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`Page 1
` UNITED STATES PATENT AND TRADEMARK OFFICE
` ____________________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________________________________________
` Intel Corporation
` Petitioner
` v.
` Qualcomm Incorporated
` Patent Owner
` U.S. Patent No. 8,698,558
` ____________________________________________
` Case IPR2018-01152
` Case IPR2018-01153
` Case IPR2018-01154
` Case IPR2018-01240
` ____________________________________________
`
` DEPOSITION of ALYSSA B. APSEL, Ph.D.
` Boston, Massachusetts
` August 13, 2019
`
`Reported by:
`Dana Welch, CSR, RPR, CRR, CRC
`Job #165514
`
`TSG Reporting - Worldwide
`
`877-702-9580
`
`Intel Corp. v. Qualcomm Incorporated
`IPR2018-01153
`Exhibit 2008
`
`

`

`Page 2
`
`Page 3
`
`APPEARANCES:
`For the Patent Owner:
`JONES DAY
`BY: JOSEPH SAUER, ESQ.
`North Point
`901 Lakeside Avenue
`Cleveland, OH 44114
`
`For the Petitioner:
`WILMERHALE
`BY: LOUIS TOMPROS, ESQ.
`RICHARD GOLDENBERG, ESQ.
`60 State Street
`Boston, MA 02109
`
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` August 13, 2019
` 9:23 a.m.
`
` Deposition of ALYSSA B. APSEL, Ph.D., held
`at the offices of WilmerHale, 60 State Street,
`Boston, Massachusetts 02109, before Dana Welch,
`Certified Shorthand Reporter, Registered
`Professional Reporter, Certified Realtime Reporter
`and Notary Public of the Commonwealth of
`Massachusetts.
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` APSEL
` P R O C E E D I N G S
` ALYSSA B. APSEL, Ph.D.,
` having been first duly sworn on oath,
`was examined and testified as follows:
` EXAMINATION
` BY MR. SAUER:
` Q. Please state your name for the record.
` A. Alyssa Apsel.
` Q. And, Dr. Apsel, you understand you're
` under oath this morning?
` A. Yes.
` Q. And is there any reason that you can't
` testify fully and truthfully this morning?
` A. No.
` Q. This deposition pertains to your
` supplemental declaration testimony in four IPR
` matters all pertaining to U.S. Patent Number
` 8,698,558.
` Is that your understanding?
` A. Yes.
` MR. SAUER: And for the record those IPR
` matters are IPR2018-01154, IPR2018-01153,
` IPR2018-01240 and IPR2018-01152.
` Does that meet your understanding?
`
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` A. Yes. I don't remember the numbers,
`but --
` Q. That's fine.
` A. -- I believe you.
` Q. I am handing you Intel Exhibit 1027 in
` IPR2018-01152.
` Do you recognize this as a copy of your
` supplemental declaration that you submitted in this
` IPR?
` A. Yes.
` Q. Did you write this document?
` A. Yes.
` Q. Are there any errors that you're aware of?
` A. There are not errors I'm aware of, but
` it's possible there are typos.
` Q. Any opinions you'd like to change?
` A. No.
` Q. Okay. You can set that one aside.
` MR. SAUER: I've now handed the witness
` Exhibit 1127 in IPR2018-0153.
` Q. Do you recognize this as a copy of your
` reply declaration in this IPR?
` A. Yes.
` Q. Did you write this one as well?
`
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`

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` APSEL
` A. Yes.
` Q. Any errors in this one or corrections?
` A. I found a typo. I can't remember exactly
` where it is. Oh -- no, I don't -- there is one
` typo in here that found, but I can't remember where
` it is actually. I thought that was it. But for
` the most part this expresses my opinion.
` Q. And no opinions you'd like to change?
` A. No.
` Q. Okay. Set that one aside, too.
` There you go. I'm now handing you
` Exhibit 1329 in IPR2018-01240.
` Do you recognize this as a copy of your
` reply declaration in this IPR?
` A. Yes.
` Q. You wrote this one, too?
