Transcript of Arthur W. Kelley,
`Ph.D.
`
`Date: June 21, 2019
`Case: Intel Corporation -v- Qualcomm Incorporated
`
`Planet Depos
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`planetdepos.com
`
`Intel v. Qualcomm
`Exhibit 1229
`IPR2018-01154
`
`Worldwide Court Reporting & Litigation Technology
`
`

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`Transcript of Arthur W. Kelley, Ph.D.
`Conducted on June 21, 2019
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`APPEARANCES:
`
` On Behalf of the Petitioner:
`
` JAMES M. DOWD, ESQ.
` WILMER HALE
` 350 South Grand Avenue
` Suite 2100
` Los Angeles, CA 90071
` 213.443.5309
` 213.443.5400 FAX
` James.dowd@wilmerhale.com
`
` RICHARD GOLDENBERG, ESQ.
` WILMER HALE
` 60 State Street
` Boston, MA 02109
` 617.526.6548
` 617.526.5000 FAX
` Richard.goldenberg@wilmerhale.com
`
` On Behalf of the Patent Owner:
`
` JOSEPH M. SAUER, ESQ.
` DAVID E. ANDERSON, ESQ.
` JONES DAY
` North Point
` 901 Lakeside Avenue
` Cleveland, OH 44114
` 1.216.586.3939
` 1.216.579.0212 FAX
` jmsauer@jonesday.com
` danderson@jonesday.com
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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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`- - - - - - - - - - - - x
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`INTEL CORPORATION
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` : IPR2018-01152; -01153;
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` Petitioner
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` vs.
`
` :
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`-01154; -01240
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` :
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`QUALCOMM INCORPORATED
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` : U.S. Patent No. 8,698,558
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` Patent Owner. :
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`- - - - - - - - - - - - x
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` Deposition of ARTHUR W. KELLEY, PH.D.
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` Cleveland, Ohio
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` Friday, June 21, 2019
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` 9:30 a.m.
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`Job No.: 244258
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` EXAMINATION INDEX
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`4
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`EXAMINATION OF ARTHUR W. KELLEY, PH.D.
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` BY MR. DOWD
` BY MR. SAUER
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` 5
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`Exhibit
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` EXHIBIT INDEX
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`1026, 1126, 1227, 1328 Order Construing Claims
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`Pages: 1 - 309
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`Reported By: Cheryl L. Baker, RPR
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` Deposition of ARTHUR W. KELLEY, PH.D., held at
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`the offices of:
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` JONES DAY
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` 901 Lakeside Avenue
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` Cleveland, Ohio 44114
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`(216) 586-3939
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` Pursuant to notice, before Cheryl L. Baker,
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`Registered Professional Reporter, and Notary Public
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`Transcript of Arthur W. Kelley, Ph.D.
`Conducted on June 21, 2019
`5
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` A Okay.
` Q You can take a break at any time. The
`only thing I'll ask is if we have a question
`pending, that you answer the question before we
`take a break. Okay?
` A
` I understand.
` Q
` Now, you understand that Intel has
`filed four IPR petitions seeking to invalidate
`Claims 1 through 20 of U.S. Patent No. 8,698,558?
`
` A
` That's right.
` Q
` If I refer to it as the '588 patent,
`that will make sense?
`
` A
` That will be fine.
` Q
` The IPR numbers are IPR208-1152 --
`sorry -- 2018-1152, 1153, 1154, and 1240. Is it
`okay if I refer to those as just by their last
`digits?
` That would be fine.
`
` A
` Now, you've submitted four
` Q
`declarations, one in each of the IPRs; is that
`right?
`
` A
`
` That's correct.
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`
` ARTHUR W. KELLEY, Ph.D.
` Being first duly sworn or affirmed to
`testify to the truth, the whole truth and nothing
`but the truth, was examined and testified as
`follows:
` EXAMINATION BY COUNSEL FOR THE PETITIONER
`BY MR. DOWD:
` Q Welcome back, Dr. Kelley.
` A Good morning.
` Q Please state your full name for the
`record.
` A Arthur Woodton, Kelley, K-e-l-l-e-y.
` Q What's your current address?
` A 2033 Weston Green Loop, three words.
` Q And you understand you're under oath
`today?
` A Cary, North Carolina.
` Q Sorry?
