UNITED STATES PATENT AND TRADEMARK OFFICE
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`- - -
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`BEFORE THE TRIAL AND APPEAL BOARD
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`Page 1
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`- - -
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`APPLE INC,
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`Petitioner,
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`v.
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`LIMESTONE MEMORY SYSTEMS LLC,
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`Patent Owner.
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`- - -
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`Case IPR2016-01561
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`U.S. Patent No. 6,233,181
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`- - -
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`Video tape deposition of PINAKI
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`MAZUMDER, PH.D, taken on April 27, 2017, at
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`1350 I Street Northwest, Suite 1100,
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`Washington, DC 20005, beginning at 9:03 a.m.,
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`before Valerie D. Owens, a Court Reporter.
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`- - -
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`VERITEXT LEGAL SOLUTIONS
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`MID-ATLANTIC REGION
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`1801 Market Street - Suite 1800
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`Philadelphia, Pennsylvania 19103
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`Veritext Legal Solutions
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`Limestone Memory Systems, LLC – Exhibit 2007, p. 1
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`

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`1 A P P E A R A N C E S :
`2 ANDREWS KURTH KENYON LLP
`BY: JOHN R. HUTCHINS, ESQUIRE;
`3 ROMAN KHASIDOV, ESQUIRE
`1350 I Street Northwest
`4 Suite 1100
`Washington, DC 20005
`5 (202) 662-3038
`Jhutchins@andrewskurthkenyon.com
`6 Appearing on behalf of Apple Inc.
`7 FITCH EVEN TABIN & FLANNERY LLP
`BY: DAVID A. GOSSE, ESQUIRE
`8 120 South LaSalle Street
`Suite 1600
`9 Chicago, Illinois 60603
`(312) 577-7000
`10 dgosse@fitcheven.com
`Appearing on behalf of Limestone Memory
`11 Systems LLC.
`12
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`Also present: Jonathan Perry, Videographer
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`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
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`1 - - -
`2 I N D E X
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`3
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`4
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`Testimony of: PINAKI MAZUMDER, PH.D
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`Direct Examination by Mr. Gosse 5
`5 Cross-Examination by Mr. Hutchins 233
`Redirect Examination by Mr. Gosse 246
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`6
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` - - -
`7 E X H I B I T S
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`8
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`EXHIBIT DESCRIPTION PAGE
`9 Exhibit 1 Declaration of
` Dr. Pinaki Mazumder 16
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`10
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`11
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`12
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`13
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`14
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`15
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`Exhibit 2 CV of Dr. Pinaki Mazumder 16
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`Exhibit 3 Hidaka Patent 87
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`Exhibit 4 Sukegawa Patent 160
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`Exhibit 5 Fujishima Patent 160
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`Exhibit 6 Watanabe Patent 201
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`Exhibit 7 IEEE Journal of Solid-State
`16 Circuits, A Flexible Redundancy
` Technique for High-Density
`17 DRAM's 213
`18 Exhibit 8 Fault-Tolerance and Reliability
` Techniques for High-Density
`19 Random-Access Memories 213
`20 Exhibit 9 Walck Patent 225
`21
`22
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`Page 2
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`Page 3
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`Page 4
`1 THE VIDEOGRAPHER: We are now on
`2 the record. Recording will continue until all
`3 parties agree to go off the record. My name
`4 is Jonathan Perry. I represent Veritext
`5 Reporting. Today's date is April 27th, 2017.
`6 The time is approximately 9:03 a.m. We're at
`7 the offices of Andrews Kurth Kenyon, located
`8 at 1350 I Street Northwest in Washington, DC.
`9 The deposition it being taken by counsel for
`10 the Defense in the matter of Apple
`11 Incorporated versus Limestone Memory Systems
`12 LLC, case filed with the US Patent and
`13 Trademark Office before the Patent Trial and
`14 Appeal Board. Case number IPR 2016-1561. The
`15 name of the witness is Pinaki Mazumder.
`16 And would counsel present please
`17 introduce themselves and state whom they
`18 represent.
