Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`CASES IPR 2018-01152;-01153;-01154;-1240
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`U.S. PATENT NO. 8,698,558
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`_________________________________
`)
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`INTEL CORPORATION,
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`))
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`))
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`_________________________________)
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`DEPOSITION OF ALYSSA B. APSEL, Ph.D.
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`March 6, 2019
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`New York, New York
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`TRANSCRIPT of the stenographic notes of
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`the deposition of ALYSSA B. APSEL, Ph.D., in the
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`above-entitled matter, as taken by and before
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`LORRAINE B. ABATE, a Certified Shorthand Reporter and
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`Notary Public of the State of New York and Registered
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`Professional Reporter, held at the offices of Wilmer
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`Cutler Pickering Hale and Dorr LLP, 7 World Trade
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`Center, New York, New York, on March 6, 2019,
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`commencing at 9:30 a.m., pursuant to Notice.
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`GregoryEdwards, LLC | Worldwide Court Reporting
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`
`Intel Corporation v. Qualcomm Incorporated
`IPR2018-01153
`Exhibit 2006
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`))
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`))
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`))
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`Petitioner,
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`vs.
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`QUALCOMM INCORPORATED,
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`Patent Owner
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`Page 1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CASES IPR 2018-01152;-01153;-01154;-1240
`
`U.S. PATENT NO. 8,698,558
`
`_________________________________
`)
`
`INTEL CORPORATION,
`
`))
`
`))
`
`_________________________________)
`
`DEPOSITION OF ALYSSA B. APSEL, Ph.D.
`
`March 6, 2019
`
`New York, New York
`
`TRANSCRIPT of the stenographic notes of
`
`the deposition of ALYSSA B. APSEL, Ph.D., in the
`
`above-entitled matter, as taken by and before
`
`LORRAINE B. ABATE, a Certified Shorthand Reporter and
`
`Notary Public of the State of New York and Registered
`
`Professional Reporter, held at the offices of Wilmer
`
`Cutler Pickering Hale and Dorr LLP, 7 World Trade
`
`Center, New York, New York, on March 6, 2019,
`
`commencing at 9:30 a.m., pursuant to Notice.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`Intel Corporation v. Qualcomm Incorporated
`IPR2018-01153
`Exhibit 2006
`
`))
`
`))
`
`))
`
`Petitioner,
`
`vs.
`
`QUALCOMM INCORPORATED,
`
`Patent Owner
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 2
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`A P P E A R A N C E S:
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`WILMER CUTLER PICKERING HALE and DORR LLP
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`Attorneys for the Plaintiff
`
`60 State Street
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`Boston, Massachussetts 02109
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`BY: LOUIS W. TOMPROS, ESQ.
`
`(617)526-6886
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`louis.tompros@wilmerhale.com
`
`-and-
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`WILMER CUTLER PICKERING HALE and DORR, LLP
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`7 World Trade Center
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`New York, New York 10007
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`BY: THEODOROS KONSTANTAKOPOULOS, ESQ.
`
`(212) 295-6367
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`theodoros.konstantakopoulos@wilmerhale.com
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 3
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` A P P E A R A N C E S (CONTINUED):
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`JONES DAY
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`Attorneys for the Defendant
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`North Point - 901 Lakeside Avenue
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`Cleveland, Ohio 44114-1190
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`BY: JOSEPH M. SAUER, ESQ.
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`(216)586-3939
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`jmsauer@jonesday.com
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`-and-
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`JONES DAY
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`500 Grant Street - Suite 4500
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`Pittsburgh, Pennsylvania 15219-2514
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`BY: JOSHUA R. NIGHTINGALE, ESQ.
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`jrnightingdale@jonesday.com
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 4
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` I N D E X
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` WITNESS: Alyssa B. Apsel, Ph.D
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` EXAMINATION BY PAGE
`
` Mr. Sauer 5
`
` *********
`
` E X H I B I T S
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` ( NONE MARKED )
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` *********
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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` ALYSSA B. APSEL, Ph.D.
