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`Massoud Pedram, Ph.D. - June 5, 2019
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________
` )
`APPLE INC., )
` )
` Petitioner, ) Case IPR2018-01315
` ) Patent 8,063,674
` v. )
` ) Case IPR2018-01316
`QUALCOMM INCORPORATED, ) Patent 8,063,674
` )
` Patent Owner. )
`____________________________)
`
` DEPOSITION OF MASSOUD PEDRAM, PH.D.
`
` LOS ANGELES, CALIFORNIA
`
` WEDNESDAY, JUNE 5, 2019
`
`DORIEN SAITO, CSR 12568, CLR
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`1
`
`Exhibit 1017
`Apple v. Qualcomm
`IPR2018-01316
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`Massoud Pedram, Ph.D. - June 5, 2019
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________
` )
`APPLE INC., )
` )
` Petitioner, ) Case IPR2018-01315
` ) Patent 8,063,674
` v. )
` ) Case IPR2018-01316
`QUALCOMM INCORPORATED, ) Patent 8,063,674
` )
` Patent Owner. )
`____________________________)
`
` DEPOSITION OF MASSOUD PEDRAM, PH.D.
`
` LOS ANGELES, CALIFORNIA
`
` WEDNESDAY, JUNE 5, 2019
`
`DORIEN SAITO, CSR 12568, CLR
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`1
`
`Exhibit 1017
`Apple v. Qualcomm
`IPR2018-01316
`
`
`
`Massoud Pedram, Ph.D. - June 5, 2019
`
`Page 2
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________________
` )
`APPLE INC., )
` )
` Petitioner, ) Case IPR2018-01315
` ) Patent 8,063,674
` v. )
` ) Case IPR2018-01316
`QUALCOMM INCORPORATED, ) Patent 8,063,674
` )
` Patent Owner. )
`____________________________)
`
` DEPOSITION OF MASSOUD PEDRAM,
`
` PH.D., taken on behalf of
`
` PETITIONER at 555 South Flower
`
` Street, 50th Floor, Los Angeles,
`
` California 90071, commencing at
`
` 10:05 a.m., Wednesday, June 5,
`
` 2019, before DORIEN SAITO,
`
` CSR 12568, CLR.
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`Massoud Pedram, Ph.D. - June 5, 2019
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`Page 3
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`A P P E A R A N C E S :
`
` FOR PETITIONER:
`
` FISH & RICHARDSON
` By: WHITNEY A. REICHEL, Attorney at Law
` One Marina Park Drive
` Boston, Massachusetts 02210-1878
` (617) 521-7826
` wreichel@fr.com
`
` FOR PATENT OWNER:
`
` JONES DAY
` By: JOSEPH M. SAUER, Attorney at Law
` North Point
` 901 Lakeside Avenue
` Cleveland, Ohio 44114-1190
` (216) 586-3939
` jmsauer@jonesday.com
`
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`Massoud Pedram, Ph.D. - June 5, 2019
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`Page 4
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` I N D E X
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`W I T N E S S :
`
`MASSOUD PEDRAM, PH.D. PAGE
`
` EXAMINATION BY MS. REICHEL 6
`
`AFTERNOON SESSION:
`
` EXAMINATION BY MS. REICHEL 96
`
`INFORMATION REQUESTED:
`
` (NONE)
`
`QUESTIONS INSTRUCTED NOT TO ANSWER:
`
` (NONE)
`
`E X H I B I T S :
`
`NUMBER DESCRIPTION PAGE
`
`Exhibit 1 Patent Owner Response to 7
` Petition for Inter Partes
` Review Pursuant to 37 C.F.R.
` 42.220
`
`Exhibit 2 Patent Owner Response to 13
` Petition for Inter Partes
` Review Pursuant to 37 C.F.R.
` 42.220
`
`Exhibit 3 Patent No.: US 8,063,674 B2 167
`
`E X H I B I T S : (Previously marked)
`
`NUMBER DESCRIPTION PAGE
`
`Apple 1005 U.S. Patent No.: 7,279,943 135
` B2
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`Massoud Pedram, Ph.D. - June 5, 2019
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`E X H I B I T S : (Continued) (Previously marked)
`
`NUMBER DESCRIPTION PAGE
`
`Apple 1006 U.S. Patent No.: 4,717,836 124
`
`Apple 1007 Sleepy Stack Leakage 143
` Reduction by Jun Cheol Park,
` et al.
`
`Apple 1008 U.S. Patent Application 168
` Publication No.:
` US 2002/0163364 A1
`
`Apple 1009 U.S. Patent No.: 168
` US 6,646,844 B1
`
`Apple 2002 Declaration of Dr. Massoud 13
` Pedram (IPR2018-01315)
`
`Apple 2002 Declaration of Dr. Massoud 16
`
` Pedram (IPR2018-01316)
`
`Apple 2002-B Appendix A 23
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`Massoud Pedram, Ph.D. - June 5, 2019
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` LOS ANGELES, CALIFORNIA; WEDNESDAY, JUNE 5, 2019
`
` 10:05 A.M.
