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`HORST - IPR2018-01249
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`---o0o---
`
`APPLE INC.,
`Petitioner,
`
`Case IPR2018-01249
`vs.
`QUALCOMM INCORPORATED, U.S. Patent No. 7,693,002
`Patent Owner.
`
`______________________________
`
`CONFIDENTIAL
`DEPOSITION OF ROBERT W. HORST, PH.D.
`VOLULME II
`BELLEVUE, WASHINGTON
`THURSDAY, AUGUST 8, 2019
`
`Reported by:
`DARCY J. BROKAW, RPR, CRR, CCR No. 3455
`JOB NO. 165495
`
`TSG Reporting - Worldwide 877-702-9580
`
`QUALCOMM EXHIBIT 2006
`Apple v. Qualcomm
`IPR2018-01249
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`HORST - IPR2018-01249
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`---o0o---
`
`APPLE INC.,
`Petitioner,
`
`Case IPR2018-01249
`vs.
`QUALCOMM INCORPORATED, U.S. Patent No. 7,693,002
`Patent Owner.
`
`______________________________
`
`CONFIDENTIAL
`DEPOSITION OF ROBERT W. HORST, PH.D.
`VOLULME II
`BELLEVUE, WASHINGTON
`THURSDAY, AUGUST 8, 2019
`
`Reported by:
`DARCY J. BROKAW, RPR, CRR, CCR No. 3455
`JOB NO. 165495
`
`TSG Reporting - Worldwide 877-702-9580
`
`QUALCOMM EXHIBIT 2006
`Apple v. Qualcomm
`IPR2018-01249
`
`
`
`Confidential
`
`HORST - IPR2018-01249
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`Page 63
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`AUGUST 8, 2019
`8:57 A.M.
`
` Deposition of ROBERT W. HORST, PH.D., Volume II, held
`at The Westin Bellevue, 600 Bellevue Way NE, Bellevue,
`Washington, before Darcy J. Brokaw, a Registered
`Professional Reporter, Certified Realtime Reporter,
`Washington Certified Court Reporter.
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`APPEARANCE OF COUNSEL:
`
` JONES DAY
` Attorneys for the Patent Owner:
` 901 Lakeside Avenue
` Cleveland, Ohio 44114
` BY: DAVID COCHRAN, ESQ.
`
` FISH & RICHARDSON
` Attorneys for the Petitioner:
` One Marina Park Drive
` Boston, Massachusetts 02210
` BY: WHITNEY REICHEL, ESQ.
` KENNETH HOOVER, ESQ.
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` HORST - IPR2018-01249
` ROBERT W. HORST, PH.D.,
` called as a witness, having been duly sworn,
` was examined and testified as follows:
` ---o0o---
`
` EXAMINATION
`BY MR. COCHRAN:
` Q. Good morning.
` A. Good morning.
` Q. Dr. Horst, you've seen you're under oath
`today?
` A. Yes.
` Q. Is there any reason you cannot testify
`truthfully today?
` A. No.
` Q. Great.
` This first deposition that we're going to
`do today relates to your Supplemental Declaration
`testimony in IPR2018-01249. It relates to the '002
`patent.
` Is that your understanding?
` A. Yes.
` Q. Great.
` MR. COCHRAN: I'll hand the witness what
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`has previously been marked as Exhibit 1013.
` (Deposition Exhibit 1013 marked for
` identification.)
`BY MR. COCHRAN:
` Q. Do you recognize this document, Dr. Horst?
` A. Yes. This is the Declaration for the '002
`that I submitted on July 13th.
` Q. Can you take a look at page 22 of
`Exhibit 1013 and tell me if that is your signature
`on page 22.
` A. Yes.
` Q. Are there any errors that you're aware of
`in this document, Exhibit 1013, Dr. Horst?
` A. There's nothing that I know of, but there
`could be some small typos and other things.
` Q. Are there any opinions set forth in this
`document, Exhibit 1013, that you would like to
`change before we get started?
` A. No. No, my opinions have not changed.
` Q. Okay. Can you turn to page 3 of
`Exhibit 1013.
` Are you at page 3?
` A. Yes.
` Q. Sorry, page 2.
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` In paragraph 3 -- I'm going to draw your
`attention to paragraph 3 on page 2, Dr. Horst, where
`you state:
` "A POSITA would not have
` considered a periodic clock signal to
` be the broadest reasonable
` interpretation (BRI) of 'clock signal'
` as used in the claims of the '002
` patent."
` Do you see that statement, sir?
