HAROLD STONE
`
`Page 1
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________________
` )
`HTC AMERICA, INC., HTC CORP., )
`APPLE INC., )
` )
` Petitioners, )
` )
`vs. ) No. IPR2016-00924
` ) Patent No. 5,960,464
`PARTHENON UNIFIED MEMORY )
`ARCHITECTURE LLC, ) No. IPR2016-00923
` ) Patent No. 5,812,789
` Patent Owner. )
` )
`______________________________)
`
` DEPOSITION OF HAROLD STONE, Ph.D.
` Menlo Park, California
` Wednesday, November 16, 2016
`
`Reported by:
`CATHERINE A. RYAN
`CSR No. 8239
`
`212-279-9424
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`Veritext Legal Solutions
`www.veritext.com
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`212-490-3430
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`HTC v. PUMA, IPR 2016-00923
`Page 1
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`
`
`Page 1
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________________
` )
`HTC AMERICA, INC., HTC CORP., )
`APPLE INC., )
` )
` Petitioners, )
` )
`vs. ) No. IPR2016-00924
` ) Patent No. 5,960,464
`PARTHENON UNIFIED MEMORY )
`ARCHITECTURE LLC, ) No. IPR2016-00923
` ) Patent No. 5,812,789
` Patent Owner. )
` )
`______________________________)
`
` DEPOSITION OF HAROLD STONE, Ph.D.
` Menlo Park, California
` Wednesday, November 16, 2016
`
`Reported by:
`CATHERINE A. RYAN
`CSR No. 8239
`
`212-279-9424
`
`Veritext Legal Solutions
`www.veritext.com
`
`212-490-3430
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`HTC v. PUMA, IPR 2016-00923
`Page 1
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`
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`HAROLD STONE
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`Page 2
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________________
` )
`HTC AMERICA, INC., HTC CORP., )
`APPLE INC., )
` )
` Petitioners, )
` )
`vs. ) No. IPR2016-00924
` ) Patent No. 5,960,464
`PARTHENON UNIFIED MEMORY )
`ARCHITECTURE LLC, ) No. IPR2016-00923
` ) Patent No. 5,812,789
` Patent Owner. )
` )
`______________________________)
`
` Deposition of HAROLD STONE, Ph.D.,
`taken on behalf of Patent Owner, at 1600 El Camino Real,
`Suite 280, Menlo Park, California, beginning at 9:15
`a.m. and ending at 2:51 p.m., on Wednesday, November 16,
`2016, before CATHERINE A. RYAN, Certified Shorthand
`Reporter No. 8239.
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 2
`
`
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`HAROLD STONE
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`Page 3
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`APPEARANCES:
`For the Patent Owner Parthenon Unified Memory
`Architecture LLC:
` AHMAD, ZAVITSANOS, ANAIPAKOS, ALAVI, MENSING
` BY: MASOOD ANJOM
` Attorney at Law
` 1221 McKinney, Suite 3460
` Houston, Texas 77010
` (713) 655-1101
` manjom@azalaw.com
`For Petitioner Apple Inc.:
` FEINBERG DAY ALBERTI & THOMPSON LLP
` BY: DAVID ALBERTI
` Attorney at Law
` 1600 El Camino Real, Suite 280
` Menlo Park, California 94025
` (650) 384-9869
` dalberti@feinday.com
` HAYNES AND BOONE, LLP
` BY: MICHAEL S. PARSONS
` Attorney at Law
` 2505 North Plano Road, Suite 4000
` Richardson, Texas 75082-4101
` (972) 739-8611
` michael.parsons@haynesboone.com
`
`For Petitioner HTC America, Inc. and HTC Corp.:
` SIDLEY AUSTIN LLP
` BY: CURT HOLBREICH
` Attorney at Law
` 555 California Street
` San Francisco, California 94104
` (415) 772-7446
` cholbreich@sidley.com
`
`Also Present:
`JESSICA HANNAH, Apple (not present at commencement)
`
`212-279-9424
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`HTC v. PUMA, IPR 2016-00923
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`HAROLD STONE
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`Page 4
`
` INDEX
`WITNESS EXAMINATION
`HAROLD STONE, Ph.D.