`
` A L Y S S A B. A P S E L, Ph.D.,
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` Having been first duly sworn by a Notary
`
` Public of the State of New York, was
`
` examined and testified as follows:
`
` EXAMINATION BY MR. SAUER:
`
` Q. Hi, Professor. You understand that
`
` you're under oath this morning?
`
` A. I do.
`
` Q. Is there any reason you can't testify
`
` truthfully today?
`
` A. No.
`
` Q. And you've been deposed before?
`
` A. Yes.
`
` Q. So you know the drill. Just a couple of
`
` preliminaries. I'm going to try to ask clear
`
` questions.
`
` If I ask a question that you don't
`
` understand or isn't clear, if you could just let me
`
` know. I'll try to make it better.
`
` For the court reporter's sake, we need
`
` to try to not talk over one another. And if we need
`
` to take a break, just let me know. We can take a
`
` break at any time. The only thing I'll ask is if we
`
` are in the middle of a question, that you finish your
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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` ALYSSA B. APSEL, Ph.D.
`
` answer and then we can take a break afterwards.
`
` For the record, this deposition pertains
`
` to four IPR matters, and those matters are IPR 2018
`
` 01152, 01153, 01154, and 01240.
`
` Is that your understanding as well?
`
` A. Yes.
`
` Q. If I'm asking a question specific to any
`
` one of those four IPRs, I'll try to make that clear.
`
` But if it's not clear on the record or to you which
`
` IPR matter I'm referring to, if you could just ask
`
` and I'll make it clear. Okay?
`
` A. Okay.
`
` Q. I'm handing the witness what has been
`
` premarked as Intel Exhibit 1203.
`
` Sorry, these are double-sided to save a
`
` little space in my bag.
`
` A. Okay.
`
` Q. Do you recognize this document,
`
` Professor, as a copy of the declaration that you
`
` submitted in IPR 2018 01154?
`
` A. Yes.
`
` Q. And specifically, this declaration -- or
`
` back up a minute. This declaration relates to patent
`
` No. 8,698,558, correct?
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 7
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` ALYSSA B. APSEL, Ph.D.
`
` A. Yes.
`
` Q. And specifically, this declaration
`
` relates to claims 15 through 20 of that patent,
`
` correct?
`
` A. Yes.
`
` Q. Would it be all right if we refer to
`
` that as the '558 patent?
`
` A. Yes.
`
` Q. I'm now handing the witness what has
`
` been premarked as Intel Exhibit 1201.
`
` Professor, do you recognize this as a
`
` copy of the '558 patent?
`
` A. Yes.
`
` Q. Did you review the '558 patent in
`
` connection with the preparation of your declaration?
`
` A. Yes.
`
` Q. Would you consider yourself to be
`
` familiar with the technology described in the '558
`
` patent?
`
` A. Yes.
`
` Q. You can set that aside for a moment.
`
` If we can turn back to your declaration,
`
` please, and on page 83, is this your signature on
`
` page 83?
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 8
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` ALYSSA B. APSEL, Ph.D.
`
` A. Yes.
`
` Q. Did you write this document?
`
` A. Yes.
`
` Q. Are there any mistakes in this document
`
` that you're aware of?
`
` A. There may be some typos or minor issues,
`
` but I believe the opinions stated in here are all
`
` accurate.
`
` Q. Is there any opinions you would like to
`
` change?
`
` A. No.
`
` Q. Can you turn to page 85. Starting on
`
` page 85 is a copy of your CV, correct?
`
` A. Yes.
`
` Q. Is this a current copy?
`
` A. I believe it's a little bit old. It's
`
` probably a year, might be a year old.
`
` Q. Since --
`
` A. Eight months old or something.
`
` Q. Since you created this CV, is there any
`
` experience or publications or anything that is
`
` pertinent to the technology in the '558 patent?
`
` A. I don't think so, but my position has
`
` changed.