`19 MR. GOSSE: David Gosse on
`20 behalf of the patent owner, Limestone Memory
`21 Systems LLC.
`22 MR. HUTCHINS: John Hutchins
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`Page 5
`1 from Andrews Kurth Kenyon presenting Apple and
`2 with me is Roman Khasidov.
`3 THE VIDEOGRAPHER: The court
`4 reporter is Valerie Owens, also with Veritext.
`5 Would you please swear in the witness.
`6 THEREUPON:
`7 PINAKI MAZUMDER, PH.D,
`8 was called as a witness and, having been first
`9 duly sworn and responding "I do," was examined
`10 and testified as follows:
`11 DIRECT EXAMINATION
`12 BY MR. GOSSE:
`13 Q. Good morning, Dr. Mazumder.
`14 A. Okay. Good morning.
`15 Q. You understand that you're here
`16 for your deposition today?
`17 A. Yes.
`18 Q. Okay. Have you ever been
`19 deposed before, sir?
`20 A. Yes.
`21 Q. Okay. Then you probably are
`22 familiar with the process. I'm going to cover
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`Page 6
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`1 a few ground rules, just in case. You're
`2 entitled obviously to a fair question. I'll
`3 be asking you questions all day.
`4 A. Yes.
`5 Q. If you don't understand the
`6 question, let me know and we'll try to
`7 rephrase it or work out the misunderstanding
`8 so that we can come to an answer that is as
`9 accurate as possible. Do you understand?
`10 A. Sure.
`11 Q. Okay. And in the course of
`12 answering questions that I ask, if you could
`13 please respond with something verbal, like a
`14 yes or a no. Avoid head nods or head shakes
`15 and avoid any sort of uh-huhs or ah-huhs,
`16 because the court reporter won't be able to
`17 accurately transcribe those and indicate
`18 whether you meant yes or no. Do you
`19 understand?
`20 A. I understand.
`21 Q. Okay. And we'll try avoid
`22 talking over each other. I'll ask you a
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`Page 8
`1 an expert witness on behalf of Apple. Is that
`2 correct?
`3 A. Yes.
`4 Q. Okay. Have you worked with
`5 Apple any other times?
`6 A. No.
`7 Q. And did you meet with attorneys
`8 to prepare for today's deposition?
`9 A. I met attorneys yesterday.
`10 Q. Okay. How long did you speak
`11 with them?
`12 A. I came here after 10:30 --
`13 around 10:30 or so and we are there probably
`14 around six o'clock.
`15 Q. Who all did you meet with in
`16 preparation for today's deposition?
`17 A. John and Roman.
`18 Q. Okay. Did you do anything else
`19 to prepare for today's deposition?
`20 A. I reviewed the materials for few
`21 days before coming over here.
`22 Q. Which materials did you review?
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`Page 7
`1 question and you can answer it, that way we
`2 can get an accurate transcript from the -- the
`3 court reporter.
`4 A. Okay.
`5 Q. Does that work for you?
`6 A. Sure.
`7 Q. Okay. Great. Could you spell
`8 your name for the court reporter, please.
`9 A. Pinaki Mazumder is my name, that
`10 way it is pronounced; and spelling is
`11 P-i-n-a-k-i and then last name is
`12 M-a-z-u-m-d-e-r.
`13 Q. Dr. Mazumder, are you employed?
`14 A. Yes.
`15 Q. Where do you work, sir?
`16 A. I work at the University of
`17 Michigan.
`18 Q. How long have you been working
`19 there?
`20 A. I joined there in 1987,
`21 September.
`22 Q. Okay. And you're here today as
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`Page 9
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`1 A. The apple petition.
`2 Q. Okay.
`3 A. Then Limestone's reply, as the
`4 well as the other materials, like the prior
`5 arts, then both -- the prior arts that we
`6 asserted in the petition, as well as the other
`7 materials like -- which we consider in the
`8 list of materials. We consider --
`9 THE REPORTER: Consider what
`10 materials?