` A. Yes.
` Q. Any errors that you'd like to change,
` opinions you'd like to change?
` A. No.
` Q. Okay. Set that one aside.
` One more. And now I've handed you
` Exhibit 1228 in IPR2018-01154.
` Is this a copy of your reply declaration
`
`Page 8
`
` APSEL
` Q. Okay.
` MR. SAUER: I'm handing the witness what's
` been previously marked as Intel Exhibit 1011.
` Q. Do you recognize this as a copy of the
` Kwak reference?
` A. Yes.
` Q. Take a look at Figure 5.
` Are you there?
` A. Yeah.
` Q. The equation that you refer to in your
` declaration, Io equals Ia plus Id relates to the
` operation of the circuits shown in Figure 5; is
` that right?
` A. Correct.
` Q. And specifically Io is the output flowing
` through the load Zl at the bottom right-hand part
` of the circuit, correct?
` A. Correct.
` Q. And Id is the current flowing through the
` inductor L, correct?
` A. Correct.
` Q. And you also refer to this current as the
` inductor current in your declaration, correct?
` A. Correct.
`
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` APSEL
` in this IPR?
` A. Yes.
` Q. You wrote this one?
` A. Yes.
` Q. Any corrections?
` A. No.
` Q. Okay. You can keep this one in front of
` you if you don't mind. If you'll turn to page 13,
` paragraph 25.
` Are you there?
` A. Yes.
` Q. In paragraph 25 you state, first sentence:
` "Second, any decrease in the linear amplifier
` current, Ia, caused by Kwak's feedforward path is
` balanced by an identical increase in the inductor
` current Id," correct?
` Did I read that correctly?
` A. Yes.
` Q. And then a couple of sentences later you
` state, "Therefore because Io=Ia+Id and because Io
` remains unchanged, if Ia decreases, Id must
` increase by the identical amount."
` Is this your testimony?
` A. Yes.
`
`Page 9
`
` APSEL
` Q. And Ia in the equation is the current
` shown at the bottom right portion of Figure 2,
` correct?
` A. Correct.
` Q. And you refer to that in some places in
` your declaration as a linear amplifier, correct?
` A. Correct.
` Q. If you can flip back a page to Figure 2 in
` Kwak, the equation that you refer to Io=Ia+Id, it's
` also reflected by the phase diagram in Figure 2(b),
` correct?
` A. Yes.
` Q. And as we talked about in your last
` deposition, each of the currents in this equation
` are complex variables both with a magnitude
` component and a phase component, correct?
` A. Yes.
` Q. And in Figure 2(b) of Kwak, the magnitude
` components of the current variables are represented
` by the length of the arrows or vectors in the phase
` diagram; is that right?
` A. That's correct.
` Q. And then the phase components are
` represented in the phase diagram by the angle
`
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` APSEL
` between the arrow and the x-axis; is that right?
` A. Yes.
` Q. And the equation Io=Ia+Id, it could also
` be written in polar form showing the magnitude and
` phase components?
` A. Yes.
` Q. If I were to give you a piece of paper
` would you be able to write the equation in polar
` form?
` A. Yes.
` Q. All right. I'm handing you a blank sheet
` of paper that's been marked as Apsel Deposition
` Exhibit A and a pen.
` Could you please write the equation
` Io=Ia+Id in polar form and make it big enough that
` I can see it without coming over there.
` (Exhibit A, Hand drawn equation, marked for
` identification.)
` A. So you want me to represent both the phase
` and the magnitude?
` Q. Yes, please.
` A. There are a couple of ways to do this.
` one is to say that --
` Q. Maybe with the magnitude and phase angle?
`
`Page 12
`
` APSEL
` combinations of sine and cosine. I can write that
` example, Io would be equal to Io times cosine omega
` t plus theta, right, plus J sine omega t plus theta
` naught. Okay?
` (Clarification by the reporter.)
` A. So I'm just writing the one term right
` now, expanding it out in Euler form, as I naught
` equals capital I naught times cosine omega t plus
` theta plus J times sine omega t plus theta.