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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` ALYSSA B. APSEL, Ph.D.
`
` Q. What's your new position?
`
` A. I'm director of electrical and computer
`
` engineering at Cornell now.
`
` Q. Congratulations. I think I saw that in
`
` here somewhere.
`
` And what do the duties entail?
`
` A. I need to give an honest answer. A lot
`
` of cat herding.
`
` Q. Administrative duties?
`
` A. A lot of administrative duties, yes.
`
` Q. Do you still teach?
`
` A. No. Not right now.
`
` Q. So on page 87, there's a list, starting
`
` on page 87, that's a list of ten, I believe, patents
`
` that you're one of the inventors on; is that correct?
`
` A. I haven't counted, but I take your word
`
` for that.
`
` Q. I just counted. I'll represent there
`
` are ten.
`
` A. Yes.
`
` Q. Are there -- is this a current list?
`
` A. I think so, yes.
`
` Q. Based on your current recollection, are
`
` any of those patents relevant to the technology
`
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 10
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` ALYSSA B. APSEL, Ph.D.
`
` described in the '558 patent?
`
` A. The first one is a little bit relevant.
`
` It is a patent related to design of power amplifiers.
`
` Q. Any others?
`
` A. There are some related concepts in the
`
` third one somewhat. Actually, the third and fourth,
`
` because they're connected, but they're related to low
`
` power transceiver design.
`
` Q. And then starting on page 94, there a
`
` long list of many publications and book chapters and
`
` articles.
`
` A. Yes.
`
` Q. And I know this is a long list, but I'm
`
` going to ask you the same question; based on your
`
` current recollection, are there any publications that
`
` are relevant to the technology described in the '558
`
` patent?
`
` A. Yes. I'd say that the third one is
`
` related to the design of on chip power regulators,
`
` DCD convertors, ways of networking them together.
`
` Q. And specifically, that's the third
`
` journal paper?
`
` A. That's the third journal paper.
`
` The fourth one is related to the design
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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` ALYSSA B. APSEL, Ph.D.
`
` of power amplifiers, and also, some of the power
`
` control for power amplifiers at some level.
`
` Let's see. The one in September 2013 is
`
` related to low power transevers. There is
`
` probably -- if I look at the conference papers,
`
` there's also -- let's see. Probably the first one,
`
` the third one.
`
` Q. The first one and the third one?
`
` A. Of the conference papers, so conference
`
` proceedings and papers.
`
` MR. TOMPROS: Page 97.
`
` MR. SAUER: Thank you.
`
` A. Sorry, the first, third, fourth, sixth,
`
` seventh, eighth. Those are all related --
`
` Q. Okay. Great.
`
` A. -- to this area.
`
` Q. Well, thank you. I have some reading to
`
` do.
`
` A. Maybe I shouldn't have pointed them all
`
` out.
`
` Q. I'm sure they will be brilliant.
`
` If you could turn, then, to the
`
` declaration and pages -- excuse me.
`
` At the table of contents of the
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 12
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`ALYSSA B. APSEL, Ph.D.
`
` declaration, pages i, and ii, your declaration
`
` includes three grounds challenging the '558 patent,
`
` correct?
`
`A.
`
`Q.
`
`Yes.
`
`And specifically, ground 1 challenges
`
` claims 15, 17 through 18, and 20 as anticipated by
`
` Kwak, correct?
`
`A.
`
`Q.
`
`Yes.
`
`Claim 16 -- ground 2 is claim 16 as
`
` obvious in view of Kwak, correct?
`
`A.
`
`Q.
`
`Yes.
`
`And ground 3 alleges that claim 19 is
`
` obvious in view of Kwak combined with Choi 2010; is
`
` that correct?
`
`A.
`
`Q.
`
`Yes.
`
`I'm handing the witness now what has
`
` been premarked as Intel 1211.
`
`Professor, do you recognize the document
`
` I just handed you as a copy of the Kwak reference
`
` that is referenced in your declaration?