`11 THE WITNESS: The list of
`12 materials that we used in preparing the
`13 declaration --
`14 BY MR. GOSSE:
`15 Q. Okay.
`16 A. -- and --
`17 Q. Did you review any material that
`18 is not cited as an exhibit in this matter?
`19 MR. HUTCHINS: Well, if you
`20 know -- if you know what's been cited as an
`21 exhibit.
`22 THE WITNESS: Yes. If you show
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`Page 10
`1 me the exhibits, I will know, but definitely
`2 the things that has been referenced in the
`3 declaration in the footnote or in the list of
`4 materials considered. I did look into them.
`5 Especially there was -- in footnote of my
`6 declaration Horiguchi's paper in 1997. So I
`7 did review that, as well as the -- some of the
`8 references which he used to describe some
`9 inter subarray replacement to see that --
`10 there's one reference 256 megabit DRAM in
`11 1996. So I did look into that.
`12 And, similarly, for Sukegawa, I
`13 think he has a series of patents on this
`14 particular concept. So I also looked into
`15 other patents a little bit, but mostly I
`16 concentrated on 0430 patent, which we have
`17 used in the prior art.
`18 BY MR. GOSSE:
`19 Q. Okay. So in terms of material
`20 that's not cited in your declaration, am I
`21 correct that you reviewed several documents,
`22 several papers that are cited in Sukegawa's
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`Page 12
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`1 if I may. The -- you reviewed several papers
`2 that are cited in the Horiguchi article,
`3 correct?
`4 A. Not several. There are two of
`5 them which are related to inter subarray
`6 replacement.
`7 Q. Okay. One of those you
`8 mentioned was a 256 megabit DRAM paper.
`9 A. That's right.
`10 Q. What was the other one?
`11 A. I cannot recall, but that's also
`12 like inter subarray replacement technique.
`13 This 256 megabit DRAM 1996 paper seemed more
`14 closer to this 181 patent.
`15 Q. Do you know the author of that
`16 paper offhand?
`17 A. Actually, it is a -- you know,
`18 at that time IBM, then Toshiba and Simmons,
`19 they are working on 256 megabit DRAM manuals.
`20 So it was a Japanese author, I think, Kitahara
`21 (phonetic) probably. I'm not hundred percent
`22 sure. If you have a copy of the Horiguchi
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`Page 11
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`Page 13
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`1 1997 article?
`2 A. I wouldn't say several. As a
`3 matter of fact, Sukegawa had filed three
`4 patents at the same time almost. I think 040
`5 is one of them and it's complementary one is
`6 called 850, some number of this, ends with
`7 850. And then he had also a month before, I
`8 suppose he filed 394 patent. So I just very
`9 cursory looked into to see that, you know, I
`10 mean how they complement with this concept
`11 related to any mapping.
`12 Q. Okay.
`13 MR. HUTCHINS: I'm sorry. Did
`14 you -- were you asking about Horiguchi or
`15 Sukegawa?
`16 MR. GOSSE: I -- I misspoke,
`17 Counsel. I apologize.
`18 MR. HUTCHINS: That's okay.
`19 There may have been a little bit of confusion
`20 about what he was asked --
`21 BY MR. GOSSE:
`22 Q. Yeah. So let me just rephrase,
`
`1 1997 paper, I can point that out.
`2 Q. Sure. We'll -- we'll jump into
`3 that later, if that's okay.
`4 A. Okay.
`5 Q. In preparing for the deposition,
`6 did you speak with anybody other than the
`7 attorneys that are here with us today?
`8 A. Yesterday I met them for the
`9 first time and we discussed over different
`10 things. My --
`11 MR. HUTCHINS: He's just asking
`12 if you spoke with --
`13 THE WITNESS: Right. Right.
`14 MR. HUTCHINS: -- anyone other
`15 than the attorneys.
`16 THE WITNESS: Right. I'm just
`17 trying to recollect. I think probably --
`18 today is Thursday. Tuesday, I suppose another
`19 attorneys just explained to me what a
`20 deposition will be like. I mean, the
`21 logistics and things like that.