` Q. And what's theta in your equation?
` A. That's the phase.
` Q. The phase of what?
` A. The phase of I naught of the combination.
` Q. So each theta has a -- it's not just
` theta. It's theta I or theta A or theta O?
` A. They're each -- each theta is different,
` right?
` Q. Right.
` A. That's why I gave them subscripts.
` Q. Okay. Subscript, that's the word I was
` looking for.
` So there are three theta variables in that
` equation?
` A. Yes.
`
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` APSEL
` A. I have to change the way that I define it.
` So Io is going to be, I'll call it Io positive, Io
` E to the J theta O.
` Q. Okay.
` A. And I'll call Ia equal to Ia times E to
` the J theta A. And Id equals Id times E to the J
` theta D. Okay?
` These can also be represented as
` combinations of sines and cosines. Each of these
` -- it's implied by that diagram that each of these
` is at a single frequency. This is a steady state.
` This pictures applies to single frequency. It's
` not a combination of frequencies. So each
` frequency has their own phaser.
` Q. Okay.
` A. And so this is also kind of implied that
` there is like A plus 0mega T term in there --
` Q. And what's that term represent?
` A. -- but we usually leave it out.
` That defines that it's a single -- that
` this is operating at a single frequency.
` So based on that, then I can just plug in
` for these expressions and I can say Io=Ia+Id.
` So these can be written either as
`
`Page 13
`
` APSEL
` Q. And there are three magnitude variables in
` that equation?
` A. There are three magnitude variables.
` Q. So your complexed equation has six
` variables?
` A. Yes.
` Q. And referring again to Figure 5 of Kwak,
` you agree that in Kwak's Figure 5, the use of the
` feedforward path does not change the output
` current, Io, in your equation, correct?
` A. Correct.
` Q. Now, in your complex equation, does that
` mean the addition to feedforward path would cause
` no change in either the magnitude or the phase
` component of Io?
` A. Can you repeat the question?
` Q. Try to say it better.
` In the complex version of your equation,
` the addition of the feedforward path in Figure 5
` would cause no change in both the magnitude and
` phase component of Io; is that correct?
` A. That's correct.
` Q. You also agree in Kwak's Figure 5 the use
` of a feedforward path causes a decrease in the
`
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` APSEL
` linear amplifier current Ia, correct?
` A. Yes.
` Q. But in your complex equation, that means a
` decrease in the magnitude component of Ia, correct?
` A. Yes, that's correct.
` Q. It doesn't necessarily mean a decrease in
` the phase component of Ia?
` A. So this is -- I have a little bit of a
` problem with the way this is being posed.
` Q. Okay. How so?
` A. Just because that assumption when we're
` talking about the magnitude in phase of the sine
` waves, we're talking about a single frequency
` component, whereas the full signal, what is coming
` out of Io is very unlikely to be a single phaser, a
` single frequency component. It's likely to be a
` combination, a sum of sines and cosines at
` different frequencies with a broad range of
` frequency content.
` So we can talk about a single frequency,
` like single component of that, that's saying that
` the phase and magnitude are changing in a certain
` way, but it's not exactly telling you how the
` current -- the sum of the currents, because they
`
`Page 16
`
` APSEL
` Q. And it may increase in one place and
` decrease in another; is that what you're saying?
` A. Yes. Or more likely increase more in some
` places and less in others; it's that sort of
` relationship.
` Q. So in your equation, when the feedforward
` path is introduced into Kwak's Figure 3 --
` Figure 5, we know the magnitude and phase
` components of the output current stay the same.
` A. Yes.
` Q. And we know that the magnitude component
` of the linear amplifier current decreases.
` A. Yes.
` Q. But there's still three unknown variables
` in that equation; isn't that right?
` A. I'm not sure I understand that.
` Q. Well, based on the complex equations
` you've written, when the feedforward path is
` introduced into Figure 5, we don't know what
` happens to the magnitude and phase component of Id
` or the phase component of Ia; isn't that right?