`
` -0o0-
`
` ***
`
` MASSOUD PEDRAM, PH.D.,
`
` having been duly administered an oath
`
` in accordance with CCP 2094, was
`
` examined and testified as follows:
`
` ***
`
` EXAMINATION
`
`BY MS. REICHEL:
`
` Q. Good morning, Dr. Pedram.
`
` A. Good morning.
`
` Q. How are you?
`
` A. Good, thank you.
`
` Q. Do you understand that you're here today to
`
`discuss the declarations that you submitted in IPR
`
`case Nos. 2018, '1315 and '1316 which relate to U.S.
`
`Patent No. 8,063,674?
`
` A. Yes.
`
` Q. What is your understanding of what your
`
`assignment was in this case -- or in these cases?
`
` A. I was asked to look at a couple of
`
`combinations of prior arts related to '674 that had
`
`been, I guess, provided by Apple and look at the
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`Massoud Pedram, Ph.D. - June 5, 2019
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`required documentation, '674 itself, the prior art
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`references, get the declaration of Apple's experts,
`
`and opine on the validity of '674, or lack thereof,
`
`in view of the asserted prior arts combination.
`
` MS. REICHEL: I put in front of you Pedram
`
`Exhibit 1, which is the Patent Owner Response to
`
`Petition For Inter Partes Review in the '1315 case.
`
` (The aforementioned document was
`
` marked Exhibit 1 for identification
`
` by the reporter.)
`
`BY MS. REICHEL:
`
` Q. Do you have that in front of you?
`
` A. Yes.
`
` Q. If you can turn to the table of contents,
`
`please.
`
` A. Yes.
`
` Q. Do you see Section 8 relating to the AAPA
`
`and Majcherczak combination?
`
` A. Yes.
`
` Q. There's only one lettered subheading under
`
`that section, which is entitled, "The POSA, P-O-S-A,
`
`would not combine the alleged AAPA and Majcherczak
`
`as proposed by petitioner."
`
` Do you see that?
`
` A. Yes.
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`Massoud Pedram, Ph.D. - June 5, 2019
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` Q. Do you see that there are no other lettered
`
`sections under Section 8?
`
` A. Yes, ma'am, that's correct.
`
` Q. Were you asked only to opine, with respect
`
`to the AAPA and the Majcherczak combination, on the
`
`question of whether a person skilled in the art
`
`would have made that combination?
`
` MR. SAUER: Objection.
`
` To the extent you can answer without
`
`revealing attorney work product, go ahead.
`
` THE WITNESS: So this is not my report,
`
`right. This is Apple, petitioner versus Qualcomm,
`
`Incorporated, patent owner's response.
`
` I have my own report -- or declaration
`
`regarding this patent that you mentioned the numbers
`
`for. And basically my understanding was, again, to
`
`look at these prior art combinations and provide my
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`assessment whether they anticipate or, in this case,
`
`render obvious the claims of patent '674.
`
` I do not recall any specific task of only
`
`dealing with this particular subheading, the POSA
`
`would not combine the alleged AAPA and Majcherczak
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`as proposed by petitioner, as my only responsibility
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`or task. I was to look at the totality of the
`
`asserted prior art combinations, look at the patent
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`and opine.
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`BY MS. REICHEL:
`
` Q. It's your understanding that the scope of
`
`your assignment included an evaluation of whether
`
`AAPA and Majcherczak combined are -- fully disclose
`
`the scope of the claims at issue in this proceeding?
`
` MR. SAUER: Objection; form.
`
` THE WITNESS: I look at AAPA and
`
`Majcherczak, as proposed by the petitioner, as an
`
`obviousness combination. And I looked at that
`
`combination to see if it meets on -- or meets all
`
`the limitations of the claims of the '674 patent.
`
`That's what I did.
`
`BY MS. REICHEL:
`
` Q. Did you provide an opinion about whether
`
`AAPA, in combination with Majcherczak, discloses
`
`every elements of the claims at issue?
`
` A. Yes, of course I did. And my opinion was
`
`no, it did not -- or it does not.
`
` Q. Your recollection of your opinion is that
`
`elements of the claims are missing from the AAPA and
`
`Majcherczak combination?
`
` A. That -- so they -- the key idea -- the key
`
`statement I can make with respect to AAPA and
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`Majcherczak is that this combination would result in
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`a solution which is --
`
` The proposed combination, which is a
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`reengineering of AAPA in view of Majcherczak,
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`produces a solution which is inferior both to AAPA
`
`itself, as well as to Majcherczak itself. And
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`therefore a POSA would not combine the two in the
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`way that it's been alleged.