`22 BY MR. GOSSE:
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`Page 14
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`Page 16
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`1 Q. That was another attorney from
`2 Andrews Kurth?
`3 A. Yeah. Rose, yes.
`4 Q. Okay. Sure.
`5 A. And Roman was also on the phone.
`6 Q. Okay. In the course of your
`7 work on this case, have you spoken to lawyers
`8 for any of the other defendants, any of the
`9 other defendants in the district court
`10 litigation?
`11 A. Can you explain. What do you
`12 mean by other defendants?
`13 Q. Have you spoken with lawyers
`14 from Micron Technology?
`15 A. No, I don't know them.
`16 Q. Okay. Have you spoken with any
`17 lawyers from Acer --
`18 A. No.
`19 Q. -- Dell --
`20 A. No.
`21 Q. -- HP --
`22 A. No.
`
`1 the two references I have provided in the
`2 declaration, I think the footnote eight and
`3 nine, both are authored by Horiguchi. One is
`4 1997 paper, the other one is part of a chapter
`5 of a book that he wrote with the Kiyoo Itoh,
`6 so I did look into that.
`7 Q. Okay. And did you speak with
`8 anybody else -- outside of attorneys in
`9 preparing --
`10 A. No.
`11 Q. -- your declaration?
`12 A. No.
`13 Q. Okay. The court reporter has
`14 marked Exhibits 1 and 2. She'll put those in
`15 front of you.
`16 MR. HUTCHINS: Thank you.
`17 (Limestone Exhibit 1 and Exhibit
`18 2 were marked for Identification.)
`19 BY MR. GOSSE:
`20 Q. Exhibit 1 is your declaration in
`21 this matter. Do you recognize that document?
`22 A. Yes. It appears to be the same
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`Page 17
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`1 Q. -- Kingston --
`2 A. No.
`3 Q. -- Lenovo --
`4 A. No.
`5 Q. -- or OCZ Storage Solutions?
`6 A. No.
`7 Q. Okay. And in the course of your
`8 work overall on this case, have you reviewed
`9 any documents other than the ones cited in
`10 your declaration?
`11 A. While writing the declaration, I
`12 did read quite a -- things to basic relate to
`13 the 181 patent, Sukegawa and other things, but
`14 of late, no.
`15 Q. Okay. Did any of those other
`16 documents inform your reasoning or your
`17 opinions?
`18 A. Well, I have written a book on
`19 DRAM where fault tolerance is the main theme
`20 and there I discussed about Horiguchi's 1991
`21 paper and all. So I did reference to --
`22 looked into my own book, actually. And then
`
`1 one which I provided with my signature.
`2 Q. Okay. And Exhibit 2 is also in
`3 front of you. That is your curriculum vitae.
`4 Do you recognize that document?
`5 A. Yes.
`6 Q. Okay. And does your -- does
`7 this declaration, Exhibit 1, summarize your
`8 opinions in this case?
`9 A. Yes.
`10 Q. Okay.
`11 A. Based on the facts I had at that
`12 time and the knowledge at that time, yes.
`13 Q. Okay. Other relevant facts or
`14 knowledge that you've since learned that's not
`15 cited in here?
`16 A. No. I just mentioned that what
`17 are additional materials I just looked into.
`18 That's all.
`19 Q. Okay. Dr. Mazumder, when were
`20 you first approached by Andrews Kurth
`21 regarding this matter?
`22 A. When I was first contacted or --
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`Page 18
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`Page 20
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`1 Q. Yes.
`2 A. I mean, I was retained on July
`3 20th, 1996. Now before that, I do remember
`4 they just called me to find out that --
`5 whether I will be available during the time
`6 frame. And then July 20th onwards, I think I
`7 started working on this particular case. And
`8 August 12th was the day we -- I provided my
`9 signed copy of the declaration.
`10 Q. You mentioned July 28th. That
`11 would have been last year, 2016?
`12 A. July 20th -- two, zero.
`13 Q. Oh, 20th --
`14 A. Yeah.
`15 Q. -- two, zero.