` A. Yes.
` Q. Is this still your opinion, Dr. Horst?
` A. Yes, it is.
` Q. Can you turn to page 5. And I'm going to
`direct your attention to paragraph 7.
` In paragraph 7, you state:
` "Dr. Pedram states that his
` definition is the broadest reasonable
` interpretation based on the definition
` of 'clock signal' from an IEEE
` dictionary."
` Do you see that, sir?
` A. Yes.
` Q. And then in paragraph 8, just below that,
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` HORST - IPR2018-01249
`you say:
` "Also, Dr. Pedram's declaration
` omits alternate definitions for
` 'clock' in the same IEEE dictionary."
` Do you see that?
` A. Yes.
` MR. COCHRAN: I'm handing the witness what
`has previously been marked as Exhibit 1014.
` (Deposition Exhibit No. 1014 marked for
` identification.)
`BY MR. COCHRAN:
` Q. Would you please turn to page 5,
`Dr. Horst.
` A. Okay.
` Q. And on page 5 of Exhibit 1014, this is an
`excerpt from the IEEE dictionary, correct?
` A. This is an excerpt from one edition of the
`IEEE. I believe it's the one that I quoted. I
`haven't checked.
` Q. On the left-hand column, you'll see
`there's a term "clock signal" on page 5.
` Do you see that?
` A. Yes.
` Q. The IEEE dictionary includes one
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`definition for the term "clock signal," correct?
` MS. REICHEL: Objection to form.
` THE WITNESS: In this version, it includes
`the one definition, but this doesn't appear to be
`the same one that I reviewed for my report, because
`it has something after the reference for -- or after
`the definition of "clock signal." And it says there
`are synonyms for clock signal.
`BY MR. COCHRAN:
` Q. Does this not appear to be the version of
`the IEEE dictionary that you used in your creating
`of your Supplemental Declaration, Dr. Horst?
` A. On page 5 of my report, in paragraph 7,
`after the part you quoted, my report says:
` "The portion of the IEEE
` dictionary cited in Dr. Pedram's
` declaration defines 'clock signal' as
` '[a] periodic signal used for
` synchronizing events,' but this
` partial quotation omits the part of
` the definition that says part of the
` definition that says 'Synonyms: clock
` pulse; timing pulse."
` The version that I reviewed had this part
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` HORST - IPR2018-01249
`of the definition, but it appears to be different
`than the one you handed me.
` Q. In Exhibit 1014, the definition of "clock
`signal" includes one definition, correct?
` MS. REICHEL: Objection to form. The
`document speaks for itself.
` THE WITNESS: As I just said, the
`definition on the one you handed me is slightly
`different than the one that I quoted in my report.
`BY MR. COCHRAN:
` Q. You mentioned that the definition of
`"clock signal" in Exhibit 1014 includes two
`synonyms, correct?
` A. Yes.
` Q. One of those is "clock pulse," correct?
` A. Yes.
` Q. And the other is "timing pulse," correct?
` A. Yes.
` Q. If you look at Exhibit 1014, a few
`references above, entries above "clock signal,"
`you'll see the IEEE definition of "clock pulse."
` Do you see that?
` A. Yes.
` Q. And what is the definition of "clock
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`pulse"? What's the synonym?
` A. Here, it says: "'Clock pulse' See: clock
`signal."
` Q. So you'd agree that, according to the IEEE
`dictionary, "clock pulse" has the same definition as
`"clock signal," correct?
` MS. REICHEL: Objection. Form.
` THE WITNESS: It says "See: clock signal."
`So it says that they are related. It doesn't
`explicitly say that they are identical.
`BY MR. COCHRAN:
` Q. Could you take a look back at page 4 of
`your -- sorry. Take a look at page 4 of the
`Exhibit 1014, the dictionary.
` A. Yes.
` Q. And as you noted in your Supplemental
`Declaration, the IEEE dictionary has multiple
`definitions for the term "clock," correct?
` A. Correct.
` Q. In fact, if you count the subparts, there
`are at least -- I count seven different definitions
`set forth in the IEEE dictionary for the term
`"clock," correct?
` A. Depending on how you count them, there are
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`several different major definitions and then
`subdefinitions within those.
` Q. Doesn't the fact that there are multiple
`definitions for the term "clock" in the IEEE
`dictionary but only one definition for the term
`"clock signal" tell you that the term "clock" is a
`broader term than the term "clock signal"?
` MS. REICHEL: Objection to form.