`
` BY MR. ANJOM 7
`
` BY MR. ALBERTI 168
`
` BY MR. ANJOM 171
`
` EXHIBITS
`NUMBER DESCRIPTION PAGES
`Exhibit 1 "Parthenon Unified Memory Architecture 8
` LLC's Notice of Deposition of Harold
` Stone, Ph.D." and "Certificate of
` Service"; 3 pages
`
`Exhibit 2 "Parthenon Unified Memory Architecture 9
` LLC's Notice of Deposition of Harold
` Stone, Ph.D." and "Certificate of
` Service"; 3 pages
`
`Exhibit 3 "United States Patent, Diaz et al., 9
` Patent Number: 5,812,789, Date of
` Patent: Sep. 22, 1998"; 13 pages
`
`//
`//
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 4
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`HAROLD STONE
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`Page 5
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` EXHIBITS
`NUMBER DESCRIPTION PAGES
`Exhibit 1001 "United States Patent, Diaz et al., 9
` Patent Number: 5,812,789, Date of
` Patent: Sep. 22, 1998"; 13 pages
`
`Exhibit 4 "United States Patent, Lam, Patent 10
` Number: 5,960,464, Date of Patent:
` Sep. 28, 1999"; 11 pages
`
`Exhibit 1001 "United States Patent, Lam, Patent 10
` Number: 5,960,464, Date of Patent:
` Sep. 28, 1999"; 11 pages
`
`Exhibit 5 "Curriculum Vitae, Harold Stone"; 14 17
` pages
`
`Exhibit 6 "Declaration of Harold S. Stone, 44
` Ph.D., Regarding U.S. Patent No.
` 5,960,464"; 129 pages
`
`Exhibit 7 "Declaration of Harold S. Stone, 44
` Ph.D., Regarding U.S. Patent No.
` 5,812,789"; 104 pages
`//
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 5
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`
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`HAROLD STONE
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`Page 6
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` EXHIBITS
`NUMBER DESCRIPTION PAGES
`Exhibit 8 "United States Patent, Notarianni, 60
` Patent Number: 5,404,511, Date of
` Patent: Apr. 4, 1995"; 14 pages
`
`Exhibit 9 "United States Patent, Lambrecht, 125
` Patent Number: 5,682,484, Date of
` Patent: Oct. 28, 1997"; 42 pages
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`HTC v. PUMA, IPR 2016-00923
`Page 6
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`
`
`HAROLD STONE
`
`Page 7
` Menlo Park, California; Wednesday, November 16, 2016
` 9:15 a.m.
`
` HAROLD STONE, Ph.D.,
`having been administered an oath, was examined and
`testified as follows:
` EXAMINATION
`BY MR. ANJOM:
` Q Good morning, Dr. Stone.
` A Good morning.
` Q My name is Masood Anjom. I represent PUMA.
` Can you please state your full name for the
`record.
` A Harold Stuart Stone.
` Q And can you please state your address?
` A 223 Sixth Avenue, Kirkland, Washington 98033.
` Q And do you understand that you are testifying
`in your capacity as an expert today?
` A I do.
` Q And it's my understanding you've already been
`deposed several times?
` A Yes, I have.
` Q So with that understanding, I'm not going to
`go through all the rules again, which I'm sure you're
`familiar with.
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 7
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`
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`HAROLD STONE
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`Page 8
` Do you understand that you have taken an oath
`to tell the truth?
` A I do.
` Q Is there any reason why you can't tell the
`truth today?
` A There is no reason.
` Q And before I get started, if at any point you
`need a break, let me know, and we can take a break.
` A Okay.
` MR. ANJOM: I'm going to go ahead and hand you
`what's been marked as Exhibit 1, and, for the record,
`Exhibit 1 is paper No. 13 in proceeding IPR21600923.
` (Exhibit 1 was marked for identification by
` the court reporter.)
`BY MR. ANJOM:
` Q Have you seen this document before?
` A I know what it is. I don't recall having seen
`it, though.
` Q Okay. Do you understand that you are being
`presented as an expert in this IPR by the petitioners?
` A I do.
` Q And do you understand that you are being
`presented pursuant to this deposition notice today?
` A Yes, I do.
` MR. ANJOM: Okay. And I'm now going to hand
`
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`HTC v. PUMA, IPR 2016-00923
`Page 8
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`HAROLD STONE
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`Page 9
`you what's been marked as Exhibit No. 2. And, for the
`record, Exhibit No. 2 is paper No. 13 in IPR21600924.
` (Exhibit 2 was marked for identification by
` the court reporter.)
`BY MR. ANJOM:
` Q Have you seen this document before?
` A I don't believe I have.
` Q And like the previous document that you looked
`at, do you understand that you are being presented as an
`expert witness pursuant to this deposition notice today?
` A I do.