`16 A. Yes.
`17 Q. And that was 2016, last year?
`18 A. Yeah. 2016, yeah. Okay.
`19 Q. You said 1996.
`20 A. I'm sorry about that.
`21 Q. Certainly that brings us to the
`22 time period of the patents at issue.
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`1 A. Once I received the materials
`2 from them through e-mail, I don't remember
`3 whether in that night or -- next day onwards,
`4 I started looking into.
`5 Q. Okay. And I understand that
`6 you're billing Andrews Kurth $350 per hour for
`7 your work on this case. Is that correct?
`8 A. $350, yes.
`9 Q. And do you bill Andrews Kurth
`10 for that work or is it Apple?
`11 A. Well, when I was retained, it
`12 was Kenyon and Kenyon before the merger, so I
`13 billed Kenyon and Kenyon.
`14 Q. Okay. And since the merger?
`15 A. Since the merger, I do believe
`16 that I did a very little small amount of work
`17 when they're preparing the request for
`18 rehearing for the 441 patent.
`19 Q. Sure. In terms of the 181
`20 patent, do you have an estimate for how many
`21 hours you've spent working on this matter?
`22 A. I mean, when I was retained, I
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`Page 21
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`1 A. Sorry.
`2 Q. You mentioned that there was a
`3 call sometime prior to July 20th.
`4 A. Yes. I think I was going out of
`5 country at that time and just a very brief
`6 phone call about this particular lawsuit and
`7 whether I would be available within this time
`8 frame. I said, yes, I will return --
`9 return -- I returned around, I think, 14th
`10 July and then a week -- almost a week later,
`11 six days later I started working on this.
`12 Q. Okay. And did you do any work
`13 prior to being retained?
`14 A. No. They did not provide me
`15 any -- any document or anything related to the
`16 case. I mean, 20 -- 20th July I do remember
`17 that I signed the agreement and after that,
`18 they provided me the document.
`19 Q. Okay. So is it true then that
`20 the first time you looked at the 181 patent
`21 that's at issue was sometime after July 20th,
`22 2016?
`
`1 was retained for both 441, as well as 181.
`2 And between July 20th and August 12th, if
`3 you're asking -- are you asking the number of
`4 hours I worked on this?
`5 Q. Yes.
`6 A. I mean, I really did not break
`7 down between the two, but totally I do believe
`8 that it was in the ballpark of 185 hours or
`9 something like that for the two patents.
`10 Q. And that was over the course of
`11 approximately three weeks?
`12 A. Approximate, that's right.
`13 Q. Okay.
`14 A. I mean, I had to work very hard,
`15 because that short time, yes.
`16 Q. Are you engaged in any other
`17 litigation matters presently?
`18 A. Yes. In -- I can't remember
`19 exactly when it started, but they -- after
`20 this, there was another case -- Nexus versus
`21 Inix Incorporation and I think before the
`22 Christmas around that time. That's also an
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`Page 22
`1 IPR case. There are three different patents I
`2 was retained to work on to write declaration.
`3 I did that.
`4 Q. Were you retained in that case
`5 on behalf of the patent owner or on behalf of
`6 the petitioner?
`7 A. Petition, Inix, yes.
`8 MR. HUTCHINS: Is your
`9 involvement in a that case public?
`10 THE WITNESS: Pardon?
`11 MR. HUTCHINS: Is your
`12 involvement in that case known, public?
`13 THE WITNESS: I'm not sure. I
`14 mean, once you file the -- because IPR is not
`15 public. Isn't IPR --
`16 MR. HUTCHINS: Yeah.
`17 THE WITNESS: -- proceedings --
`18 MR. GOSSE: Proceedings are
`19 public, once it's filed, yes.
`20 THE WITNESS: Okay. Yeah. They
`21 have filed a declarations.
`22 MR. HUTCHINS: Okay. Then
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`1 BY MR. GOSSE:
`2 Q. And in that case were you
`3 representing -- working on behalf the
`4 petitioner or the --
`5 A. Nvidia. No. That is not an IPR
`6 case. That's a district case. It went to
`7 the trial.