`
`A.
`
`Q.
`
`Yes.
`
`Did you review the Kwak reference in
`
` connection with the preparation of your declaration?
`
`A.
`
`Yes.
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 13
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` ALYSSA B. APSEL, Ph.D.
`
` Q. Would you consider yourself familiar
`
` with the technology described in Kwak?
`
` A. Yes.
`
` Q. If you can go back to go your
`
` declaration, then, on page 40, please. Starts on
`
` page 40 of your declaration. You address why, in
`
` your opinion, claim 15 of the '558 patent is
`
` anticipated by the Kwak reference, correct?
`
` A. Yes.
`
` Q. Is it your understanding that for a
`
` reference to anticipate a claim, that that single
`
` reference must disclose each and every element of the
`
` claim?
`
` A. Yes.
`
` Q. And is it your opinion that Kwak
`
` discloses each and every element of claim 15?
`
` A. Yes.
`
` Q. If you turn to page 43. Sorry, that
`
` double sided is a little awkward, but it saved me a
`
` lot of space.
`
` Starting at the bottom of page 43,
`
` subheading C, you address an element of claim 15
`
` requiring a switcher operative to sense an input
`
` current and generate the switching signal to charge
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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` ALYSSA B. APSEL, Ph.D.
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` and discharge the inductor to provide the supply
`
` current, the switcher adding an offset to the input
`
` current to generate a larger supply current via the
`
` inductor than without the offset, correct?
`
` A. Yes.
`
` Q. Is it your opinion that Kwak discloses
`
` this limitation of the claim?
`
` A. Yes.
`
` Q. It's a long claim element, so let's take
`
` it one part at a time.
`
` The claim starts a switcher operative to
`
` sense an input current, correct?
`
` A. Yes.
`
` Q. Referring to paragraph 92 on page 44,
`
` it's your opinion that Kwak discloses a switcher
`
` which is highlighted in yellow in the highlighted
`
` version of figure 5 on page 44, correct?
`
` A. Yes.
`
` Q. Referring to that highlighted version of
`
` figure 5, can you tell me what in the highlighted
`
` portion of this circuit is operative to sense an
`
` input current.
`
` A. Yes. So the switcher contains a PFET
`
` and an NFET that are switched via these drivers that
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 15
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` ALYSSA B. APSEL, Ph.D.
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` are controlled such that either one or the other is
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` on. Right? So basically, they are -- they have a
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` single input signal and they respond to opposite
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` polarity of that input signal. That signal is
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` modulated by this kind of thresholding circuit
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` beforehand, and the thresholding circuit is comparing
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` the sawtooth to the output -- the output of this
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` integrator. This integrator is kind of a conceptual
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` integrator. It's a block of an integrator. And so
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` the integrator is basically integrating the sum of
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` two currents, in this case. And so the current
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` that's being sensed is really, the sum of those two
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` currents.
`
` Q. Which two currents?
`
` A. There are two inputs into this summer.
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` Again, a conceptual summer shown in this picture,
`
` that are coming out of the block labelled As and the
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` black labelled Af.
`
` Q. So in figure 5, specifically, is it the
`
` summer that's doing the sensing, in your opinion?
`
` A. I wouldn't say it that way. I would say
`
` the sensing is a combination of the summation, the
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` integration and the comparison.
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` Q. And those three functions are being
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 16
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` ALYSSA B. APSEL, Ph.D.
`
` performed by the summation circuit that you've
`
` highlighted in brown on this figure 5 and the
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` integrator and the comparitor that are both
`
` highlighted in red; is that correct?
`
` A. Yes.
`
` Q. What in figure 5 of Kwak corresponds to
`
` the claimed input current?
`
` A. There's not an explicitedly drawn
`
` current signal here, but the input current would be a
`
` signal, the summed result of these two -- oh,
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` actually, what am I saying? Scratch that. I said
`
` that wrong.
