1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Page 1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`Apple Inc.,
`
`Petitioner,
`
`v.
`
`Qualcomm Incorporated,
`
`Patent Owner.
`
`____________________
`
`Case IPR2018-1249
`
`U.S. Patent No. 7,693,002
`
`_____________________
`
`ORAL DEPOSITION OF ROBERT W. HORST, Ph.D.
`
`MARCH 20, 2019
`
`Reported by:
`
`Dana Welch, CSR, RPR, CRR
`
`Job 157424
`
`TSG Reporting - Worldwide 877-702-9580
`
`QUALCOMM EXHIBIT 2005
`Apple v. Qualcomm
`IPR2018-01249
`Page 1
`
`
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Page 1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`Apple Inc.,
`
`Petitioner,
`
`v.
`
`Qualcomm Incorporated,
`
`Patent Owner.
`
`____________________
`
`Case IPR2018-1249
`
`U.S. Patent No. 7,693,002
`
`_____________________
`
`ORAL DEPOSITION OF ROBERT W. HORST, Ph.D.
`
`MARCH 20, 2019
`
`Reported by:
`
`Dana Welch, CSR, RPR, CRR
`
`Job 157424
`
`TSG Reporting - Worldwide 877-702-9580
`
`QUALCOMM EXHIBIT 2005
`Apple v. Qualcomm
`IPR2018-01249
`Page 1
`
`
`
`Page 2
`
`March 20, 2019
`
`10:02 a.m.
`
`Deposition of ROBERT W. HORST, Ph.D., held
`
`at the offices of Fish & Richardson P.C., One
`
`Marina Park Drive, Boston, MA 02210-1878, before
`
`Dana Welch, Certified Shorthand Reporter,
`
`Registered Professional Reporter, Certified
`
`Realtime Reporter and Notary Public of the
`
`Commonwealth of Massachusetts.
`
`1 2 3 4 5
`
`6
`
`7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 2
`
`
`
`Page 3
`
`APPEARANCES:
`
`For the Petitioner:
`
`FISH & RICHARDSON
`
`BY: WHITNEY REICHEL, ESQ.
`
`KENNETH HOOVER, ESQ.
`
`One Marina Park Drive
`
`Boston, MA 02210
`
`For the Patent Owner:
`
`JONES DAY
`
`BY: DAVID COCHRAN, ESQ.
`
`North Point
`
`901 Lakeside Avenue
`
`Cleveland, OH 44114
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 3
`
`
`
`Page 4
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` P R O C E E D I N G S
`
` ROBERT W. HORST, Ph.D.,
`
` having been first duly sworn on oath,
`
`was examined and testified as follows:
`
` EXAMINATION
`
` BY MR. COCHRAN:
`
` Q. Good morning.
`
` A. Good morning.
`
` Q. Thanks for coming.
`
` Can you go ahead and state your name,
`
` please, full name.
`
` A. Robert Horst.
`
` Q. Robert Horst.
`
` And you have a Ph.D., correct?
`
` A. Yes.
`
` Q. I'll probably call you Dr. Horst during
`
` the course of the deposition. I hope that's okay.
`
` Or sir; I'm sure that's okay with you, too.
`
` A. Yes.
`
` Q. Can you tell us what your home address is,
`
` sir?
`
` A. 1182 Glenn Avenue in San Jose, California.
`
` Q. And you understand that you're under oath
`
` this morning, right?
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 4
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` A. Yes.
`
` Q. Is there any reason that you can't testify
`
`Page 5
`
` truthfully today?
`
` A. No.
`
` Q. Great.
`
` Dr. Horst, have you been deposed before?
`
` A. Yes.
`
` Q. How many times?
`
` A. Not sure exactly, but it's over a dozen
`
` times.
`
` Q. Over a dozen times.
`
` When was the last time you were deposed?
`
` A. The last time was in another IPR last
`
` year.