`8 Q. Were they the patent owner or
`9 the accused infringer?
`10 A. The patent owner was Samsung. I
`11 mean, it was a series of patents between the
`12 two firms and there are lawsuits, counter
`13 lawsuits. The one I was involved in is a
`14 patent on DRAM on posted CACHE addressing
`15 scheme in DRAM. That was the Samsung patent.
`16 And so they asserted several claims in that
`17 patent on Nvidia products. So I was retained
`18 to defend -- or rather help the attorneys in
`19 terms of the claims which are asserted to
`20 invalidate them. So I was an expert for
`21 invalidating contention, as well as I was an
`22 expert for non-infringement.
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`Page 23
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`Page 25
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`1 that's fine.
`2 BY MR. GOSSE:
`3 Q. In terms of your past and I --
`4 strike that.
`5 Are you presently engaged in any
`6 other proceedings, litigation type
`7 proceedings?
`8 A. No. These two are --
`9 Q. And prior to your work on this
`10 matter, had you been engaged as an expert
`11 witness?
`12 A. Prior to which work?
`13 Q. This present case, the Apple
`14 versus Limestone case.
`15 A. Over the course of my career?
`16 Q. In the past five years.
`17 A. In past five years, I can't
`18 recollect all of them. But the main ones I do
`19 remember is that in Samsung versus Nvidia.
`20 THE REPORTER: One more time.
`21 THE WITNESS: Samsung versus
`22 Nvidia Corporation.
`
`1 Q. Okay. You mentioned that
`2 there's been other cases as well that you've
`3 have been involved in.
`4 A. I mean, I cannot offhand
`5 recollect everything, but I do remember that
`6 there was a case Nan Young, probably, and I
`7 cannot recall the plaintiff, probably just
`8 MOSTEC or something like that. So I had
`9 worked on that case. I had worked on --
`10 Q. In that case did you represent
`11 the accused infringer or the patent owner?
`12 A. The accused infringer.
`13 And then there was case on sense
`14 amplifier between -- I mean -- or I'm just
`15 forgetting the name of the company.
`16 Q. It's okay if you don't remember.
`17 A. Yeah.
`18 Q. In that particular case relating
`19 to the sense amplifiers --
`20 A. I thinks it's -- it's --
`21 Q. -- were you working on behalf of
`22 patent owner or the accused infringer?
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`Page 26
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`1 A. Defendant, yes. Defendant.
`2 I -- it just -- with all of this reading
`3 probably it just -- it's eluding my head.
`4 Q. Sure. In the last five years
`5 can you recall a case where you worked on
`6 behalf of the patent owner?
`7 A. On behalf of the patent owner --
`8 I mean, not -- I mean, there are some cases
`9 where some attorneys had contacted me for
`10 looking at -- reading my book and all, so I
`11 cannot offhand recollect, you know, who was
`12 for the -- many of these cases are just at the
`13 initial stage and I was not really involved
`14 too much when there was a lawsuit or not
`15 actually.
`16 So I do believe that some of
`17 them maybe was the plaintiff, but honestly I
`18 cannot recollect everything right now.
`19 Because I do recollect the ones which goes to
`20 this level of, you know, writing declaration
`21 or writing expert report and, you know, going
`22 to trial, that kind of thing.
`
`1 recall the major cases, like one, Hyundai
`2 versus Simmons. That went to trial. I was
`3 testifying witness there. So I do remember
`4 that and we won that trial all -- I mean,
`5 we -- I mean, Hyundai won the trial. Then --
`6 Q. And in that case, were you
`7 working on behalf of Hyundai or Simmons?
`8 A. On behalf Hyundai, yes.
`9 Q. Was Hyundai the patent owner?