`
` Sorry. The input current is coming from
`
` the -- that's the current coming from the linear
`
` amplifier the way this is described. Scratch what I
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` said before.
`
` Q. And the linear amplifier is the block
`
` highlighted in purple; is that correct?
`
` A. Yes.
`
` Q. So the current coming out of the block
`
` highlighted in purple is labeled in figure 5 ia; is
`
` that correct?
`
` A. That is the -- yes, that is the current
`
` coming out of the linear amplifier into the load, and
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 17
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` ALYSSA B. APSEL, Ph.D.
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` depending on how the sensing is done -- depending on
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` how the sensing is done, that's essentially what is
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` being sensed and used -- and used to sum with the
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` offset current to drive the switcher.
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` Q. So it's your opinion, then, that ia in
`
` figure 5 corresponds to the claimed input current?
`
` A. Yes.
`
` Q. How does the yellow highlighted switcher
`
` in figure 5 sense the current, sense the input
`
` current?
`
` A. There's a block As which is, again, a
`
` behavioral model of something. It could be done in a
`
` variety of different ways, but essentially, what
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` that's showing is that that is measuring the output
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` of that linear amplifier. You know, there are a
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` variety of ways that that could be done. It could be
`
` done with a current mirror, or by just, you know,
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` leaking off a small portion of the current that's
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` proportional to that current coming out of that
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` block. There are a number of ways it could be done.
`
` It's not shown in detail here, but that's essentially
`
` the idea.
`
` Q. Okay. You had said that the summation
`
` circuit in figure 5 receives two input signals,
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 18
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` correct?
`
` A. Yes.
`
` Q. And looking at figure 5, one of those
`
` input signals coming out of this block that's
`
` labelled As, right?
`
` A. Yes.
`
` Q. And the other input signal to the
`
` summation circuit comes out of the block labelled Af,
`
` correct?
`
` A. Correct.
`
` Q. The output of block As that you were just
`
` talking about is an AC signal, correct?
`
` A. It may have a DC component, but ideally
`
` it's an AC signal.
`
` Q. But essentially has an AC component?
`
` A. Yes.
`
` Q. Being a signal with an AC component or
`
` ideally, a pure AC signal, the output of block As
`
` would include both a magnitude and a phase, correct?
`
` A. Yes.
`
` Q. The next part of this claim element,
`
` looking back at the top of page 44, requires adding
`
` offset to the input current, correct?
`
` A. Yes.
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 19
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` ALYSSA B. APSEL, Ph.D.
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` Q. So again, referring to your highlighted
`
` version of figure 5, what in Kwak provides the
`
` claimed offset to the input current?
`
` A. The output of Af.
`
` Q. Af is a gained value, correct?
`
` A. Yes. I should clarify, the output of
`
` the block labelled with the label Af. Af is
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` presumably the gain of that block.
`
` Q. So to be clear, the output of block
`
` labelled Af provides, in your opinion, the offset to
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` the input current?
`
` A. Yes.
`
` Q. And you refer to that in some place as
`
` the offset current; is that correct?
`
` A. Could you direct me where I'm looking.
`
` Q. So as an example, let's look at
`
` paragraph 95 where you say the offset current is
`
` added to the sensed signal by the summing circuit.
`
` So in that sentence, when you're
`
` referring to the offset current, you're referring to
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` the current out of block Af, correct?
`
` A. Yes, or the equivalent circuit.
`
` Q. What do you mean the equivalent?
`
` A. I mean, this is a block diagram. So...
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 20
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` ALYSSA B. APSEL, Ph.D.
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` Q. So whatever --
`
` A. Whatever is performing that function,
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` yes.
`
` Q. Okay. Fair enough.
`
` But the output of block Af that you're
`
` referring to as the offset current is also an AC
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` signal, correct?
`
` A. It is probably not a pure AC signal. It
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` probably has a DC component as well.
`
` Q. It would have an AC component?
`
` A. It is -- it has probably both.