` Q Thank you.
` I think it will be easier to just go ahead and
`mark the two patents at issue as well before we get
`started. I'm going to ask the court reporter to hand
`you Exhibit No. 3, which, for the record, is going to be
`Exhibit 1001 from IPR21600923, and it's United States
`Patent No. 5,812,789.
` (Exhibit 3 was marked for identification by
` the court reporter.)
` MR. ANJOM: And I'm also going to ask the
`court reporter to hand you what's been marked as Exhibit
`No. 4, which, for the record, is going to be Exhibit
`1001 from IPR proceeding 21600924. For the record,
`that's United States Patent No. 5,960,464.
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`HTC v. PUMA, IPR 2016-00923
`Page 9
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`HAROLD STONE
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`Page 10
` (Exhibit 4 was marked for identification by
` the court reporter.)
`BY MR. ANJOM:
` Q Are you familiar with these two patents,
`Dr. Stone?
` A Yes, I am.
` Q Would it be fair -- would it be okay if I
`refer to these two patents as the '464 patent for
`Exhibit 4 and the '789 patent as Exhibit 3, going
`forward today?
` A Yes.
` Q With respect to the '464 patent, when did you
`first get involved with the IPR of that patent?
` A There are two IPRs on the '464, and I -- can I
`-- I'm not sure which one you're referring to.
` Q Let's talk about those two.
` So what's the first one that you're referring
`to?
` A Well, on the -- there are two on the '464, and
`the first one I'm referring to I was involved -- one at
`around the time that it was filed. I wrote a
`declaration for it. I don't recall the exact date.
` Q Do you remember -- was that last year?
` A It was probably around the turn of the year.
`Something on that order. My recollection is in 2015,
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 10
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`
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`HAROLD STONE
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`Page 11
`
`but it may be close to the end of the year.
` Q And then there was a second IPR of the '464
`patent?
` A That's correct, and I -- I simply use the same
`declaration on that patent. That was March, April, May
`time frame. I don't recall.
` Q Okay. Were you aware of the '464 patent
`before getting involved with these IPRs?
` A Yes, I was.
` Q In what context?
` A I was retained to examine the '464 in the
`context of a district court hearing.
` Q And when were you retained for that?
` A I don't have the exact date. I'm sorry. I'd
`have to speculate.
` Q Yeah. We don't want you to speculate. That's
`fine.
` What is your standard rate of compensation for
`your consulting work?
` A It's $500 an hour.
` Q And is that the same rate that's being used in
`this case?
` A Yes, it is.
` Q Have you submitted any invoices with respect
`to your work relating to the IPRs?
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 11
`
`
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`HAROLD STONE
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`Page 12
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` A On this IPR, no.
` Q Have you done any work on this IPR?
` A Yes.
` Q And what about the previous IPR? Did you
`submit any invoices on that one?
` A Yes, I did.
` Q How many hours would you say you've spent on
`the previous IPR?
` A I -- it's very difficult for me to say. I
`have to explain that there are seven defendants, and my
`numbers are distributed across seven files, across three
`years -- three calendar years. I simply did not bring
`all of those numbers together. So I don't know.
` Q Let's talk about the declaration that you
`submitted.
` So the declaration that you submitted in this
`proceeding is the same as the declaration you submitted
`in the previous proceeding --
` A That's correct.
` Q -- correct?
` How much time did you spend putting together
`that declaration?
` A I spent zero time.
` Q You spent some time putting it together with
`respect to the first IPR, or not?
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`HTC v. PUMA, IPR 2016-00923
`Page 12
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`HAROLD STONE
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`Page 13
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` A I did on the first IPR, yes.
` Q And how much time would you say you spent
`putting it together for the first IPR?
` A I -- I really don't recall. It's been a
`while. I'm sorry that I can't help you on that.
` Q More than ten hours?
` A I'd speculate perhaps more than ten.
` Q More than a hundred hours?
` A No, not more than a hundred.
` Q More than 50 hours?
` A Not more than 50.
` Q More than 30 hours?
` A We're getting in a range -- in a gray area. I
`don't recall.
` Q Can you just give me a range as best you can
`recall?
` A It's pure speculation. So I could say one to
`three days.
` Q Okay. So between 10 to 30 hours,
`approximately; is that correct?
` A That would be 8 to 24.
` Q Okay. Then let's talk about the declaration
`you submitted with respect to the '789 patent.
` Is it true that you also submitted the same
`declaration in two IPRs for the '789 patent?