` They're unknown variables.
` A. I'm not sure that that can't be known. I
` don't look at the circuit immediately and know
`
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` APSEL
` can add -- those sines and cosines can add in phase
` or out or phase, it's not exactly telling you how
` the sum of those currents is changing necessarily.
` Q. So it would be fair to say that Figure 5
` of Kwak just doesn't give you enough information to
` know what happens to the phase of Ia?
` MR. TOMPROS: Object to form.
` A. No. I don't think that that's correct
` either. I think that the -- talking about the
` phase of Ia is a little strange because it is a
` combination of sines and cosines with different
` phases, that's what I'm trying to say.
` Q. Okay. But are you able to tell from Kwak
` or Figure 5 what happens to that combination of
` sines and cosines in Ia?
` A. There is a goal in this circuit of
` speeding up the response of the switcher, which is
` -- we can talk about the phase increasing or
` decreasing, but it's difficult to say that it's a
` single phase or of a single component because it's
` really an aggregate signal.
` Q. An aggregate of the phases of different
` components?
` A. Yes.
`
`Page 17
`
` APSEL
` exactly how much the phase is changing for one
` component versus the other, but I think it's
` certainly knowable.
` Q. In any of your calculations with respect
` to Kwak, have you ever calculated any of those
` values from that equation?
` A. I don't understand that question.
` Q. You said it's knowable. Have you
` determined those values from Kwak? Have you
` determined what happens to those components when
` the feedforward path is introduced in Figure 5?
` A. I can look at the circuit behavior and I
` can look at what the feedforward path is doing. So
` the feedforward path is adding to this summation
` block in Figure 5, and acts to change the signal
` going into this thresholding block. It increases
` it relative to -- it increases the negative input
` relative to the positive input, right? So it
` changes the output of this switching thresholding
` block, which we -- it's easy to see and understand
` that that changes the duty cycle of the switcher.
` And changing the duty cycle of the switcher changes
` the slope of the current of Id, which means that it
` will increase the current of Id.
`
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` APSEL
` So I can look at this circuit and I can
` say which direction things are going without
` knowing the specifics of, you know, what are the
` values of things in the circuit. It's difficult to
` say how much something is increasing or decreasing,
` but I can look at this behaviorally as a person
` skilled in the art and understand what this is
` doing.
` Q. Okay. Let's look back to your declaration
` on page 21, please.
` A. Okay. Yes.
` Q. Are you there?
` A. Uh-huh.
` Q. On page 21 you've included a diagram with
` a graph of the currents Io, Ia, and Id, correct?
` A. Yes.
` Q. And you've labeled this diagram Example 1.
` A. Yes.
` Q. And then on page 22, you have another
` diagram with another graph of the currents Io, Ia,
` and Id, correct?
` A. Yes.
` Q. And you've labeled them as Example 2,
` correct?
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`Page 20
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` APSEL
` can see how phases change and how amplitudes
` change.
` Q. Okay. But you didn't simulate Kwak's
` Figure 5?
` A. This is not an example of simulating
` Kwak's Figure 5.
` Q. Did you perform a simulation?
` A. I'm trying to remember. I don't remember
` if I actually have simulated this exact circuit. I
` played with some of the circuits on this, related
` to this patent.
` Q. But you didn't use a simulation to create
` this figure?
` A. No.
` Q. Let's discuss your first example. In
` paragraph 39 you state, "In Example 1, the phase of
` inductor current Id lags the total current Io phase
` by 20 degrees," right?
` A. Yes.
` Q. And this 20 degree phase difference can be
` seen in the graph as the difference between where
` the plot for Io and the plot for Id cross the
` x-axis, right?
` A. Yes.
`
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` APSEL
` A. Yes.
` Q. Are these two diagrams on page 21 and 22
` intended to show examples of the operation of
` Kwak's Figure 5?
` A. They're possible examples. They are based
` on just looking at how sine waves can add, so
` they're not based on a circuit simulation.
` Q. Okay.
` A. This is in response to Kelley's similar
` argument.