`
` Q. Do you remember what that matter was?
`
` A. I could look at my CV and give you the
`
` exact numbers. I can't remember the IPR number,
`
` but it was a computer networking IPR.
`
` Q. Were you testifying on behalf of Apple in
`
` that IPR?
`
` A. No.
`
` Q. Were you engaged by Fish & Richardson in
`
` that IPR?
`
` A. No.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 5
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` Q. Have you been engaged by Fish & Richardson
`
`Page 6
`
` previously?
`
` A. Yes, I have.
`
` Q. Approximately how many times have you been
`
` engaged by Fish & Richardson?
`
` A. About two other times.
`
` Q. And what did those matters relate to?
`
` A. They were other computer design type
`
` matters, IPRs.
`
` Q. So the deposition today is going to relate
`
` to your declaration in IPR2018-01249.
`
` Is that your understanding?
`
` A. Yes.
`
` Q. Great.
`
` So I'm handing the court reporter, she's
`
` now handing to you what has previously been marked
`
` as Apple 1003.
`
` I'm going to ask you whether you recognize
`
` this document, Dr. Horst?
`
` MS. REICHEL: Do you have a copy?
`
` MR. COCHRAN: Yes, I do.
`
` A. This is my declaration related to patent
`
` 7,693,002.
`
` Q. Could you turn to page 75 of Apple 1003,
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 6
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`HORST
`
`Page 7
`
` Dr. Horst. Is that your signature on page 75?
`
`A.
`
`Q.
`
`Yes, it is.
`
`Thank you.
`
`Did you write this document, Dr. Horst?
`
`A.
`
`Yes. I wrote this document in conjunction
`
` with counsel.
`
`Q.
`
`Can you explain the process you went
`
` through from the beginning of when you started
`
` writing the document until its final form?
`
`MS. REICHEL: I'll just caution the
`
` witness, the parties do have an agreement not to
`
` take discovery on the drafting process or the
`
` substance of communications with counsel.
`
`If you have any questions about what
`
` you're able to reveal and not reveal in response to
`
` counsel's question, please let me know. But you
`
` can go ahead and respond with that caveat.
`
`A.
`
`I don't know what I can reveal and not
`
` reveal about those conversations with counsel.
`
`Q.
`
`How long did it take you to create the
`
` document?
`
`A.
`
`I started on this case in early 2018, and
`
` so the document has been in process since then,
`
` including all the stages of finding and reviewing
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 7
`
`
`
`Page 8
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` prior art and doing figures and actually drafting
`
` the document.
`
` Q. Inside your declaration, there are several
`
` drawn figures that you created; is that right?
`
` A. Yes.
`
` Q. Approximately how much time have you spent
`
` on this matter, Dr. Horst?
`
` A. I haven't separately accounted for my time
`
` on this matter versus another IPR I'm working for,
`
` so I don't know what the split would be.
`
` Q. Can you approximate?
`
` A. It would be hard to break it down. I
`
` really wouldn't know.
`
` Q. 100 hours?
`
` MS. REICHEL: Objection, calls for
`
` speculation.
`
` A. I really don't know if it would be over or
`
` under 100 hours.
`
` Q. Are there any mistakes in your
`
` declaration?
`
` A. There's nothing that I have found at this
`
` point that would be a mistake, but it's possible
`
` that I've overlooked something.
`
` Q. Are there any opinions set forth in the
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 8
`
`
`
`Page 9
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` declaration that you'd like to change?
`
` A. No. There are no opinions that I would
`
` change at this time.
`
` MR. COCHRAN: By the way, I'm not throwing
`
` those at you. It's the only way I can get it to
`
` you.
`
` MS. REICHEL: The numbers on the bottom of
`
` these, may I just ask were those on the original
`
` documents or were they appended in preparation for
`
` the deposition to be exhibit numbers or what was
`
` the source of those?