` THE WITNESS: The term "clock," when it's
`being used to describe a signal on a printed circuit
`board, is the same as calling it a clock signal.
` So I see "clock signal" as a way of
`identifying that you're talking about a signal as
`opposed to, say, an oscillator or a real-time clock.
` There's other uses for the term "clock"
`which have nothing to do with signals.
`BY MR. COCHRAN:
` Q. Okay. So "clock" is a broader term than
`"clock signal," according to the IEEE dictionary,
`correct?
` MS. REICHEL: Objection to form.
` THE WITNESS: There can be some other uses
`of the term "clock" which are not applicable to
`signals on printed circuit boards. So when used in
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` HORST - IPR2018-01249
`those contexts, it's a different set of definitions.
`BY MR. COCHRAN:
` Q. But the reason the IEEE dictionary has
`multiple definitions of the term "clock" but only
`one definition of the term "clock signal" is because
`"clock" is a broader term than "clock signal"; isn't
`that right?
` MS. REICHEL: Objection to form.
` THE WITNESS: When clock is used in the
`context of a signal on a printed circuit board, I
`can call it, this is the clock, or I can say, this
`is the clock signal; and in that usage, "clock" is
`no less or more broad than "clock signal".
`BY MR. COCHRAN:
` Q. Just in terms of the Exhibit 1014, just
`focusing on 1014, the reason that the dictionary has
`multiple definitions of "clock" is because it's a
`broader term than "clock signal," correct?
` MS. REICHEL: Objection to form.
`Foundation.
` THE WITNESS: I wouldn't use the term
`"broader". I would say it's used for different
`types of clocks. So it's -- it doesn't mean that
`one is broader than the other.
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`BY MR. COCHRAN:
` Q. Well, why does the IEEE dictionary have
`multiple definitions of the term "clock" but only
`one definition of the term "clock signal"?
` MS. REICHEL: Objection to form.
`Foundation.
` THE WITNESS: Because "clock" sometimes
`refers to things other than signals; and when it's
`being -- referring to other things, it needs
`different definitions. But when it's referring to
`signals, they have -- one is not broader than the
`other.
`BY MR. COCHRAN:
` Q. Could you take a look at Exhibit 1014,
`definition (2) under "clock."
` Do you see that?
` A. Yes.
` Q. Definition (2) says:
` "A signal, the transitions of
` which (between the low and high logic
` level [or vice versa] are used to
` indicate when a stored-state device,
` such as a flip-flop or latch, may
` perform an operation."
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` Is that right?
` A. Yes.
` Q. And then after the definition (2) of
`"clock," the dictionary identifies the relevant
`categories as "(C/TT)".
` Do you see that?
` A. Yes.
` Q. Do you know what that means?
` A. I'm not sure what that means.
` Q. Could you take a look at definition (1)(A)
`on page 4.
` Do you see that?
` A. Yes.
` Q. Definition (1)(A) says:
` "A device that generates periodic
` signals used for synchronization."
` Do you see that?
` A. Yes.
` Q. Is that the same definition as the
`definition of "clock signal"?
` A. The definition here is not identical to
`the one that the IEEE definition gives for "clock
`signal." It has some differences.
` Q. Is it mostly the same?
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` MS. REICHEL: Objection to form.
` THE WITNESS: I don't know what you mean
`by "mostly."
`BY MR. COCHRAN:
` Q. Well, what's the difference?
` A. The words in the definitions are those
`words. You can read them and go word by word if you
`want to point out the differences.
` Q. Do you think definition (1)(A) is saying
`that a clock is a device that generates a clock
`signal?
` A. (1)(A) says:
` "A device that generates periodic
` signals used for synchronization."
` And I would understand that to be clock
`signals that it's describing.
` Q. Can you turn back to your Declaration,
`Supplemental Declaration, Exhibit 1013, page 6,
`please. Paragraph 10, in particular. Why don't you
`take a look at that, please.
` In paragraph 10 of your Supplemental
`Declaration, you refer to a definition for the term
`"clock" from the Modern Dictionary of Electronics,
`correct?
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` A. Yes.
` MR. COCHRAN: I'm going to hand the
`witness what has been previously marked as
`Exhibit 1015.
` (Deposition Exhibit No. 1015 marked for
` identification.)
`BY MR. COCHRAN:
` Q. Do you recognize this document, Dr. Horst?
` A. Yes. This is the reference that I'm
`referring to in paragraph 10.
` Q. Do you know who publishes this dictionary?