` A Do you want the zip?
` Q Sure.
` A 27513.
` Q You understand you're under oath
`
`2 (5 to 8)
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`today?
` A I do.
` Q And that means you must answer my
`questions truthfully and fully just as though you
`were in a court or a hearing room in front of a
`Judge.
` I understand.
` A
` Is there any reason why you can't
` Q
`provide complete and accurate testimony today?
`
` A
` No reason.
` Q
` Are you suffering from any medical
`condition?
`
` A
` I'm not.
` Q
` Under the influence of any
`medications?
`
` A
` I'm not.
` Q
` I know you've been deposed before, so
`you understand the ground rules. But I'll just
`briefly note them. If there's any question that I
`ask of you that you don't understand, please let me
`know so I can try to rephrase my question in the
`moment to avoid any confusion. Okay?
`
` Let me just hand you copies of the
` Q
`depositions -- I'm sorry -- the declarations so
`that you have them handy. The first is in the 1152
`IPR, Exhibit 2005. Then in the 1153 IPR, again,
`Exhibit 2005; in the 1154 IPR, Exhibit 2002, and
`finally in the 1240 IPR, again, in Exhibit 2002.
` A You know, as I sit here and look at
`this, these have binder clips on them. Could I
`have stapled copies? Could I perhaps have the
`stapled ones? That would avoid some of the
`0
`problems.
`11
` Q No problem.
`12
` A That would be great. So let's
`13
`inventory. 53, 4 -- I have the documents.
`14
` Q Thank you. And the documents that
`15
`have been placed before you and previously marked,
`16
`those are your four declarations in these IPRs; is
`17
`that correct?
`18
`
` A That's correct.
`19
` Q Now, in each of your declarations,
`20
`have you listed all of the documents that you
`21
`considered in forming your opinions?
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`Transcript of Arthur W. Kelley, Ph.D.
`Conducted on June 21, 2019
`9
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`3 (9 to 12)
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`before?
` No.
` A
` Had you heard of any of the inventors
` Q
`named on the '558 patent before that?
` A
` I had not.
` Q
` If you turn to the 1152 Declaration,
`but I think it's appended to each of them, turn to
`your CV at the back. In the 1152 Declaration,
`Appendix A.
`
` A
` I have that.
` Q
` And is your CV here accurate?
` A
` Let me just review and make sure.
`
` A
` Yes. I think it is all the recent
`
`work that I've done is here. And the other things
`I know to be accurate.
` Q
` If you turn to Page 3, you were a
`senior design engineer at Linear Technology
`Corporation from 2000 through September 2007?
`
` A
` Page 3 of 9. And yes, that's what it
`says here on Linear Technology Corporation.
` Q
` While working at Linear, did you work
`with power management circuits?
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` That's right.
` A
` And have you provided all the opinions
` Q
`that you have in each of the IPRs?
` A
` That's right.
` Q
` Great. And all bases for each
`opinion?
` A
` That's right.
` Q
` Do you have any plans to supplement
`your declarations?
`
` A
` I have no plans to do so, but things
`happen. If I'm asked, I will. But as far as I
`know, there's no plan to do that.
` Q
` Any plan to change any opinion stated
`in any declarations?
`
` A
` No.
` Q
` Now, you've provided opinions about
`the validity of the '588 patent in the related ITC
`case and the District Court case in San Diego; is
`that right?
`
` A
` That's right.
` Q
` Have your opinions changed since the
`ITC case?
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` No.
` A
` Has the basis for your opinion
` Q
`changed?
` A
` No.
` Q
` How about since the San Diego case?
` A
` No.
` Q
` Are you providing any theories of
`validity that were not presented in the ITC
`validity report?
` MR. SAUER: Objection; form.
` I would perhaps have to go back and
` A
`
`review. But as I sit here today, I don't recall
`any differences. But I couldn't answer without a
`direct review.
` Q
` Okay. And is your answer the same for
`the District Court case?
`
` A
` That's right.
` Q
` Now, before you were retained for the
`first case that involved '558, I think that was the
`ITC case?
`
` A
` That's fine.
` Q
` Had you heard of the '558 patent
`
` I did.
` A
` Were you involved in designing power
` Q
`management circuits at Linear Technologies?
` A
` I was.
` Q
` Now, am I correct that power
`management circuits manage power?