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 13
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`HAROLD STONE
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`Page 14
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` A That's correct.
` Q And you didn't spend any time with respect to
`the second IPR because it was the same declaration as
`the first IPR --
` A That's --
` Q -- correct?
` A That is correct.
` Q With respect to the declaration that you
`submitted in the first IPR, would it be fair to say that
`you spent about the same one to three days or was it
`more?
` A Rather than have you put the words in my
`mouth, I will say that I don't recall exactly, and my
`speculation one to three days is reasonable. It could
`be different.
` Q Are you currently consulting on any other
`matters unrelated to this PUMA IPR or PUMA litigation?
` A Yes.
` Q And are any of those matters related to
`technology similar to the PUMA patents, say, shared
`memory?
` A In a broad sense they are involved with memory
`and sharing. They're different from the PUMA patents.
` Q And are you representing the plaintiff or the
`defendant in those -- in those cases?
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 14
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`HAROLD STONE
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`Page 15
` A I am representing the defendant in all the
`cases.
` Q Okay. Did you do anything to prepare for your
`deposition today?
` A Yes, I did.
` Q What did you do?
` MR. ALBERTI: I'd just caution the witness to
`the extent that it requires you to disclose confidential
`communications you had with your attorneys, to leave
`that out of your answer.
` THE WITNESS: [Witness nods head.]
` I spent some time reviewing the documents that
`I felt would be relevant.
`BY MR. ANJOM:
` Q And when was that?
` A I did that on Monday.
` Q Okay. Other than reviewing the documents that
`were relevant on Monday, did you have -- did you do
`anything else to prepare for the deposition today?
` A I did.
` Q What else?
` A I met with counsel.
` Q And is that the counsel representing you
`today?
` A Yes, and there's one additional person.
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 15
`
`
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`HAROLD STONE
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`Page 16
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` Q Okay. When --
` A Two -- two additional people.
` Q So you met with three -- three attorneys?
` A Three. Two more. Five.
` Q Five attorneys. And when was that meeting?
` A I met with one attorney on Monday and five
`attorneys on Tuesday.
` Q And how long was the meeting on Monday?
` A Under three hours.
` Q And how long was the meeting on Tuesday?
` A Under seven hours. Seven hours, I'd say.
` Q Okay. Did you review any documents during any
`of those meetings?
` A I looked at documents. I'm not sure -- you
`and I may have a different meaning of "review." Have in
`front of you, look at is one thing. To read every word
`is another thing. I had documents in front of me, yes.
` Q So did -- so you had documents in front of
`you?
` A Yes.
` Q Did you review any of those documents, as the
`term "review" means to you?
` A I did not read the documents word for word
`that were in front of me.
` Q Were those documents that are referenced in
`
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
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`HAROLD STONE
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`your expert report or your declaration?
` A Yes, they are.
` Q Other than the documents referenced in your
`declaration, did you review any other documents during
`these meetings?
` A No.
` MR. ANJOM: I'm going to ask the court
`reporter to hand you what's been marked as Exhibit No.
`5. For the record, Exhibit No. 5 is Exhibit 1029 from
`the IPRs.
` (Exhibit 5 was marked for identification by
` the court reporter.)
`BY MR. ANJOM:
` Q Are you familiar with this document,
`Dr. Stone?
` A Yes, I am.
` Q And this document is your resumé, correct?
` A It's called "Curriculum Vitae."
` Q Does -- is this document accurate?
` A I believe it is.
` Q So you got your master's degree from Princeton
`in 1960; is that correct?
` A That's correct.
` Q And your master's degree from UC Berkeley in
`1961?
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 17
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`HAROLD STONE
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`Page 18
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` A That's correct.
` Q Did you have to write a master's thesis as
`part of that program?
` A I did not.
` Q And then you obtained your Ph.D. degree in
`1963 from UC Berkeley; is that correct?
` A That's correct.
` Q Did you have to write a dissertation for that?
` A I did.
` Q What was the general topic of your
`dissertation?
` A It was a class of comma-free error-correcting
`codes.
` Q And what did these codes relate to?
` A I'm sorry? Would you repeat that, please?
` Q What -- what did this code relate to?
` A It -- it was a code for communications that
`allowed you to correct errors during transmission, and
`it was comma-free.
` Q Following graduation from Princeton, you
`started working at Boeing; is that correct?
` A No.
` Q Did you obtain employment after graduating
`somewhere else?
` A Well, you stated something incorrect in your
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 18
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`HAROLD STONE
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`Page 19
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`-- in your question. If you want to repeat your
`question, I can answer it.