`
` MR. COCHRAN: That's a good question. I
`
` believe those were put on there by Fish &
`
` Richardson when the IPRs were filed.
`
` MS. REICHEL: And you're not planning to
`
` use a different exhibit number consistent --
`
` MR. COCHRAN: I'm not. I'm going to use
`
` your numbers.
`
` Q. So the court reporter has handed you a
`
` document that is marked Apple 1004.
`
` Do you recognize this document, Dr. Horst?
`
` A. Yes. This is a version of my CV that was
`
` submitted along with my declaration.
`
` Q. Is this a current copy of your CV?
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 9
`
`
`
`Page 10
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` A. I currently have a more up-to-date version
`
` of the CV that has a few more items.
`
` Q. Can you take a look at pages 3, 4, 5 of
`
` the CV, Dr. Horst. This appears to include a list
`
` of patents which list you as an inventor; is that
`
` correct?
`
` A. That's correct.
`
` Q. Is this list current?
`
` A. No. There are currently four more patents
`
` that have issued since I produced this document.
`
` Q. Do any of these patents relate to the
`
` subject matter of the '002 patent?
`
` MS. REICHEL: Objection to form.
`
` A. There are several of these patents that
`
` relate to memory design and circuit design, and
`
` I've called those out in my expert report.
`
` Q. Can you take a look at page 6 of the CV.
`
` This appears to be a list of publications that name
`
` you as an author, starting on page 6, going through
`
` page 8.
`
` Do you see that?
`
` A. Yes.
`
` Q. And is this list current?
`
` A. Yes. This list is current. I have no new
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 10
`
`
`
`Page 11
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` publications since this version of the CV.
`
` Q. Thank you, sir.
`
` The court reporter has now handed you a
`
` document that's been marked Apple 1001.
`
` Do you recognize this document, Dr. Horst?
`
` A. Yes. This is the Lin patent, the
`
` 7,693,002 patent which is the subject of this IPR.
`
` Q. So for purposes of the deposition today,
`
` I'm going to generally refer to this as the '002
`
` patent.
`
` Is that okay with you?
`
` A. Yes.
`
` Q. That's how we refer to these.
`
` In connection with the preparation of your
`
` declaration which we've previously marked as Apple
`
` 1003, did you review the '002 patent?
`
` A. Yes, I did.
`
` Q. How many times have you read it?
`
` A. I haven't counted them up, but I've read
`
` it many times.
`
` Q. Did you review the entire document?
`
` A. Yes. I reviewed the entire document.
`
` Q. Approximately how long would you say
`
` you've spent studying the '002 patent, Dr. Horst?
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 11
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`HORST
`
`Page 12
`
`A.
`
`I can't really estimate that. I've always
`
` done it in conjunction with reviewing other
`
` materials.
`
`Q.
`
`Can you turn to Figure 1 of Apple 1001.
`
`Figure 1 is a block diagram of a wordline
`
` driver system labeled 100, correct?
`
`A.
`
`Q.
`
`Yes.
`
`And in Figure 1, there is a 6-bit memory
`
` address specifying one of 64 wordlines in a memory
`
` array; is that right?
`
`A.
`
`The 6-bit address will select one of 64
`
` wordlines of the array.
`
`Q.
`
`And Figure 1 includes a 2 to 4-bit decoder
`
` marked 112, and a 4 to 16-bit address decoder
`
` marked 108; is that correct?
`
`A.
`
`Q.
`
`That's correct.
`
`What is the function of the 2 to 4-bit
`
` memory address decoder that's labeled 112?
`
`A.
`
`The 2 to 4 decoder is part of the
`
` conditional clock generator that's used to select
`
` one of the clocks to apply to the wordline circuit.
`
`Q.
`
`In Figure 1, the first portion of the
`
` memory address includes bits 0 and 1; is that
`
` correct?
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 12
`
`
`
`Page 13
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` A. By first logic, are you referring to the
`
` claims, the way it uses first logic?