` A
` That's kind of a tautology. But
`certainly power management, integrated circuits get
`used in power supplies.
` Q
` Is it fair to say that one goal of a
`0
`management circuit is to make sure that the circuit
`11
`that's being managed has enough power to operate?
`12
` A
` When you say, "the circuit that's
`13
`being managed," I'm not quite sure of that.
`14
`There's input power. There's output power.
`15
`There's a supply in between.
`16
` Q Sure. So I'm thinking here of the
`17
`power management circuit will manage the power
`18
`that's supplied to some load. Is that fair?
`19
` A That's fair.
`20
` Q And one goal of the power management
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`circuit is to make sure the power supplied to that
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`Transcript of Arthur W. Kelley, Ph.D.
`Conducted on June 21, 2019
`13
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`4 (13 to 16)
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`references in this case?
` A
` I have.
` Q
` Prior art references that perform
`envelope tracking, right?
` A
` Prior art references describe
`themselves as envelope tracking.
` Q
` If you would turn to Figure 2 in the
`patent. There's 2A through 2C.
` A
` Okay.
` Q
` Let me focus you on 2C for a moment.
` A
` Okay.
` Q
` Now, that is -- that shows an envelope
`tracker, right?
`
` A
` That shows a block 230, which is an
`envelope tracker, yes.
` Q
` And then on the right-hand side of 2C,
`that shows kind of a graph that shows the actual
`envelope tracking function, right?
`
` A
` Well, it's an illustrative figure that
`shows how that particular implementation would
`work. Sure.
` Q
` Now, the envelope tracker, as shown in
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`load is sufficient to operate. Right?
` A The load will have certain
`specifications. And then the power management
`circuit of the power supply is intended to stay
`within that specification. That's correct.
` Q Okay. And then another goal is to
`make sure that you don't waste power unnecessarily.
`Is that fair?
` A High efficiency would be typically the
`way we would say that. But yes, we would like them
`as highly efficient as possible.
` Q And so in designing a power management
`circuit, you're balancing those competing concerns,
`providing enough power for the load while at the
`same time being as efficient as you can be. Is
`that fair?
` A I'm not sure I'd characterize them as
`being competing. There's certainly simultaneous
`concerns. You worry about both of those in terms
`of making your power supply work properly.
` Q Okay. But those are kind of standard
`objectives of a designer designing a power
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`management circuit?
` A At least.
` Q Okay. Let me provide you a copy of
`the patent. So this has previously been marked in
`the 1152 IPR as Intel 1001. I'll give you the
`version that's stapled.
` A
` Thank you.
` Q
` And Exhibit 1001, that's the '558
`patent?
` That's right.
`
` A
` If you -- withdrawn.
` Q
` Am I correct that the '558 patent is not the
`first to invent envelope tracking?
` MR. SAUER: Objection; form.
` Well, certainly the '558 patent
` A
`
`describes a way of doing envelope tracking. Could
`the words "envelope tracking" be applied to
`something that came before the '558 patent? I'd
`imagine they could be, but we'd have to look at
`specifics to really answer that question
`definitively.
` Q But you've seen some prior art
`
`Figure 2C, that approach was known in the prior
`art, right?
` A
` I believe that it was in some
`implementations.
` Q
` Okay. Now, if you look at Figures 2A
`through 2C, what's shown on the right for each of
`these figures illustrates power savings that is
`provided -- let me break that down.
` So along the top, there's a constant power
`source, Vbat, in 2A. Do you see that?
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` A That I see.
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` Q And in Figure 2B, it shows some power
`12
`savings by using the average power tracking
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`approach. Is that fair?
`14
`
` A Well, actually, I mean -- I think the
`15
`descriptive text relating to these figures talks
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`about that. I'm not sure if it's labeled as such
`17
`on these figures. But it's certainly meant to be
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`an illustration of some text that would talk about
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`how to save power; example, using average power
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`tracking.
`21
` Q And then if we step down from Figure
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`Transcript of Arthur W. Kelley, Ph.D.
`Conducted on June 21, 2019
`17
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`5 (17 to 20)
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`19
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`power savings; is that correct?
` MR. SAUER: Objection to form.