`10 A. Well, it was in European court
`11 and Germany -- federal court in Germany and
`12 there -- initially Simmons brought an
`13 injunction to Hyundai's DRAM, so in
`14 contention, Hyundai files a case against
`15 Simmons that they are -- patent to invalidate
`16 that patent. So I was retained to help them,
`17 because the main -- whole concept in the
`18 patent came from my Ph.D work and subsequent
`19 publications. So that's why I was -- I played
`20 a very critical role. And in the judgment
`21 also they mentioned about my work and those
`22 kind of things. So I do remember that quite a
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`Page 29
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`1 Q. Sure. Sure.
`2 A. Yeah.
`3 Q. So in terms of the work that
`4 you've done --
`5 A. Majority is say for the
`6 defendant, yes.
`7 Q. Okay. And it sounds like you've
`8 been approached a few times by plaintiffs or
`9 patent owners but most of those didn't mature
`10 into significant amount of work.
`11 A. Yeah, because I have three books
`12 in this area, they look at that and they ask
`13 me and then, you know, I mean, they are -- so
`14 to answer your question, I cannot really
`15 recollect the details of any of those things
`16 right now.
`17 Q. So that was -- we were talking
`18 kind of about the last five years worth of
`19 your work. Prior to the last five years, have
`20 you ever worked on behalf of a patent owner
`21 or --
`22 A. I mean, I mostly recollect --
`
`1 bit, because I had to travel to Germany a
`2 couple of times.
`3 And then there was another case,
`4 again, I do remember probably it was MOSTEC
`5 was the plaintiff and Samsung was the
`6 defendant, but the -- in that case I had to
`7 simulate the row driver circuitry for
`8 different Samsung DRAM -- a whole bunch of
`9 different types of -- SDRAM, then DDR, the
`10 graphics RAM and all those stuff. So that
`11 case also was very extensive. I mean, I do
`12 remember that.
`13 Q. In the MOSTEC versus Samsung
`14 case, did you represent the patent owner or
`15 the --
`16 A. No. Samsung was the defendant I
`17 was --
`18 Q. And they were accused of
`19 infringing MOSTEC's patent?
`20 A. That's right.
`21 Q. Okay. So none of the cases that
`22 you can remember right now did you work on
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`Page 30
`1 behalf of the patent owner. Is that correct?
`2 A. As I mentioned to you, that
`3 Hyundai case was -- no patent -- not patent
`4 owner. Hyundai case, Hyundai was the
`5 plaintiff, actually.
`6 Q. They were the plaintiff, but
`7 they were not the patent owner --
`8 A. Right.
`9 Q. -- in the case?
`10 A. -- they were not. And some of
`11 the discussions and some of the initial, you
`12 know, consulting I did -- I'm -- I'm not
`13 maybe -- you know, one or two of them. Maybe
`14 they were plaintiff side actually. So, again,
`15 they just gave me some patents -- five, six
`16 patents to look into and analyze and give them
`17 some opinion -- not opinions, some -- help
`18 them to sort of understand. That kind of
`19 thing, actually.
`20 Q. Sure. But the major cases that
`21 you can remember today all involved patent
`22 owner --
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`1 Q. The information is the same in
`2 your CV, I assume.
`3 A. More or less, yes. CV keeps on
`4 changing.
`5 Q. Sure. I understand that you
`6 have a Ph.D in electrical and computer
`7 engineering from the University of Illinois.
`8 Is that right?
`9 A. Yes. You are referring to page
`10 number five, right?
`11 Q. Yes.
`12 A. Yes.
`13 Q. And you received that degree in
`14 1998 -- or 1988?
`15 A. Well, I mean, I defended my
`16 thesis in August 1987. I think when we
`17 finally submitted the thesis after the, you
`18 know, correction and things like that, after
`19 the defense, it expired that year's
`20 graduation. So my teaching was honored -- I
`21 was -- given to me in the next year 1988.
`22 Q. Sure.
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`Page 33
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`1 A. Yes. I mean, the ones where I
`2 have been involved to the extent of writing
`3 declaration, working with attorney for long
`4 time and then writing expert report for
`5 invalidity or non-infringement; or in the case
`6 of Samsung case, actually, I had to write a
`7 technical report in terms of the -- Samsung's
`8 circuitry versus the MOSTEC patent.