`
` Q. I don't think I said first logic.
`
` I said in Figure 1, the first portion of
`
` the memory address is bits 0 and 1; is that
`
` correct?
`
` A. Two bits of the address are bits 0 and 1;
`
` whether you call that first or last depends on the
`
` way the address is specified.
`
` Q. And the 2 to 4-bit decoder that's labeled
`
` 112 decodes those two address bits and provides a
`
` decoded portion to the conditional clock generator
`
` that's labeled 110; is that correct?
`
` A. The decoded outputs are used by the
`
` conditional clock generator.
`
` Q. What is the function of the conditional
`
` clock generator that's labeled 110 in Figure 1?
`
` A. The conditional clock generator is used to
`
` select one wordline out of a group of wordlines,
`
` and the group has been selected by the other bits
`
` of the address through the 4 to 16 decoder.
`
` Q. And how does it do that?
`
` A. I don't understand the question.
`
` Q. How does it function to do that?
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 13
`
`
`
`Page 14
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` A. I'm still not sure what you mean by "do
`
` that."
`
` Q. Well, what is the structure of the
`
` conditional clock generator that enables it to
`
` select a wordline?
`
` A. Figure 3 shows more details about that
`
` structure.
`
` Q. What are the outputs of the conditional
`
` clock generator that's labeled 110 in Figure 1?
`
` A. Those outputs are labeled in Figure 3 as
`
` clocks 0, 1, 2, and 3.
`
` Q. Are those clock signals?
`
` A. Yes. Those are clock signals, each for a
`
` different bitline.
`
` Q. And what is the relationship between the
`
` clock signals that are output from the conditional
`
` clock generator and the clock input labeled 118 in
`
` Figure 1?
`
` A. The clock input 118 is conditionally
`
` passed to one of those clock outputs while the
`
` other ones are held low.
`
` Q. The circuit shown in Figure 1 includes
`
` groups of wordline drivers that are labeled 104 and
`
` 106; is that correct?
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 14
`
`
`
`Page 15
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` A. That's correct. Not shown are the other
`
` wordline drivers. It only shows the first and last
`
` group of wordline drivers.
`
` Q. And each of the clock outputs labeled 124,
`
` 126, 128, and 130 is coupled to each of the groups
`
` of wordline drivers labeled 104 and 106; is that
`
` correct?
`
` A. Those clock lines at 124, 126, 128, and
`
` 130 are each coupled to all of the groups of
`
` wordline drivers.
`
` Q. And by "all of the wordline drivers,"
`
` you're referring to the blocks labeled 104 and 106;
`
` is that correct?
`
` MS. REICHEL: Objection to form, misstates
`
` his testimony.
`
` A. I said "all of the groups." They're
`
` coupled to all of the groups 104 through 106.
`
` Q. What is the function of the 4 to 16
`
` decoder labeled 108 in Figure 1?
`
` A. The 4 to 16 decoder selects one of those
`
` 16 groups to be active.
`
` Q. And in Figure 1, there are four address
`
` bits labeled address 5:2 that are input to the 4 to
`
` 16 decoder; is that correct?
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 15
`
`
`
`Page 16
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` A. Yes. Address bits 5 through 2 go to that
`
` 4 to 16 decoder.
`
` Q. So in Figure 1, there are two address bits
`
` that are supplied to the 2 to 4 decoder labeled
`
` 112, and there are four address bits supplied to
`
` the 4 to 16 decoder labeled 108; is that correct?
`
` A. Yes. Those six address bits are shown at
`
` the bottom of Figure 1.
`
` Q. So in Figure 1, the address bits are
`
` decoded separately by the decoder 112 and the
`
` decoder 108, correct?
`
` A. This shows separate decoders doing those
`
` decoding functions.
`
` Q. Can you turn to page 11 of the '002 patent
`
` that's marked as page 11, column 9 and 10 of the
`
` patent.