`
` Q. Okay. I'm going to ask my question again
`
`because it's slightly different.
`
` Do you have an opinion about whether the
`
`proposed combination of AAPA and Majcherczak fully
`
`discloses every element of Claim 1, setting aside
`
`the question of whether one would have made that
`
`combination?
`
` MR. SAUER: Objection; form.
`
` THE WITNESS: I haven't really opined on
`
`that matter. I -- I have not opined on that
`
`question. Basically I look at my own report and I
`
`see that I've emphasized the fact that this
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`combination would result in a solution which is
`
`inferior to both AAPA and Majcherczak. And so that
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`combination is not something that a POSA would be
`
`motivated to use.
`
` When I look at this now, I have -- I'm
`
`looking at the proposed feedback network power
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`up/down detector, the particular configuration of
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`AAPA and Majcherczak that's been proposed by Apple.
`
`I have a lot of issues with this regarding whether
`
`this actually does the adjustment of the current
`
`capacity of the up/down detector as the claim
`
`requires it or not.
`
` But I notice here that I have not opined on
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`it. So basically -- I have not done so, but just
`
`looking at it, I tend to not agree with the
`
`statement that without further deliberation and
`
`consideration, I could say this meets every element
`
`of their claims. Probably not.
`
` Q. You do agree that your declaration
`
`submitted in the '1315 case does not express an
`
`opinion that the combination of AAPA and Majcherczak
`
`is missing any elements of any of the claims at
`
`issue in the '1315 case; correct?
`
` A. Yes, that's correct. I did not opine on
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`that subject in my claim -- in my declaration.
`
` Q. Do you agree that your declaration
`
`submitted in the '1316 case does not express an
`
`opinion that the combination of AAPA and Majcherczak
`
`is missing any element of any of the claims at issue
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`in the '1316 case?
`
` A. Yes, that's correct. I did not opine on
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`that matter.
`
` Q. And if we turn back to the table of
`
`contents for the Patent Owner Response, which is
`
`Pedram Exhibit 1, there is no subheading under
`
`heading 8 that identifies any missing element of the
`
`claims at issue in that case from the
`
`AAPA/Majcherczak combination; correct?
`
` MR. SAUER: Objection; form.
`
` THE WITNESS: It doesn't have any
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`subheadings, but it does not make, also, any
`
`admissions to the contrary saying that, in fact,
`
`this particular combination would meet every
`
`limitation of the claim. As I said to you, probably
`
`it does not, and I can discuss it with you if you
`
`like.
`
` Especially my concern here is the current
`
`capacity. I don't see the way the feedback
`
`transistor is connected to the up/down detector will
`
`allow the current capacity to be adjusted as
`
`described in the patent. But I haven't opined on
`
`it.
`
` Q. Are you aware of any location in the Patent
`
`Owner Response in the '1315 case where the patent
`
`owner has identified any element missing from the
`
`AAPA/Majcherczak combination for the claims at issue
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`in the '1315 case?
`
` A. Not that I recall, no.
`
` Q. Are you aware of any location in the Patent
`
`Owner Response in the '1316 case, which is Pedram
`
`Exhibit 2, where the patent owner has identified any
`
`element missing from the AAPA/Majcherczak
`
`combination for the claims at issue in the
`
`'1316 case?
`
` (The aforementioned document was
`
` marked Exhibit 2 for identification
`
` by the reporter.)
`
` THE WITNESS: Again, no, I do not recall
`
`any such mention.
`
` MS. PEDRAM: You should have in front of
`
`you what has been previously marked in the
`
`'1315 case as Exhibit 2002, which is declaration of
`
`Dr. Massoud Pedram.
`
` (The aforementioned document was
`
` previously marked Exhibit 2002 for
`
` identification.)
`
`BY MS. REICHEL:
`
` Q. Do you have that in front of you?
`
` A. I have two declarations, one for the
`
`'1316 case, one for '1315 case.
`
` Which one are you referring to?
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` Q. The '1315 case.
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` A. Okay.
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` Q. Does Exhibit 2002 of the '1315 case --
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`strike that.
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` Is Exhibit 2002 in the '1315 case an
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`accurate copy of the declaration that you submitted
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`in the '1315 matter?
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` A. Yes, it is.
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` Q. Are you aware of any errors in this
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`declaration that you would like to correct today?
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` A. There are some typos, as I was looking at
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`the report again last night, but minor typos.
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` Q. Do you have anything substantive that you
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`determined was an error in this declaration?
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` A. Typos, I'd say. No, nothing substantive
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`that I recall.
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` Q. If you recall or identify any such errors
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`during the course of today's deposition, will let me
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`know?