` A This relates, as the final sentence
`says, "The power amplifier is operated in
`saturation -- " this final sentence starts at line
`30. "The power amplifier is operated in saturation
`for all envelope amplitudes in order to maximize
`power amplifier efficiency."
` Q Okay.
` A So this is addressing the efficiency
`of the power amplifier. The envelope tracking
`helps the power tracking to be more efficient.
` Q The envelope tracking that was known
`in the prior art will also make the power amplifier
`more efficient; is that correct?
` MR. SAUER: Object to form.
` A Well, the intent of envelope tracking
`is to make the power amplifier more efficient. It
`doesn't say anything about, in particular, at least
`this point we're looking at, the efficiency of the
`box that's doing the envelope tracking.
` Q Okay. But my question is, the
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`2B to Figure 2C on the right side, it shows some
`additional power savings of envelope tracking over
`average power tracking. Is that fair?
` A Well, the associated text would
`describe that. This is used to illustrate that
`power savings of envelope tracking.
` Q Okay. I think we may have already
`covered this, but to make sure I'm complete because
`I don't have the Livenote in front of me, you agree
`that the prior art envelope power trackers --
`withdrawn.
` You agree that prior art envelope tracking
`achieve the power savings that's shown in 2C,
`right?
` MR. SAUER: Objection; form
` A The power savings in which part of the
`circuit?
` Q The power savings in the envelope
`tracking. In other words, in the provision of the
`Vpa that's shown in the figure.
` A Again, I'm not sure I can answer your
`question. What is intended here is to show that
`18
`the box 230 envelope trackers provide some level of
`power savings. But what the envelope tracker does
`in terms of providing that level of power savings
`depends on which approach you might, perhaps, use
`for that envelope tracker.
` Q So if you keep out 2C but you also
`turn to column 4, I think that's the text you're
`referring to starting at about line 21.
` A Okay.
` Q Do you see there's discussion of
`Figure 2C starting at line 21?
` A Right.
` Q And then down at about line 26 it
`states, "The PA supply voltage closely tracks the
`envelope of the RFout signal over time. Hence, the
`differences between the PA supply voltage and the
`envelope of the RFout signal is small, which
`results in less wasted power." Do you see that
`statement?
` A Right.
` Q So at that level, prior art envelope
`trackers were able to achieve the same type of
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`efficiency that's referenced in column 4 that we've
`just gone through.
` A Yes.
` Q And that's shown in Figure 2C on the
`right.
` A Right.
` Q That efficiency was achieved by prior
`art envelope trackers, correct?
` MR. SAUER: Objection to form.
` A The efficiency for the power
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`amplifier, yes.
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` Q Okay. So I guess the point that I'm
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`getting at, if there's any power savings of the
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`'558 claims, it has to be beyond what's shown in
`14
`Figure 2C, right?
`15
` MR. SAUER: Objection; form.
`16
` A The '558 is directed toward the
`17
`efficiency of that box there that's doing the
`18
`envelope tracking.
`19
` Q Okay.
`20
` A And what we just looked at was
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`regarding trying to make the power amplifier more
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`

`Transcript of Arthur W. Kelley, Ph.D.
`Conducted on June 21, 2019
`21
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`23
`make that RF power amplifier more efficient. And
`how you do that in the envelope tracker can be more
`or less efficient depending on what you do in the
`envelope tracker circuit that's providing the
`voltage feed PA.
` Q
` But whatever that efficiency is inside
`the box 230 --
` A
` Right.
` Q
` -- that's not shown in Figure 2C,
`right?
` No. This is talking about the
` A
`advantage of envelope tracking in general.
` Q
` I think we're on the same page then.
` Now, if I've understood correctly, you've
`identified two things you say are inventive about
`the '558 patent, right?
` A Which two and we'll see if I agree?
` Q The first is that the envelope
`amplifier dynamically receives either the first
`supply voltage or the boosted supply voltage?
` A I think I've called that selective
`boost. So if we're talking -- selective power. So
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`efficient. So those are two different things.
` Q Okay. I think we're on the same page.
`So the efficiency or power savings of the '558
`claims, that's different from what's shown in
`Figure 2C?
` MR. SAUER: Objection; form.
` Well, Figure 2C shows a box 230 called
` A
`envelope tracker.
` Q
` Right.
` A
` Okay. There are lots of ways to do
`that envelope tracker, some of which could be more
`efficient, some of which could be less efficient.