`
` Do you see that, sir?
`
` A. Yes. I'm there.
`
` Q. Down in the bottom right-hand corner of
`
` page 11 is the beginning of claim 1.
`
` Do you see that?
`
` A. Yes.
`
` Q. And do you also see that claim 1 extends
`
` onto page 12 in the upper left-hand portion.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 16
`
`
`
`Page 17
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` Do you see that?
`
` A. Yes.
`
` Q. Claim 1 of the '002 patent recites first
`
` logic and second logic, correct?
`
` A. Correct.
`
` Q. And according to claim 1, the first logic
`
` receives a clock signal and a first portion of a
`
` memory address of a memory array; is that correct?
`
` A. That's part of what it says.
`
` Q. What is the first logic as claimed in
`
` claim 1 that's shown in Figure 1 of the '002
`
` patent?
`
` MS. REICHEL: Objection to form.
`
` A. In Figure 1, the first logic includes the
`
` 2 to 4 decoder and the conditional clock generator.
`
` Q. And if you look further in claim 1 at the
`
` top left portion of page 12, claim 1 recites
`
` "second logic to decode a second portion of the
`
` memory address," correct?
`
` A. That's part of what it says.
`
` Q. And what is the second logic as claimed in
`
` claim 1, shown in Figure 1 of the '002 patent?
`
` MS. REICHEL: Objection to form.
`
` A. The second logic includes that the 4 to 16
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 17
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`HORST
`
`Page 18
`
` decoder, based on selecting from address bits 5
`
` through 2.
`
`Q.
`
`Anything else?
`
`MS. REICHEL: Objection to form.
`
`A.
`
`The output of decoder 4 -- the 4 to 16
`
` decoder is shown further in Figure 3, and there's
`
` an inverter 302 that's logically part of that
`
` selection.
`
`Q.
`
`The inverter 302 that's shown in Figure 3
`
` is part of the second logic that's claimed in claim
`
` 1; is that correct?
`
`MS. REICHEL: Objection to form.
`
`A.
`
`The second logic acts to selectively
`
` activate a particular wordline driver. So the path
`
` from that second logic to the activation includes
`
` that inverter. So I would include that inverter as
`
` part of that second logic.
`
`Q.
`
`Okay. Back to Figure 1 for a moment,
`
` Dr. Horst.
`
`The 4 to 16 decoder labeled 108 in
`
` Figure 1 does not receive the clock signal 118,
`
` correct?
`
`MS. REICHEL: Objection to form.
`
`A.
`
`This diagram does not show a clock signal
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 18
`
`
`
`Page 19
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` going to that decoder.
`
` Q. Is there any part of the '002 patent that
`
` would indicate that the clock signal 118 is
`
` provided to the 4 to 16 decoder labeled 108 in
`
` Figure 1?
`
` A. No. In these figures, there's no clock
`
` signal that's going to that decoder.
`
` Q. Why is that?
`
` MS. REICHEL: Objection to form,
`
` foundation.
`
` A. I don't -- there are many ways to
`
` implement a decoder. Decoders can have clocks and
`
` they can be designed without clocks. The designers
`
` of the -- and inventors of the '002 evidently
`
` decided to illustrate this with a non-clock
`
` decoder.
`
` Q. In decoding the address bits that are
`
` labeled 5:2 in Figure 1, the 4 to 16-bit decoder
`
` labeled 108 does not use the clock signal labeled
`
` 118, correct?
`
` A. In the embodiment shown in Figure 1, they
`
` do not show a clock decoder.
`
` Q. The 4 to 16-bit decoder labeled 108 shown
`
` in Figure 1 of the '002 patent operates
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 19
`
`
`
`Page 20
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` independently of the clock signal labeled 118,
`
` correct?
`
` A. The embodiment shown here does not use a
`
` clock and is independent of the clock signal.