` Q You can go ahead and correct me.
` A Pardon me?
` Q What did I state incorrectly?
` A You said after my graduation from Princeton.
`It was after my graduation from Berkeley, I obtained a
`position at Boeing.
` Q Okay. And what was your position -- and I'm
`reading from page 12 of your resumé, if you want to
`reference it, where you have "Positions Held." It's on
`the page number 2.
` A Okay. Yeah.
` Q So I'm just going to start from the bottom to
`get a sense for the different positions that you held.
` So you were hired by Boeing as a research
`engineer; is that correct?
` A That's correct.
` Q And you were there for four months?
` A That's correct.
` Q Can you tell me generally what sort of
`projects you were working on while at Boeing?
` A Yeah, I was working on error-correcting codes.
` Q Error-correcting?
` A Error-correcting codes.
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 19
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`HAROLD STONE
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`Page 20
` Q Did this also relate to codes that were used
`for communication?
` A Yes.
` Q And why did you leave Boeing?
` A I decided that I didn't want to work in the
`aerospace industry. It was less pure research. I
`decided I wanted to do more pure research and then left
`for SRI International.
` Q And you worked at SRI as a research engineer
`from November 1963 until December of '68; is that
`correct?
` A That's correct.
` Q And when you started at SRI, I guess your
`position was the same for the whole time: research
`engineer?
` A No, I ended with -- as a senior research
`engineer.
` Q Okay. So when you started as a research
`engineer, what were your -- what were some of the
`projects you were working on?
` A I started by doing -- continuing my work on
`error-correcting codes. I worked on what was called
`cellular logic. That's c-e-l-l-u-l-a-r. And that was a
`forerunner of what is now integrated circuit technology.
`We were laying out circuits on -- on flat surfaces
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 20
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`HAROLD STONE
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`Page 21
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`theoretically, and that's what's happening now.
` I also worked on design automation, and I also
`worked in high-performance computing.
` Q You said design automation?
` A Mm-hmm.
` Q What do you mean by that?
` A It was programs that would allow you to
`specify a computer design with programming-like
`statements, and then that particular program would
`generate the automatic wiring for point-to-point wiring
`machines that would wire up backplanes.
` Q And the last area you mentioned was
`high-performance computers?
` A High-performance computing.
` Q And what did you do in the context of
`high-performance computing?
` A I worked on algorithms that could be used for
`programs that execute in parallel -- on parallel
`processors.
` Q Did you work on designing any decoders while
`you were at SRI?
` A There was a period of time when I was at
`Stanford and SRI both. Although it shows as discrete
`times here, I was going back to SRI, and I was working
`on a decoder during that period of time. So it may have
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 21
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`HAROLD STONE
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`Page 22
`been while I was on SRI property. It may have been
`while I was at Stanford.
` Q And when you say you were working on a
`decoder, what do you mean by that?
` A There were -- there was interest in codes that
`were called burst error-correcting codes, and I was
`working on techniques for decoding code streams that
`were -- that were subject to bursts: runs of -- bunches
`of bits that could be changed randomly, but they're
`close together. And so I was looking at how to -- how
`to decode when you have these bursts.
` Q And did you ultimately come up with a
`solution?
` A I did, in part. Let me point it out. It's on
`page 11 of my curriculum vitae, paper No. 52. The title
`of the paper is "Spectrum of Incorrectly Decoded Burst
`Errors for Cyclic Burst Error Codes."
` Q And you mentioned at some point your position
`changed from a research engineer to something else?
` A It was called senior research engineer. I
`didn't mark it on the vitae. That was probably 1967.
` Q Did the projects you were working on change as
`well or was it just a change in title and
`responsibilities?
` A That was just a change in title.
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 22
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`HAROLD STONE
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`Page 23
` Q Okay. And then after that you joined Stanford
`as a faculty member?
` A That's correct.
` Q Generally, what were the -- were you teaching
`courses or were you a research faculty member?
` A I was both.
` Q And as far as the courses that you were
`teaching, do you remember generally what they related
`to?
` A I did a course on programming at the assembly
`language level, another course on error-correcting
`codes, a course on discrete mathematics, compiler
`writing, operating systems, computer architecture. I
`think that covers the bulk. There may be something I
`missed.
` Q And what was your area of research at the
`time?
` A It was parallel computer architecture.
` Q What do you mean by that?
` A I mean a computer system that has two or more
`processors executing concurrently.