`
` Q. Can you turn to Kwak for a moment.
`
` A. Sure.
`
` Q. Look at page 2669 of Kwak on the upper
`
` right-hand corner of the little page numbers, and
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` specifically, this is at the page with figure 6.
`
` A. Yes.
`
` Q. And figure 6 has, on the left-hand side,
`
` a dotted box that's labelled feedforward path.
`
` Do you see that?
`
` A. Yes.
`
` Q. Is it your opinion that this feedforward
`
` path corresponds with the feedforward path that
`
` includes block Af in figure 5?
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 21
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` ALYSSA B. APSEL, Ph.D.
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` A. Can you repeat the question.
`
` Q. Sure. It wasn't asked very well.
`
` Figure 5 includes block Af in a
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` feedforward path, correct?
`
` A. Yes.
`
` Q. Is this the same feedforward path in
`
` figure 6? Let me ask it this way; is it your opinion
`
` that the components within the feedforward path in
`
` figure 6 would be an implementation of block Af in
`
` figure 5?
`
` A. Yes, I think that's fair.
`
` Q. And you see in the feedforward path in
`
` figure 6 there's a capacitor labelled C1?
`
` A. Yes.
`
` Q. Wouldn't that capacitor C1 block any DC
`
` components of the output?
`
` A. Yes.
`
` Q. So in view of that, wouldn't the output
`
` of block Af in figure 5 be a pure AC signal?
`
` A. In the implementation in figure 6, it is
`
` a pure AC signal.
`
` Q. It is.
`
` So referring back, then, to your
`
` declaration, at paragraph 95, and we read this
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 22
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` ALYSSA B. APSEL, Ph.D.
`
` earlier, I'm going to read it again.
`
` The first sentence in paragraph 95 says
`
` the offset current is added to the sensed signal by
`
` the summing circuit (the summation sign, outlined in
`
` brown.)
`
` So the summation circuit is outlined in
`
` brown in figure 5 in your highlighted version of
`
` figure 5, correct? Sorry, let me back up. Sorry. I
`
` messed up.
`
` Referring to paragraph 95 of your
`
` declaration, it's your opinion that the offset
`
` current, which you've testified is the output of
`
` block labelled Af in your highlighted version of
`
` figure 5, is added to the sensed signal by the
`
` summing circuit, correct?
`
` A. Yes.
`
` Q. And that summing circuit is the circuit
`
` that's highlighted in brown in your highlighted
`
` version of figure 5?
`
` A. Yes.
`
` Q. And you agree that both of the inputs to
`
` this summation circuit that's circled in brown in
`
` your highlighted version of figure 5 are AC signals,
`
` correct?
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 23
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` ALYSSA B. APSEL, Ph.D.
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` A. I think there still are potentially DC
`
` components of those. In the extenuation in figure 5,
`
` you know, it's not clear that it's pure AC, but
`
` it's -- certainly the intention of the circuit is to
`
` have AC components.
`
` Q. So let me ask it this way, then.
`
` The two inputs -- you would agree that
`
` the two inputs to the summation circuit highlighted
`
` in brown in figure 5 include AC components?
`
` A. Yes.
`
` Q. Both inputs?
`
` A. Yes.
`
` Q. And so then the output of that summation
`
` circuit would include a combination of those two AC
`
` inputs, correct?
`
` A. Yes.
`
` Q. In combining the two AC inputs, the
`
` magnitude of AC output from that summation circuit is
`
` going to be dependent on the phase alignment to the
`
` two AC components; isn't that correct?
`
` A. Yes.
`
` Q. If we can turn to page 50 of your
`
` declaration.
`
` On page 50, the paragraph 103, you
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 24
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` ALYSSA B. APSEL, Ph.D.
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` address Kwak's equation 4, correct?
`
` A. Yes.
`
` Q. And if we look at Kwak on page 2669,
`
` equation 4 appears on that page, right?
`
` A. It does.