`
` Q. I want to turn back to claim 1 for a
`
` minute, which is pages 11 and 12.
`
` In claim 1, the first logic receives a
`
` clock signal, correct?
`
` A. The first line of claim 1 says "the first
`
` logic" -- "a first logic to receive a clock
`
` signal."
`
` Q. Claim 1 does not recite that the second
`
` logic receives the clock signal, correct?
`
` A. The portion of the claim talking about the
`
` second logic is silent about whether the clock
`
` signal goes to the second logic or not.
`
` Q. So in claim 1, the second logic does not
`
` receive the clock signal, correct?
`
` MS. REICHEL: Objection to form,
`
` mischaracterizes his testimony.
`
` A. Claim 1 is not restricted to second logic
`
` that uses the clock signal, but it could include
`
` second logic that does include the clock signal.
`
` Q. Does claim 1 recite that the second logic
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 20
`
`
`
`Page 21
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` receives the clock signal?
`
` A. It does not say that it receives a clock
`
` signal, but there's no prohibition of a clock
`
` signal going there. So a system that has a clock
`
` signal still would have all the elements of the
`
` second logic of claim 1.
`
` Q. I'm just asking whether the claim recites
`
` the second logic receives the clock signal. Does
`
` it or not?
`
` MS. REICHEL: Objection to form.
`
` A. The second logic does not require a clock
`
` signal.
`
` Q. Claim 1 also recites that the first logic
`
` is to apply the clock signal to a selected clock
`
` output, correct?
`
` A. It actually states that "and to apply the
`
` clock signal to a selected clock output of a
`
` plurality of clock signals associated with a
`
` selected group of a plurality of wordline drivers
`
` that are associated with the memory array."
`
` Q. Fair enough.
`
` Claim 1 of the '002 patent also recites
`
` that the second logic is to decode a second portion
`
` of the memory address, correct?
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 21
`
`
`
`Page 22
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` A. That's part of what the claim says. It
`
` says, "the second logic to decode a second portion
`
` of the memory address, the second logic to
`
` selectively activate a particular wordline driver
`
` of the selected group of wordline drivers according
`
` to the second portion of the memory address."
`
` Q. And claim 1 does not recite that the
`
` second logic uses the clock signal, correct?
`
` MS. REICHEL: Objection to form.
`
` A. As I previously answered, it -- the second
`
` logic does not require a clock signal, but it
`
` doesn't preclude a clock signal.
`
` Q. Could you take a look at -- still in the
`
` '002 patent, Dr. Horst, column 1, which is on
`
` page 7, column 1, lines 64 to 66.
`
` You there?
`
` A. Yes, I'm there.
`
` Q. Here at column 1, lines 64 to 66 of the
`
` '002 patent, it states that "One particular
`
` advantage of a particular illustrative embodiment
`
` of the circuit is that a timing delay from a clock
`
` to a particular wordline is reduced," correct?
`
` A. That's what it says.
`
` Q. Do you understand what that means?
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 22
`
`
`
`Page 23
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` A. It's talking about an advantage in
`
` reducing the number of loads on a single clock
`
` line.
`
` Q. Why is that relevant?
`
` A. The performance of a memory system
`
` partially depends on how fast the wordline drivers
`
` can be driven, and if there's excessive loading on
`
` a clock, the rise time of the clock is slow and it
`
` affects the performance.
`
` Q. One of the stated advantages of the '002
`
` patent is to reduce timing delay from a clock to a
`
` particular wordline, correct?
`
` MS. REICHEL: Objection to form,
`
` mischaracterizes the document.
`
` A. The statement we just read says, "One
`
` particular advantage of a particular illustrative
`
` embodiment of the circuit is that a timing delay
`
` from a clock to a particular wordline is reduced."
`
` So there is one embodiment, at least,
`
` which has reduced clock loading.
`
` Q. Would you agree that that's an advantage
`
` of the invention described in the '002 patent,
`
` Dr. Horst?