` Q
` I understand.
` A
` Right. So you could -- as long as you
`did some effective version of envelope tracking,
`Figure 2C says that you can save energy in the
`power amplifier 210.
` Q
` And my question is -- I think we're
`talking about the same thing. But my question is,
`the right-hand portion of 2C, if you focus on this.
` A
` Right.
` Q
` You told me that that's the efficiency
`
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`
`24
`yes, that's right. Either the first supply voltage
`or the boosted voltage.
` Q
` And just to map that feature, that
`feature is not recited in Claims 15 through 20,
`right?
` A
`
` So you asked about Claims 15 through
`
`20?
`
`at the power amplifier of using the technique
`envelope tracking, right?
` A
` That illustrates that if you do
`envelope tracking, the RF power amplifier 210 in
`the figure becomes more efficient.
` Q
` Right. And that efficiency was true
`of prior art envelope trackers, right?
` A
` If we restrict the discussion to the
` Yes.
` Q
` So if I look at Claim 19.
` A
`power amplifier only.
` Okay.
` Q
` Q
` And so the efficiency, if there is
`0
` I see that feature there wherein the
` A
`
`any, to the claims of the '558 patent is the
`11
`envelope amplifier operates based on the first
`different efficiency than what is shown in Figure
`12
`supply voltage or the boosted supply voltage.
`2C, correct?
`13
`
` A
` The efficiency claims of the '558
` Q
` Thank you. Then what you've called
`14
`patent would be within the box labeled envelope
`the selective boost feature is not a part of Claims
`15
`tracker.
`15, 16, 17, 18 or 20; is that correct?
`16
`
` A
` No. Those are addressing different
` Q
` Right. And so it's different from
`17
`features of the patent.
`what's shown in the right-hand portion of the graph
`18
` Q
` Okay. And then the second feature
`of Figure 2C, right?
`19
`that you've identified as novel about the '558
` MR. SAUER: Objection.
`20
` Well, you know, I've already testified
` A
`
`claims is an offset current in a switcher that
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`that, you know, the efficiency in Figure 2C is to
`increases the inductor current; is that right?
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`Transcript of Arthur W. Kelley, Ph.D.
`Conducted on June 21, 2019
`25
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`7 (25 to 28)
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`27
`
`converter.
` Q You see it says, "In another design"?
` A Right.
` Q Whereas that at line 14 it said, "In
`one design."
` A Okay.
` Q And you'd agree that another design at
`line 24 is different than the one design at line
`14, right?
` A I'm not sure I see it that way in
`reference to Figure 3. But I don't know. I don't
`have an answer for that. I think it's consistent.
`It's just saying you can with a low battery voltage
`operate off the boost converter.
` Q Okay. So let me ask it this way: If
`in the -- another design, line 24, "the entire
`envelope tracker is operated based on the Vboost
`voltage," correct?
` A That is describing a mode in which the
`envelope tracker is operating from the Vboost
`voltage. That's right.
` Q And that means that the envelope
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` A That's right. That's what's in
`Claim 15, for example.
` Q Okay. And just to map it out, that
`feature is not in Claims 1 through 14, correct?
` A I don't believe it is. But, again, I
`guess I'm going to have to check.
` Q Please. Thank you.
` A So just so I can make sure I'm
`answering plainly, would you mind giving me the
`question again, please.
` Q Sure. My question is, the offset
`current that increases inductor current, that
`feature is not claimed in Claims 1 through 14?
` A I believe that's correct, yes.
` Q Okay. If you could turn to column 8
`of the patent. And there's some discussion
`starting at line 10 in that paragraph. It goes
`down to about line 23.
` A Okay.
` Q Do you see there's discussion about
`line 13, where it says, "In one design"?
` A Yes.
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`26
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` Q That portion where it says, "In one
`design of supporting operation with a lower battery
`voltage, as shown in Figure 3, switcher 160 is
`connected to the Vbat voltage and envelope
`amplifier 170 is connected to either the Vbat
`voltage or the Vboost voltage," and then continues.
` That portion is describing what you've
`identified as selective boost; is that right?
` A At least. And with regard to Figure 3
`and elsewhere. But that's certainly one example.