` Q. So you said they're possible examples,
` meaning they're non-limiting examples, there could
` be others?
` A. Sure.
` Q. What did you use to create these diagrams?
` First of all, did you create these diagrams?
` A. Yes, in combination with the attorneys.
` The equation that this is based on is a
` simple trigonometric identity, basically angle
` addition theorem. So sine of omega t plus theta
` equals sine -- I'm probably going to get it
` backwards in my head -- but sine theta cosign omega
` t plus sine omega t cosine theta, right? So
` basically you just plug in that identity and you
`
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` APSEL
` Q. And in your graph here it says "Phase Id
` lags Io by 10 degrees."
` I think that's a typo. That should be
` 20 degrees, right?
` A. Yeah, I think that's right.
` Where are you looking?
` Q. In the diagram on page 21 where it says
` "phase: Id lags Io by 10 degrees."
` A. Oh, yeah, that's a typo.
` Q. It should say 20 degrees?
` A. Should say 20.
` Q. On what basis did you choose a 20 degree
` phase difference?
` A. I picked it at random, just picking values
` that are possible.
` Q. Okay. In looking at this plot for the
` linear amplifier current Ia, in this first example
` there appears to be a 70 degree phase difference
` between Ia and Io, correct?
` A. Yes.
` Q. So you'd say Ia leads Io by 70 degrees?
` A. Yes. I think. I have to double-check.
` So sure.
` Q. On what basis did you choose a 70 degree
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` phase difference between Ia and Io?
` A. That's just based on the angle addition
` theorem, I mean, plugged in the numbers.
` Q. And in both Example 1 and Example 2, the
` output current Io has a peak-to-peak magnitude of 2
` volts, right?
` A. Yes, about. It's not exactly 2 volts.
` It's close.
` Q. Approximately 2 volts?
` A. Yeah.
` Q. On what basis did you choose a 2-volt
` peak-to-peak magnitude for Io?
` A. Just because one is a nice number.
` Q. Fair enough.
` Okay. And then in paragraph 39 you go on
` and you say, "The magnitude of the inductor
` current, Id, has a peak-to-peak value of 0.9397
` times 2 equals 1.8974 I sub PP, and the magnitude
` of the linear amplifier current, Ia, has a
` peak-to-peak value of 0.342 times 2 equals 0.6841 I
` sub PP, correct?
` A. Yes.
` Q. How did you determine these values?
` A. Again, this is just from angle addition
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` A. Yes.
` Q. And that's also a 10 degree phase change
` from your Example 1, I believe?
` A. Yes.
` Q. Did you have a basis for selecting that
` phase change?
` A. It falls out of the equation. I mean, the
` two phases have to add up to 90 degrees. It's
` just --
` Q. But nothing in Kwak led to that?
` A. No. It's just a mathematical identity.
` Q. And, again, in the next sentence of
` paragraph 40 you identify values for Id and Ia,
` specific values. And, again, you calculated those
` using the angle addition theorem; is that right?
` A. Yes.
` Q. So the values you've calculated here for
` the magnitude of Id are dependent on the phase
` values that you used for Id and Ia in this example,
` correct?
` A. Yes.
` Q. And if you had other phase values you'd
` have other magnitude values, correct?
` A. That's correct.
`
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` theorem, from trigonometric identity.
` Q. Let's look at Example 2 on page 22. In
` paragraph 40 you state, "In Example 2, the phase of
` inductor current Id lags the total current Io phase
` by 10 degrees," correct?
` A. Yes.
` Q. And, again, that's reflected in the
` diagram.
` A. Yes.
` Q. And this is a 10 degree phase change from
` your Example 1, right?
` A. Yes.
` Q. On what basis did you select a 10 degree
` phase change for the inductor current Id?
` A. I just wanted an example where there was
` an attempt to catch up the switcher, so just
` something less than 20.
` Q. Okay. Kwak doesn't specify a 10 degree
` phase change?
` A. No.
