. 1
`
`
`
`
`
`5
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