` A. On the second page, it says "Newnes,"
`N-e-w-n-e-s, is the publisher, a member of the Reed
`Elsevier Group.
` Q. Is that a standard-setting organization?
` A. As far as I know, I do not know whether or
`not Newnes is involved in standard setting or not.
` Q. Can you turn to page 3 of Exhibit 1015,
`please.
` The definition for "clock" that you refer
`to in your Supplemental Declaration begins on
`page 3, on the right-hand column, at the very bottom
`of the page.
` Do you see that?
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` A. Are you referring to the reference or to
`my --
` Q. I'm referring to the reference.
`Exhibit 1015. You're in the right spot.
` In the right-hand column, the bottom is
`where the definition of "clock" begins. Do you see
`that? And it goes on to the next page.
` A. Yes, I see that.
` Q. The definition of "clock" in this
`dictionary, Exhibit 1015, includes five different
`definitions, correct?
` A. Yes.
` Q. In your Supplemental Declaration, you
`specifically refer only to definitions 1 and 4,
`correct?
` A. In this paragraph, I only show those two,
`that's correct.
` Q. Definition 1 for "clock" states:
` "A pulse generator or signal
` waveform used to achieve
` synchronization of the timing of
` switching circuits and the memory in a
` digital computer system."
` Correct?
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` A. Yes.
` Q. Definition 4 states:
` "A strobe signal that activates a
` certain sequence of operations."
` Correct?
` A. Correct.
` Q. Neither of these definitions for "clock"
`specify one way or the other whether a clock signal
`is periodic, correct?
` A. That's correct. They don't say whether
`it's periodic. And so I would understand this to
`cover both periodic and unperiodic signals.
` Q. Neither of these definitions for "clock"
`include the term "clock signal," correct?
` A. They don't include the words "clock
`signal," but they refer to signals that I would
`understand as clock signals.
` Q. The Modern Dictionary of Electronics,
`Exhibit 1015, does not include the definition of the
`term "clock signal", correct?
` A. The first definition says "a pulse
`generator or signal" . . .
` So the definition of "clock" which is
`referring to signals, I would understand to be a
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`clock signal.
` And then definition 4, it says "a strobe
`signal." So if the definition of a clock is a
`strobe signal, I would understand that to be a clock
`signal.
` Q. Does the Modern Dictionary of Electronics,
`Exhibit 1015, have a separate entry for the term
`"clock signal"?
` MS. REICHEL: Objection. Form.
` THE WITNESS: It doesn't separately define
`clock signals, but it includes definitions that
`would apply to clock signals within these
`definitions of "clock."
`BY MR. COCHRAN:
` Q. You did not refer to definition 2 in your
`Supplemental Declaration, correct?
` A. Correct.
` Q. How come?
` A. Definition 2 is:
` "a timing device in a system;
` usually it provides a continuous
` series of timing pulses."
` But this is referring to a "device," not a
`signal; so it doesn't apply to signals. It is not
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`trying to define a signal; it's defining a device
`instead.
` Q. What about definition 3? You didn't refer
`to definition 3 in your Supplemental Declaration
`either. Why not?
` A. Definition 3 says:
` "an electronic circuit that
` generates timing pulses to synchronize
` the operation of a computer as well as
` keep time."
` So this is a definition for what's usually
`called a real-time clock in a system, which is a
`device that keeps the time of day. So this is a
`definition that has nothing to do with the
`definition of "clock signal" as used in the patent.
` Q. Like the IEEE dictionary, Exhibit 1014,
`the Modern Dictionary of Electronics has multiple
`definitions of the term "clock", correct?
` A. Both of these references have multiple
`definitions of "clock," for the way it's used in
`different contexts.
` Q. Okay. What are the different contexts in
`which the term "clock" is used, in your experience?
` A. You can use "clock" to refer to a device
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`like a clock oscillator; and you can use "clock" to
`refer to a signal on a board; and you can use
`"clock" to refer to a real-time clock, which can be
`a device or it can be a whole instrument.
` So the word "clock" can be used in
`different contexts like that.
` Q. Turn back to your Supplemental Declaration
`on page 3, paragraph 5. Turn to paragraph 5.
` In paragraph 5 of your Supplemental
`Declaration, you state:
` "Dr. Pedram's definition appears
` to be based on his assumption that the
` '002 patent is directed only to
` synchronous memory systems."
` Correct?
` A. That's what the first sentence says, yes.