`9 So those types of things are the
`10 ones which went to trial. The Nvidia case
`11 went to trial actually. So, I mean, yeah,
`12 those -- all those cases it was I was working
`13 for the defendant side. Yes.
`14 Q. Okay. Let's look a little
`15 bit -- I'd like to talk to you about your
`16 education --
`17 A. Yes.
`18 Q. -- which is described in
`19 paragraphs six three through six --
`20 A. You're talking Exhibit 1?
`21 Q. Yes, of Exhibit 1.
`22 A. Okay.
`
`1 A. So, I mean, that by 1988.
`2 Q. Okay. Did you do outside work
`3 or research in between that time when the
`4 thesis was done and you actually graduated in
`5 1988?
`6 A. No. Basically, you know, I
`7 mean, they have very tight deadline and I did
`8 my defense pretty end actually -- well, it's
`9 not that I had to work for six months or
`10 something like that. So it's -- because of
`11 that way they -- set the cut off date for
`12 graduation for the convocation and all so
`13 that's why it happened.
`14 Q. Okay.
`15 A. I joined University of Michigan
`16 after finishing my Ph.D there.
`17 Q. Okay. Prior to your Ph.D work,
`18 I understand that you took a master's degree
`19 from the University of Alberta. Is that
`20 right?
`21 A. Yes.
`22 Q. What year did you receive that
`
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`1 degree?
`2 A. Can you repeat the question.
`3 Q. What year did you receive your
`4 master's degree?
`5 A. Again, probably -- there's a
`6 difference between the date I defended my
`7 thesis and when the degree was conferred on
`8 me.
`9 Q. Sure.
`10 A. I think the same thing. I think
`11 I did defend my thesis 1994, but the degree
`12 was conferred in 1995.
`13 Q. Now, what was the subject of
`14 your master's thesis?
`15 A. I don't think I have written the
`16 title here, but let me see whether it is there
`17 in my resume or not. Okay. In my resume I
`18 have given just the title of Ph.D thesis, but
`19 I do recall what my master's thesis was on. I
`20 think I looked into the prospect that DRAM,
`21 over the next course of next 20 years, will
`22 grow by a factor of hundred in terms of the
`
`1 what will be the networking connection and
`2 what will be the processor geometry so that we
`3 can get the packing density with high yield,
`4 so that was the flavor of the thesis.
`5 Q. So in sum it sounds like you
`6 were investigating multicore processors and
`7 how --
`8 A. Yes.
`9 Q. -- and how to fit a DRAM array.
`10 A. Absolutely.
`11 Q. Okay. So you're -- you're
`12 trying to fit a DRAM array or a series of
`13 arrays into a multicore processor?
`14 A. I mean, I did not, per se, say
`15 this is DRAM or this is the CACHE memory SRAM.
`16 It's more like, you know, if you have a core
`17 consisting of a CPU as well as the memory
`18 aisle you need and all, then what will be the
`19 floor planning of that so that the aggregated
`20 boundaries, what will be the shape, is the
`21 square or beyond square, what are the things.
`22 So those kind of things.
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`1 integration density. So at that time the
`2 integration density was hundred thousand
`3 transistors in most of the microprocessors and
`4 all. So when the integration increases to --
`5 by hundred fold or even a thousand fold, will
`6 have multiple microprocessors inside a chip.
`7 So what would be the way that we should
`8 connect them inside -- what is happening today
`9 in terms of multicore processors. I kind of
`10 envisioned that at the time of my master
`11 thesis. So I kind of looked at the different
`12 ways of what called the interconnection, which
`13 type of interconnection would be suitable for
`14 launching parallel processing and also the
`15 shape of the processors so that we can pack
`16 them as densely as possible. Besides square,
`17 there are other shape, actually. So it was
`18 kind of -- I think if I remember correctly,
`19 network.
`20 I mean, this -- particularly
`21 parallel processing inside a chip, using
`22 multiple processors, the connotation was that
`
`1 Q. Okay. And I understand that
`2 your bachelor's degree was from the Indian