` Q And then the next paragraph down,
`starting at about line 24 states, "In another
`design of supporting operation with a lower battery
`voltage, the entire envelope tracker is operated
`based on the Vboost voltage from boost converter
`180." Do you see that?
` A Right.
` Q And you understand that's a second
`embodiment?
` A I'm not sure I agree with that. I
`think it's just simply reciting one operational
`mode in which it's operating off the boost
`
`amplifier is powered by the Vboost voltage all the
`time, right?
` A I'm not sure I agree with that based
`on the context.
` Q Well, do you see in the next line it
`says, "In this design, boost converter 180 provides
`high current required by the power amplifier 130,
`which may be more than one Ampere, and efficiency
`is reduced by the efficiency of boost converter
`180, which may be approximately 85 percent."
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` A I see that.
`11
` Q And so in this design, starting at
`12
`line 24 of column 1A, the efficiency is the
`13
`efficiency of the boost converter, right?
`14
` A The efficiency of what is the
`15
`efficiency of the boost converter?
`16
` Q The efficiency identified for this
`17
`design is the efficiency of the boost converter,
`18
`approximately 85 percent, right?
`19
` A We've talked about the efficiency of
`20
`the envelope tracker versus the efficiency of the
`21
`RF power amplifier. So I want to make sure -- each
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`Transcript of Arthur W. Kelley, Ph.D.
`Conducted on June 21, 2019
`29
`one of those two things has their own efficiency.
`And so I'm trying to make sure I'm talking about
`the right efficiency.
` Q And this is the design where the
`entire envelope tracker is operated on the Vboost
`voltage. Do you see that?
` A Right.
` Q And so what it's saying is that the
`efficiency of the envelope tracker is limited by
`the efficiency of the boost converter, right?
` A I think the efficiency of the boost
`converter, the fact that it's not 100 percent
`efficient, does result in some additional loss.
`The envelope tracker, which is downstream from
`that, of course has its own loss as well.
` Q And the reason that the efficiency is
`85 percent, in other words, it's gated by the boost
`converter, is because the envelope tracker is
`operated based on the Vboost voltage, right?
` A Well, any time the power is derived by
`the boost converter, that is an additional loss, an
`additional loss in the system. But when you talk
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`8 (29 to 32)
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`31
`converter -- you get another efficiency hit, if you
`will, from running off the boost converter.
` Q Right. And it's saying that because
`in this alternative design, the entire envelope
`tracker is operated based on the Vboost voltage
`from the boost converter, right?
` A It just says that if you're operating
`off the boost converter and you're running the
`boost converter, there's an additional loss there.
` Q But it does say that the entire
`envelope tracker is operated based on the Vboost
`voltage from the Vboost -- I'm sorry -- from the
`boost converter 180, right?
` A Well, when you're operating from the
`boost converter, the envelope tracker, the entire
`envelope tracker is operating off the boost
`converter. The envelope tracker is the amplifier
`that's downstream of the boost converter, the thing
`to which the boost converter is supplying power.
` Q Right. And I think we're on the same
`page. But this alternative design here, column 8,
`line 24, has the entire envelope tracker operated
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`
`about the efficiency, I want to make sure that
`based on the Vboost from the boost converter,
`we're -- again, there's the envelope tracker
`right?
` A Whenever the boost converter is in
`efficiency. There's the power amplifier
`operation, and it's supplying power to the
`efficiency. There's losses all down the line.
`envelope tracker, which is a different thing, then
` And so yes, if you choose to operate off the
`of course the boost converter, being the thing
`boost converter, there will be an additional loss
`that's supplying the power, is supplying power to
`in the boost converter. And if you would look at
`the envelope tracker.
`the boost converter all by itself, as it says here,
`it may be about 85 percent.
` Q But my question is, and this is really
`a yes or no question, do you agree that in this
` Q Right. And so if I operate using the
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`alternative design, line 24 column 8, the entire
`boost converter all the time, then my loss is
`11
`envelope tracker is operated based on the Vboost?
`greater than if I operate using the boost converter
`12
` A What I'm getting into is are you
`sometime and Vbattery some other times, right?
`13
`incorporating the boost converter into the envelope
` A If you were to operate exclusively
`14
`tracker in this question?
`from the boost converter, then you would incur
`15
`whatever loss the boost converter has while it's
` Q I'm saying that the boost converter is
`16
`operating.