` Q. And looking to the diagram, you can see
` that the plot shows an 80 degree phase difference
` between linear amplifier current Ia and the output
` current Io, right?
`
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` Q. Okay. We can set that aside.
` Let's take a look at Exhibit 1127, which
` is your declaration for claims 1 through 9.
` A. Are we done with that as well
` (indicating).
` Q. Yes. You can set that aside, too.
` If you could turn to page 7. And in
` paragraphs 11 and 12 on page 7, you address your
` previous deposition testimony on the meaning of
` claim 6; is that right?
` A. Can you say again which paragraphs?
` Q. Paragraphs 11 and 12.
` A. 11 and 12.
` Yes. Okay. Let me just finish reading
` this.
` Q. Take your time.
` A. Yes.
` Q. And specifically in paragraph 11 you
` state, "patent owner suggests that I somehow,
` 'agreed that it would not make sense to interpret
` the boosted supply voltage as purely optional in
` the context of the claims,'" correct?
` A. Yes.
` Q. And then you go on in paragraph 12 to
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` discuss the language of claim 6; is that correct?
` A. Yes.
` Q. Handing you a copy of Intel Exhibit 1001.
` Do you recognize this as a copy of the '558 patent?
` A. Yes, I do.
` Q. And this is the patent you're discussing
` in paragraphs 11 and 12, correct?
` A. Yes.
` Q. Let's take a look at claim 6 together,
` which is second to last page.
` A. Uh-huh.
` Q. Are you there?
` A. Yes.
` Q. All right. Claim 6 begins with a
` preamble. Do you know what a preamble is?
` A. Yes.
` Q. The preamble of claim 6 states "An
` apparatus for wireless communication, comprising:"
` right?
` Did I read that right?
` A. Yes.
` Q. And then after the word "comprising" in
` claim 6, the claim includes two paragraphs, right?
` A. Correct.
`
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` supply voltage based on both the envelope signal
` and the boosted supply voltage, right?
` A. Yes.
` Q. And then right after this, the second
` paragraph of claim 6 goes on "wherein the supply
` generator incorporates"; do you see that?
` A. Yes.
` Q. And then after the word "incorporates,"
` the claim describes a number of things that are
` incorporated in the supply generator of claim 6,
` right?
` A. Okay. Let me read that.
` Yes.
` Q. And one of the things that claim 6 tells
` us must be incorporated in supply generator is
` starting at line 56, "a P-channel metal oxide
` semiconductor (PMOS) transistor having a gate
` receiving a first control signal, a source
` receiving the boosted supply voltage or the first
` supply voltage, and a drain providing the second
` supply voltage," correct?
` MR. TOMPROS: Objection to form.
` MR. SAUER: Did I misread it?
` MR. TOMPROS: I think you may have been
`
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` Q. And in the first paragraph starts with the
` words "a power amplifier," right?
` A. Correct.
` Q. And the second paragraph starts with the
` words "a supply generator," right?
` A. Correct.
` Q. Do you understand that everything in the
` second paragraph of claim 6 relates to the supply
` generator?
` A. Correct.
` Q. So let's take a look at that second
` paragraph. Starting at the fourth line of that
` second paragraph, one of the requirements for the
` claim supply generator is that it's operative to
` generate a second supply voltage for the power
` amplifier based on the envelope signal and the
` boosted supply voltage, correct?
` MR. TOMPROS: Objection to form.
` You can answer.
` THE WITNESS: Sorry.
` Q. You can answer.
` A. Yes, I see that.
` Q. So according to this claim language the
` supply generator must be able to generate a second
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` misheard as you read it given the -- on a critical
` word. What I think you said was "or" was written
` down as "with."
` MR. SAUER: Let me just repeat it.
` Q. One of the things that claim 6 tells us
` must be incorporated in the supply generator is "a
` P-channel metal oxide semiconductor (PMOS)
` transistor having a gate receiving a first control
` signal, a source receiving the boosted supply
` voltage or the first supply voltage, and a drain
` providing the second supply voltage. "
` Did I read that correct?
` A. Yes, I think so.