`
` MS. REICHEL: Objection to form.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 23
`
`
`
`Page 24
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` A. That is an advantage of any system that
`
` reduces the number of clock loads, and including
`
` the '002 patent and the prior art that I cited.
`
` Q. Thank you, sir.
`
` Can you move to column 1, starting line 66
`
` and going over to column 2, line 2. And here the
`
` '002 patent states that "Still another particular
`
` advantage of a particular illustrative embodiment
`
` of the circuit device is that the clock driver's
`
` capacitance loading may also be reduced."
`
` Do you see that?
`
` A. Yes, I see that.
`
` Q. Do you understand what that means?
`
` A. Yes.
`
` Q. Can you explain to me what that means?
`
` A. The number of places a clock drives on a
`
` chip increases the capacitance because the gate of
`
` the MOSFETs all have high capacitance, and so the
`
` more places it drives, the more capacitance there
`
` is and the more loading is on that signal.
`
` Q. Would you agree that that is an advantage
`
` of the invention described in the '002 patent?
`
` MS. REICHEL: Objection to form.
`
` A. Again, that's an advantage in the '002
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 24
`
`
`
`Page 25
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` patent and the prior art that have fewer loads per
`
` clock.
`
` Q. Can you turn to column 2, lines 2 to 5 of
`
` the '002 patent. And here the '002 patent states
`
` that "Another particular advantage of a particular
`
` illustrative embodiment is that use of multiple
`
` conditional clocks to selectively apply a clock
`
` signal reduces power consumption."
`
` Do you see that, sir?
`
` A. Yes.
`
` Q. And do you understand what that means?
`
` A. Yes.
`
` When there are fewer loads on the clock
`
` that's switching, power consumption is reduced
`
` because the power consumption largely depends on
`
` the frequency and the capacitance of the signals
`
` that are changing.
`
` Q. And finally, sir, can you turn to column
`
` 3, lines 13 -- which is on page 8 of the document,
`
` lines 13 to 16.
`
` And here the '002 patent states that
`
` "Still another particular advantage of a particular
`
` illustrative embodiment may be realized by sharing
`
` a common address signal among multiple wordline
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 25
`
`
`
`Page 26
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` decoders, which reduces power consumption and
`
` conserves layout area."
`
` Do you see that, sir?
`
` A. Yes.
`
` Q. And do you understand what that means?
`
` A. Can you read that section again that
`
` you're referring to?
`
` Q. Column 3, lines 13 to 16.
`
` MS. REICHEL: I'm also having trouble
`
` finding the text you just read at that citation.
`
` MR. COCHRAN: Well, that's because I
`
` pointed you to the wrong spot. I meant to say
`
` column 2, lines 13 to 16. I apologize for that.
`
` Q. Have you had a chance to read that,
`
` Dr. Horst?
`
` A. Yes.
`
` Q. Can you explain to me what that means?
`
` A. They are saying that there's an advantage
`
` to having only a single common address signal,
`
` which is the line that they use to select the
`
` group. By having multiple bits per group, there's
`
` fewer of those signal lines, and so if there's
`
` fewer lines, that would reduce power consumption
`
` and conserve layout area.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 26
`
`
`
`Page 27
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` Q. The court reporter handed you a document
`
` that is labeled Apple 1005.
`
` Do you recognize this?
`
` A. Yes. This is U.S. Patent 4,951,259, with
`
` the first author's name Sato, and I generally refer
`
` to this as the Sato patent.
`
` Q. That's what I'll call it too.
`
` How many times would you say you've read
`
` the Sato reference, Dr. Horst?
`
` A. I've read this many times, I couldn't
`
` estimate how many.
`
` Q. But you're very familiar with the subject
`
` matter of the Sato patent, correct?
`
` A. That's correct.