`
` Q. And the equation in paragraph 103 of
`
` your declaration is the same equation as on page 2669
`
` of Kwak, correct?
`
` A. Yes.
`
` Q. One of the variables in equation 4 is
`
` the current output from the envelope amplifier A --
`
` ia, correct?
`
` A. Yes.
`
` Q. And that's the same ia that's shown in
`
` figure 5, correct?
`
` A. Yes.
`
` Q. Which is the envelope amplifier output
`
` current, correct?
`
` A. Yes.
`
` Q. And the envelope amplifier output
`
` current ia is an AC signal, correct?
`
` A. It has an AC component, as we said
`
` before.
`
` Q. Another variable in Kwak's figure 4 is
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 25
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` Vin, correct?
`
` A. Yes.
`
` Q. And this is the input voltage shown in
`
` figure 5, correct?
`
` A. Yes.
`
` Q. Is the input voltage Vin also an AC
`
` signal?
`
` A. In the sense that it has an AC
`
` component, yes.
`
` Q. Fair enough.
`
` So back on page 50 of your declaration,
`
` in paragraph 103, beneath Kwak's equation 4, you've
`
` provided another equation, correct? And you
`
` explain -- was that a yes?
`
` A. I'm sorry, it's not exactly an equation,
`
` but there's only one piece of an equation. It's an
`
` expression.
`
` Q. Okay. You provided a piece of an
`
` equation underneath Kwak's equation 4 on page 50?
`
` A. Yes.
`
` Q. And you explain that this portion of
`
` equation 4 that you've included on page 50 is
`
` representative of the total output current that is
`
` provided by the switcher id, correct?
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 26
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` ALYSSA B. APSEL, Ph.D.
`
` A. Yes.
`
` Q. Then you then state below the portion of
`
` the equation according to this expression, the supply
`
` current from the switcher id is proportional to the
`
` offset current Af:as the offset Af increases, so will
`
` the supply current from the switcher id, correct?
`
` A. Yes.
`
` Q. Af is a gained value, right?
`
` A. It's a gained value, but in this case, I
`
` mean, it's being used to represent the output of that
`
` block.
`
` Q. So in what sense?
`
` A. In this description. The Af times the in
`
` is pointing to the output current. So it's kind of a
`
` proxy for --
`
` Q. Okay.
`
` A. -- current.
`
` Q. So what you're saying is --
`
` A. It's a bad way of describing it, I
`
` agree.
`
` Q. How would you describe it?
`
` A. Af is not -- is not a current.
`
` Q. Would it be better to say that the
`
` supply current from the switcher is proportional to
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 27
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` ALYSSA B. APSEL, Ph.D.
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` the -- to Af multiplied by Vin? I'm just trying to
`
` understand what you meant here.
`
` A. Yes.
`
` Q. And that Af times Vin corresponds to what
`
` you're calling the offset current, correct?
`
` A. Yes.
`
` Q. Okay. According to this portion of
`
` Kwak's equation 4 that you list here on page 50,
`
` though, the supply current from the switcher id is
`
` proportional to the sum of As times ia and Af times
`
` Vin, right?
`
` A. Yes.
`
` Q. You agree that ia and Vin are signals
`
` that include AC components, correct?
`
` A. Yes.
`
` Q. And so according to this equation, the
`
` magnitude of current id is going to be dependent on
`
` the phase alignment of ia and Vin, correct?
`
` You want me to re-ask that?
`
` A. Yes.
`
` Q. According to this equation, the
`
` magnitude of the current i -- I'm trying to read it,
`
` but let me re-ask it.
`
` According to this equation, the
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`
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`Alyssa B. Apsel, Ph.D. - March 6, 2019
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`Page 28
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` ALYSSA B. APSEL, Ph.D.
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` magnitude of the current id is going to be dependent
`
` on the phase alignment of AC signals ia and Vin?
`
` A. Sorry, I have to --
`
` Q. You want me to say it one more time?
`
` A. Yeah, say it one more time.
`
`
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