` Q. If you turn to paragraph 6 at the bottom
`of page 4, you state:
` "In the embodiment in Figure 1 of
` the '002 patent, the clock input could
` be supplied with any type of clock
` signal -- e.g., a periodic clock
` signal, a non-periodic gated clock
` signal, a non-periodic clock signal
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` HORST - IPR2018-01249
` derived from a periodic clock (e.g.,
` RS1 as shown in Itoh's synchronous
` clock system) or another type of
` non-periodic clock signal -- without
` adversely affecting its row decoding
` functionality."
` Correct?
` A. Yes, that's what it says.
` Q. So Figure 1 of the '002 patent could be
`supplied with a non-periodic clock signal and still
`function, according to you, correct?
` A. That's right.
` Q. But you don't cite to any portion of the
`'002 patent in support of that conclusion, do you?
` MS. REICHEL: Objection to form.
` THE WITNESS: I base that on my analysis
`of the circuit and noting that there's nothing in
`the circuit that depends on the periodic clock.
`BY MR. COCHRAN:
` Q. Well, the '002 patent does not state that
`the clock input in Figure 1 may be non-periodic,
`correct?
` A. It doesn't state either way as to what
`that -- the requirements are of that clock.
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` Q. Can you turn to page 17 of your
`Supplemental Declaration, Dr. Horst. Specifically
`I'm going to point you to paragraph 31.
` Are you there?
` A. Yes.
` Q. In paragraph 31 of your Supplemental
`Declaration, you state:
` "As my previous analysis shows,
` the 'clock signal' limitation should
` not be restricted to periodic signals.
` However, even if such a limited
` construction were adopted, the timing
` signal øce of Sato would still satisfy
` the limitation for 'clock signal'
` because the Sato row decoder circuit
` would still function with periodic
` external signals."
` Correct?
` A. Yes, that's what it says.
` Q. Are you suggesting here in this paragraph
`that the timing signal øce of Sato could be a
`periodic signal?
` A. Sato also doesn't state how the øce signal
`is input. And my analysis of a circuit shows that
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` HORST - IPR2018-01249
`it would work with either a periodic or a
`non-periodic øce signal.
` Q. So the timing signal øce of Sato could be
`a periodic signal, correct, according to you?
` A. Øce could be periodic. It could be -- a
`circuit could be used in such a way that the øce
`signal is a periodic signal.
` Q. In the first Declaration that you
`submitted in this matter along with the petition,
`you did not suggest that øce in Sato could be a
`periodic signal, correct?
` MS. REICHEL: Objection to form.
` Feel free to request the Declaration if
`you'd like to see it.
` THE WITNESS: I would like to see that, or
`a copy of that, if you want to ask questions about
`that Declaration.
`BY MR. COCHRAN:
` Q. Do you recall?
` MS. REICHEL: Objection to form.
` THE WITNESS: I do not recall if I
`discussed that or not in the original Declaration.
` MR. COCHRAN: I'm going to hand the
`witness what was previously marked as Exhibit Apple
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` HORST - IPR2018-01249
`1005.
` (Deposition Exhibit No. 1005 marked for
` identification.)
`BY MR. COCHRAN:
` Q. You recognize this as the Sato patent,
`correct?
` A. Yes, this is the Sato patent.
` Q. Could you refer to page 3, Figure 3, of
`Sato.
` Dr. Horst, would the circuits shown in
`Figure 3 of Sato operate properly if the signal øce
`were replaced with a periodic timing signal?
` A. The row decoder circuit, which is depicted
`in Figure 3, would work with a periodic timing
`signal, yes.
` Q. In your Supplemental Declaration, you did
`not provide any evidence that Sato would operate
`with a periodic timing signal, correct?
` MS. REICHEL: Objection to form.
` THE WITNESS: In my Declaration, I discuss
`the periodic timing signal on pages 19 and 20. So I
`have a full discussion about it in my supplement-
`supplementary Declaration.
`BY MR. COCHRAN:
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` HORST - IPR2018-01249
` Q. You didn't simulate Sato's circuit using a
`periodic timing signal, correct?
` A. No, I didn't simulate the circuit.
` Q. So how do you know it would work?
` A. On page 15 of my report, I developed this
`table of all the different states that the circuit
`can be in, and I showed that the circuit functions
`correctly in all these different states.
` And whether it sequences through these
`states periodically or not periodically doesn't
`affect its operation. So it would work correctly in
`either case.
` Q. Well, wouldn't you have to know the
`characteristics of the transistors shown in Figure 3
`in order to determine whether or not the Sato row
`decoder would operate properly with a periodic
`timing signal, Dr. Horst?