`what is supplying the entire envelope tracker with
`17
`power, with the voltage?
` Q And that's what it's saying here in
`18
` A The envelope -- the boost converter --
`this column, in this another design column at line
`19
`let's just run down the screen here and get our
`24, right?
`20
`terms defined.
` A Well, it just simply says that if
`21
` The boost converter operates off the first
`you're operating off the boost converter, the boost
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`Transcript of Arthur W. Kelley, Ph.D.
`Conducted on June 21, 2019
`33
`supply voltage, which we generally understand to be
`a battery.
` Q I'm with you so far.
` A The boost converter has an output
`voltage that is higher than the first supply
`voltage of the battery.
` Q Which is called Vboost in the patent?
` A Which is called Vboost. That voltage
`is supplied to the envelope amplifier. We all
`agree on that. So the envelope amplifier, when
`it's operating off of Vboost, the boosted voltage,
`the amplifier has all its power supplied by the
`boost converter.
` Q And in this alternative design here,
`column 8, line 24, what it's saying is that the
`envelope tracker is operated based on the Vboost
`voltage, the entire envelope tracker, right?
` MR. SAUER: Objection; form.
` A Well, maybe -- what do you mean by the
`entire envelope tracker? What's inside that box?
` Q The entire envelope tracker?
` A Right.
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`entire envelope tracker is. So I guess that's
`where we're getting hung up is on this entire
`envelope tracker.
` Q So your position is that in the
`embodiment of column 8, line 24, it's the envelope
`amplifier that is operated on Vboost all the time;
`is that correct?
` MR. SAUER: Objection; form.
` A I don't -- I'm not sure that I can
`answer that question based on -- we don't have a
`definition of the entire envelope tracker. And so
`this is to that regard a little ambiguous in terms
`of whether the switcher is included in there or
`not. It might be. It might not. I don't know.
` Q So let me ask it this way then: If we
`focus on the envelope amplifier and set aside the
`switcher for a moment, you would agree that in the
`column 8, line 24 embodiment, at least the envelope
`amplifier is operated on the Vboost voltage all the
`time, correct?
` A I just think it's -- it says that the
`envelope amplifier is operated off the Vboost
`
`9 (33 to 36)
`
`35
`
`36
`
`voltage in this particular description.
` Q Okay. And you have no opinion about
`what the term the entire envelope tracker means at
`column 8, line 25; is that correct?
` A I haven't expressed an opinion on
`that. As far as I know, it's not a term that's
`been in dispute. So I don't know exactly what that
`would necessarily encompass on where do we draw
`that box.
` Q Turn back with me if you would to the
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`abstract on the front cover of the patent.
`11
` A Okay.
`12
` Q Do you see right five lines down
`13
`there's a statement that begins, "The envelope
`14
`amplifier"?
`15
` A Yes.
`16
` Q So the abstract of the '558 says, "The
`17
`envelope amplifier generates a second supply
`18
`voltage based on an envelope signal and the boosted
`19
`supply voltage, and also possibly the first supply
`20
`voltage." Do you see that there?
`21
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` Q It includes a linear amplifier and a
`switcher.
` A Okay. For example, the switcher, I
`don't think it's at issue. It always operates off
`the first supply voltage. And so it's never
`operated off the booster voltage.
` Q Okay. So when it says, "the entire
`envelope tracker," you think that that includes
`less than the switcher?
` A Well, again, based on the circuitries
`that are shown, certainly in the Figures 3 and 5.
` Q Okay.
` A My understanding -- certainly this is
`not illustrated anywhere. My understanding is the
`switcher is always operated off the first supply
`voltage. So I don't have an illustration of this.
`So I don't know whether you could include the
`switcher in this or not. I guess in some
`hypothetical you maybe could. But it's not -- it
`doesn't actually say that.
` Q Okay. So your position is that --
` A Well, it's -- it doesn't say what the
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`Transcript of Arthur W. Kelley, Ph.D.
`Conducted on June 21, 2019
`37
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`10 (37 to 40)
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`39
`
` Q So it's listing the first supply
`voltage as just a possibility, right?
` A I think the words speak for
`themselves.
` Q And what that means is that there is
`an embodiment of the '558 patent where the envelope
`amplifier generates the second supply voltage based
`on the envelope signal and the boosted supply
`voltage alone