` Q When did you leave Stanford?
` A I left in 1974.
` Q And that's when you joined University of
`Massachusetts?
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`PUMA Exhibit 2004
`HTC v. PUMA, IPR 2016-00923
`Page 23
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`HAROLD STONE
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`Page 24
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` A That's correct.
` Q Did your area of research remain the same or
`did it change when you moved to the University of
`Massachusetts?
` A I continued working in parallel computer
`architecture, but I branched out in addition to what we
`call distributed computing, and I also became involved
`with the development of microcomputer systems.
` Q What do you mean by "distributed computing"?
` A We would consider that the infancy of computer
`networking at the time. What we now know as networking
`and computers and offices and then Wide Area Networks,
`the germ of it was being formulated in 1974 or in the
`early '70s, and I was working in that area.
` Q And what do you mean by the term
`"microcomputer systems"?
` A In the early 1970s the microcomputer industry
`started to take off. It was in its infancy, and people
`started to build things that were microcomputer based
`that formerly had no processing power in them. So a
`whole new genre of devices and things that people were
`interested in was -- were being formulated and built,
`and I was involved in ideas and how to -- what to do
`about building these and what are the possibilities.
` Q And earlier you mentioned parallel computing
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`HTC v. PUMA, IPR 2016-00923
`Page 24
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`HAROLD STONE
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`Page 25
`of computer architectures as architectures that had two
`or more processors running concurrently; is that
`correct?
` A That's correct.
` Q Were these processors sharing memory?
` A Yes and no.
` Q What do you mean by that?
` A The -- one of the examples I worked on was
`called Illiac IV.
` Q Can you spell that, please?
` A I-l-l-i-a-c, and the IV in that one is Roman.
`That was the world's largest and fastest computer system
`at the time.
` Q And what time frame is this?
` A It was 1972, '73, '74.
` Q Okay.
` A It was installed at Moffett Field, NASA. It
`had 64 processors and a control processor. The control
`processor memory was dedicated.
` Q What do you mean by that?
` A The control processor had memory that only it
`could access.
` Q Okay.
` A Each of the processing elements had memory,
`and that memory was shared between the processing
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`HTC v. PUMA, IPR 2016-00923
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`HAROLD STONE
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`Page 26
`elements and the control unit -- the control processor.
` Q And was there a benefit to sharing those
`memories between the 64 processors and the control
`processor?
` A Yes.
` Q What was the benefit?
` A You could run programs.
` Q Could you not run programs if they just used
`dedicated memory?
` A Well, you had to get the programs into the
`dedicated memory, and that was from the control memory.
`The control memory had access to all the peripherals.
`If you didn't have the shared memory, you couldn't --
`you couldn't load the processing element memories. You
`couldn't read the data out.
` Q Were there any other benefits to using this
`shared memory?
` A Well, it allowed the processing elements to
`jointly participate in doing calculations.
` Q Any other benefits?
` A I think I pointed out the major ones, but it
`all boils down to you get higher performance.
` Q Did you work on any other projects such as
`this where shared memory was used between multiple
`processors in a parallel processing architecture --
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`HTC v. PUMA, IPR 2016-00923
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`parallel computer architecture?
` A I'm just reviewing my vitae, and there were
`probably 20 papers -- at least 20 papers in the area of
`parallel computer architecture, and whether they -- some
`may be stimulated by the Illiac IV. Some may be
`stimulated by other computers. I could talk at length
`to answer your question.
` Q Other than the Illiac IV, can you remember any
`other computer systems specifically?
` A That influenced me?
` Q That you worked on?
` A That I worked on. Well, there was Star, the
`Star computer from Texas Instruments. That's paper 39.
`I did some work at IBM later, what we're talking about,
`this time frame.
` Largely these papers were stimulated by
`existing parallel computers or envisioned new -- new
`kinds of parallel computers and developed algorithms
`that were suitable for those parallel computers.
` Q And you left -- let's get back to your -- to
`your employment history.
` You left University of Massachusetts in 1984?
` A That's correct.
` Q And the classes you were teaching at
`University of Massachusetts, were they similar to the
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`HTC v. PUMA, IPR 2016-00923
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`classes you were teaching at Stanford --
` A Yes.
` Q -- as far as the general subject matter goes?
` A Yes, the general subject matter was the same.
` Q And where did you go work after University of
`Massachusetts?
` A I went to IBM Watson Research, and I also took
`a adjunct position at NYU in the Courant Institute.
` Q And your position at NYU, was that a teaching
`pos
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