` A. The characteristics of the transistors,
`assuming that they are fast enough for the clock
`that's being applied, would not be an issue. That
`wouldn't affect the circuit operation with respect
`to periodic clocks.
` Q. Well, what if they're not fast enough?
`Then would it work?
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` MS. REICHEL: Objection to form.
` THE WITNESS: If the transistors weren't
`fast enough and you gave it a clock that was too
`fast, it wouldn't function.
` And also if you gave it a nonperiodic
`clock that was too fast, it wouldn't function.
` So in both cases, you have to make sure
`that the circuit is fast enough for the clock pulses
`that it's given.
`BY MR. COCHRAN:
` Q. Could you turn to page 4 of Exhibit 1005,
`please.
` Referring to Figure 4, the timing signal
`øce is generated by the block labeled "TC," correct?
` A. Yes, it shows it coming from block TC,
`although there are not details on what's inside
`clock -- or the block TC.
` Q. Okay. "TC" stands for timing control,
`correct?
` A. I believe that's right.
` Q. The timing control block generates the
`timing signal øce based on the states of a chip
`enable signal, a rate enable signal, and an output
`enable signal, correct?
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` HORST - IPR2018-01249
` A. That's what this figure shows, yes.
` Q. If you turn back to Figure 3, page 3 of
`the patent, the timing of the predecoder, "PDCR," is
`controlled by the timing signal øce, correct?
` A. The timing of the outputs of the
`predecoder are determined by the clock øce, that's
`right.
` Q. So the decoding operations of the
`predecoder, PDCR, are triggered by some combination
`of the chip enable, write enable, and output enable
`signals, correct?
` A. I wouldn't use the term "triggered," but
`the clocks are gated by the -- the decoding function
`and the clock are ANDed together to produce outputs
`that are synchronized by the clock.
` Q. Still referring to Figure 3, in your
`periodic version of the circuit, would the periodic
`clock signal be received by both the predecoder,
`PDCR, and the NAND gate circuit, NAG0?
` A. Yes. If clock øce is periodic, it would
`go to both the decoder NAG0 and all the other NAG
`decoders, as well as the predecoders.
` Q. So in the periodic version of Sato's
`Figure 3, the predecoder in all of the multiple NAND
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`gate circuits would be coupled to the same clock
`signal, correct?
` A. I don't agree with the premise of the
`question, which is that there is a separate periodic
`and nonperiodic version of Figure 3.
` It's the same circuit in either case. It
`is just -- the only difference is the timing on the
`input signal to that circuit.
` Q. Well, if Sato's system was provided with a
`periodic clock signal, that signal would be provided
`to the predecoder PDCR and all of the multiple NAND
`gate circuits, correct?
` A. It would be provided to the NAND gate
`circuits as well as the predecoder circuits.
` Q. Still on Figure 3. And specifically the
`NAND gates, the NAND gates NAG0 through NAGk, which
`is shown in Figure 1, the NAND gate circuits operate
`in two states, an evaluation state and a precharge
`state, correct?
` A. This decoder uses that clock for both
`evaluation and precharging, yes.
` Q. And the NAND gates, NAG0 to NAGk, each
`receive the selection control signal øce, correct?
` A. They receive this øce signal, the -- the
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`clock, which is sometimes called a selection signal.
` Q. When the selection control signal øce is
`high, the NAND gates are in the evaluation state,
`correct?
` A. When øce is high, the end-channel
`transistors are active and the P-Channel is cut off;
`so it's in the evaluation state.
` Q. In the evaluation state, the selection
`control signal øce discharges the output of one of
`-- one selected NAND gate to a low level, correct?
` A. One of the NAG decoders will get pulled
`down, and the other ones will not.
` Q. Discharging the output of the selected
`NAND gate takes some amount of time, correct?
` A. It takes some amount, small amount of
`time, yes.
` Q. What determines how much time it takes?
` A. The -- like the rest of the circuit, it
`depends on the strength of the transistors, the
`amount of capacitance, and the layout and so on.
` Q. Anything else?
` A. The determination on how fast the circuit
`is depends on a lot of different factors. And if
`one is trying to run at the maximum possible
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`frequency, there are a lot of things to consider;
`but if you are not trying to push the limits, then
`it functions without considering those other
`factors.
` Q. What about the characteristics of the
`selection control signal øce? Would that be about
`the timing that it takes to discharge the NAND
`circuit?
` A. The timing depends on when it reaches a
`valid level at all the decoder circuits. So
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