` Q. So this claim element tells us that the
` drain of the PMOS transistor in the supply
` generator provides the second supply voltage,
` correct?
` A. Yes.
` Q. And as we just discussed earlier in the
` paragraph, the same paragraph, the claim tells us
` that the supply generator must be operative to
` generate the second supply voltage based on the
` envelope signal and the boosted supply voltage,
` correct?
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` A. Yes.
` Q. So the claim also tells us that the PMOS
` transistor has a source receiving the boosted
` supply voltage or the first supply voltage, right?
` A. Yes.
` Q. So if the PMOS transistor were not
` configured to receive the boosted supply voltage at
` the source, it could not provide a second supply
` voltage if its drain is based on a boosted supply
` voltage, could it?
` MR. TOMPROS: Object to the form.
` A. I feel like that's ambiguous.
` Q. How so?
` A. The --
` Q. I'm sorry. What's ambiguous, the claim
` language or my question?
` A. Well, I mean, I'll be generous. The claim
` language.
` So the term "based on" is in my opinion
` somewhat ambiguous, that it's not clear -- that
` doesn't define that the source needs to be
` connected to the boosted supply voltage. It just
` implies that there's some type of connection
` somewhere. It's -- one has to make a leap to say
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` imaginary term has to be distributed. And I also
` put in two words, I include "for example" because I
` didn't write out the Euler form for all of the
` expressions; I only wrote it out for one.
` Q. Can I ask you now if you wouldn't mind to
` go back to the exhibit addressing claims 15 to 20,
` Exhibit 1128, your declaration on those claims, and
` specifically to page 22.
` A. 1128 or 1228?
` Q. Sorry. 1228. Thank you.
` A. Page 22?
` Q. Yes. And that's where your Example 2 is
` illustrated in paragraph 40 on page 22 of
` Exhibit 1228, correct?
` A. Yes.
` Q. This was one of the examples that you were
` asked some questions about earlier during
` Mr. Sauer's questioning, right?
` A. Correct.
` Q. And you were asked some questions about
` the choice of a 10 degree phase difference between
` Id and Io, right?
` A. Correct.
` Q. How, if at all, does that 10 degree phase
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` that it's therefore defining the source to be
` connected to the boosted supply voltage.
` Q. But at the very least you'd agree that the
` boosted supply voltage is necessary for the claim
` to function, correct?
` MR. TOMPROS: Object to the form.
` A. There must be a boosted supply voltage
` somewhere.
` MR. SAUER: I don't have any further
` questions, subject to redirect.
` MR. TOMPROS: Just a quick break outside.
` (Proceedings interrupted at 10:02 a.m. and
` reconvened at 10:04 a.m.)
` EXAMINATION
` BY MR. TOMPROS:
` Q. So first, Dr. Apsel, thank you for your
` time today.
` During the break, you had been reviewing
` Exhibit A and added some annotations; is that
` right?
` A. That's correct.
` Q. Could you explain what you did?
` A. I just added some brackets to these polar
` form expressions to make it clear that the
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` difference relate to the potential operation of the
` circuit of Figure 5 of Kwak?
` A. So if I look at Figure 5 of Kwak, the --
` first off, I would say that the described operation
` in the Kwak paper is that the purpose of this
` feedforward path is to accelerate the phase or --
` to accelerate the phase is not the right word -- to
` speed up the operation of the switcher so that it
` can support more of the current for i-out because
` it is more efficient than the linear amplifier.
` So the idea is that if the switcher is --
` ideally the switcher would be fast enough to
` provide all of i-out. It's not, so there's a
` linear amplifier that's added. The linear
` amplifier therefore provides a fast response.
` But the linear amplifier is less efficient
` than the switcher, so the idea of the feedforward
` path is that there are times when just giving the
` signal earlier to the switcher will enable it to
` pick up more of the load. And that's essentially
` what the circuit is supposed to do.
` So changing from if Id is -- so in this
` example, just using simple sine waves, if Id is
` lagging behind i-out by 20 degrees means that Id is
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