`
` Q. Can you turn to Figure 3 of Sato, the Sato
`
` patent. Figure 3 of the Sato patent depicts a
`
` circuit diagram showing an X address decoder of a
`
` static RAM, correct?
`
` A. Figure 3 of Sato is showing a wordline
`
` driver circuit. It's not necessarily restricted to
`
` a static RAM.
`
` Q. Can you turn to column 2, lines 57 to 59
`
` of the Sato reference that's on page 6. And do you
`
` see there, Dr. Horst, where the Sato patent says --
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 27
`
`
`
`Page 28
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` states, "Figure 3 a circuit diagram showing the X
`
` address decoder of the static RAM in accordance
`
` with the third embodiment of the present
`
` invention," correct?
`
` A. It states, "Figure 2 is a circuit diagram
`
` showing the X address decoder of the static RAM in
`
` accordance with the second embodiment of the
`
` present invention."
`
` Q. And I'm sorry, I was talking about lines
`
` 57 to 59 state, "Figure 3, a circuit diagram
`
` showing the X address decoder of the static RAM in
`
` accordance with the third embodiment of the present
`
` invention," correct?
`
` A. That's correct, that's what it states.
`
` Q. Now, can you turn to -- I'm going to have
`
` you look at a couple of things simultaneously,
`
` Dr. Horst. Just two for now, so hopefully it will
`
` work out.
`
` Can you turn to paragraph 59 of your
`
` declaration, which was marked Apple 1003.
`
` A. Yes, I'm there.
`
` Q. In paragraph 59 of your declaration, you
`
` state, "Annotated Figure 3 (below) of Sato shows
`
` Sato's X address decoder including structures
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 28
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`HORST
`
`Page 29
`
` meeting the limitations of the first and second
`
` logic of the '002 patent," correct?
`
`A.
`
`Q.
`
`That's correct, that's what it states.
`
`What portion of Figure 3 of Sato do you
`
` contend meets the first logic limitation of the
`
` '002 patent?
`
`A.
`
`In my report, I have highlighted that in
`
` the annotated figure of Figure 3 on page 25, which
`
` shows that the first logic is the pre-decoder that
`
` receives the clock signal and generates the
`
` conditional clock outputs.
`
`Q.
`
`Can you turn to paragraph 60 of your
`
` declaration.
`
`In paragraph 60, you state, "The
`
` pre-decoder PDCR meets the limitation for the first
`
` logic because it receives both a timing (clock)
`
` signal and a portion of the memory address,"
`
` correct?
`
`A.
`
`Q.
`
`Yes, that's what it states.
`
`What is the timing signal that is received
`
` by the pre-decoder PDCR in Figure 3 of Sato?
`
`A.
`
`That's the symbol labeled Phi subscript
`
` ce. It's the Greek symbol Phi.
`
`Q.
`
`And what is the portion of the memory
`
`TSG Reporting - Worldwide 877-702-9580
`
`Page 29
`
`
`
`Page 30
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` HORST
`
` address received by the pre-decoder PDCR in
`
` Figure 3 of Sato?
`
` A. The address received is the true and
`
` complemented bits of two bits of the address
`
` labeled ax0 and ax1.
`
` Q. The Sato patent does not provide a figure
`
` showing the circuitry of the PDCR block shown in
`
` Figure 3, correct?
`
` A. Sato does not show a figure for that, but
`
` it describes in words in sufficient detail that I
`
` was able to draw a diagram of what is in that
`
` block.
`
` Q. The Sato patent does not include a figure
`
` showing the circuitry in the PDCR block, correct?
`
` A. It describes it in words instead of in a
`
` picture.
`
` Q. Sato refers to the four outputs Phi x0
`
` through Phi x3 as "selection signals," correct?
`
` A. I'd have to read through all of Sato to
`
` know the different ways it might refer to those
`
` signals.
`
` Q. Why don't you turn to column 1, line 51 of
`
` Sato.
`
` At column 1, line 51, what does Sato re
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