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` A. Of course, yes.
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` Q. If you turn to Page 64 of '1315
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`Exhibit 2002, is that your signature?
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` A. Yes, ma'am, it is.
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` Q. Did you draft this declaration,
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`Exhibit '1315 [sic] -- 2002?
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` A. This is an interactive process in which we
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`put the document together, but all the ideas, all
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`the statements here are my own.
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` Q. When you say we put the document together,
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`who are you referring to?
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` A. So the final work document that was put
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`together in formatting paragraphs, annotations and
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`so on was done by the counsel, but the report, the
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`ideas herein, all the statements are entirely mine.
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` Q. Did you review all the statements in the
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`declaration prior to signing the declaration?
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` A. Of course, yes.
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` Q. Did you propose any changes to any of the
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`statements in the declaration?
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` A. I wrote it, basically, as I said. I mean,
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`when I say it's an interactive, cooperative process
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`means that, sort of, I provide the text and somebody
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`puts in and we decide what figure goes where, that
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`kind of thing. But basically the text here is mine.
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` Q. When you first saw a draft of the
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`declaration in the '1315 case, did you propose any
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`changes to the draft -- the text of the draft?
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` MR. SAUER: Objection; form.
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` THE WITNESS: Of course. I -- I do a lot,
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`yes.
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`Massoud Pedram, Ph.D. - June 5, 2019
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`BY MS. REICHEL:
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` Q. And you adopt all the statements in the
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`'1315 declaration as your own?
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` A. Yes, ma'am.
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` MS. REICHEL: Can you please take a look at
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`the '1316 declaration, which is also marked
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`Exhibit 2002 in that case.
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` (The aforementioned document was
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` previously marked Exhibit 2002
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` for identification.)
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` THE WITNESS: Yes.
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`BY MS. REICHEL:
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` Q. Is Exhibit 2002 in the '1316 case an
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`accurate copy of the declaration that you submitted
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`in the '1316 matter?
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` A. Yes, it is.
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` Q. Are you aware of any errors in this
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`declaration that you would like to correct here
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`today?
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` A. No errors, no.
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` Q. If you turn to Page 63 of '1316
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`Exhibit 2002, is that your signature?
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` A. Yes, ma'am.
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` Q. Does your description of the drafting
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`process that you previously gave for the '1315 case
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`apply equally to your declaration in the '1316 case?
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` A. Yes, ma'am, it does.
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` Q. Do you adopt all of the statements in the
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`'1316 declaration as your own?
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` A. Yes.
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` Q. With respect to the analysis that you
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`performed to draft these two declarations, did you
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`perform a separate analysis for the two different
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`cases, or can I ask you about your analysis for both
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`cases collectively?
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` A. I think the analyses I've done on both
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`cases is almost identical, with the exception of one
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`independent claim that's included. I think it's in
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`the '1316 case. Otherwise with respect to the
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`independent claim, the analysis is identical.
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` Q. Are you referring to defendant Claim 5 in
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`the '1315 application?
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` A. Yes, defendant Claim 5. And that's
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`correct, yes, '1315.
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` Q. You did not perform any separate analysis,
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`for example, for the means-plus-function claims at
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`issue in the '1316 case?
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` MR. SAUER: Objection; form.
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` THE WITNESS: I've done the claims -- I've
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`done the analysis of the claims that you see in my
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`Massoud Pedram, Ph.D. - June 5, 2019
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`report. That's it.
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`BY MS. REICHEL:
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` Q. For example, you didn't perform an analysis
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`of the means-plus-functions framework that was
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`specific to the claims at issue in the '1316 case;
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`correct?
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` A. So what --
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` MR. SAUER: Objection; form.
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` THE WITNESS: Yeah, what claim are we
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`talking about here? I think you're making this into
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`a test of my knowing, which is not that good.
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`BY MS. REICHEL:
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` Q. Oh, I'm sorry.
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` A. So remind me what you're talking about
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`here.
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` Q. I'm not trying to do that.
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` A. No, I know.
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` Q. Does your '1316 exhibit -- strike that.
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` Why don't we turn to paragraph 120 of the
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`'1316 declaration.
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` A. Yes.
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` Q. Do you see, in paragraph 120, you identify
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`certain claims, 8, 9, 12, 13 and 16 to 22?
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` A. Yes.
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` Q. Are those the list of claims that you
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`addressed in the '1316 declaration?
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` A. You know, I really haven't focused on
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`details of any of these claims. It's just the
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`statement -- the analysis I've done stops at the
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`level that I've described it here. Because these
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`are dependent claims, 8, 9, 12, 13, 16, 22 -- some
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`of them are dependent claims. Of course, we have
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`independent Claim 8 also.
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` So these claims, 9, 12, 13, 16 to 22 are
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`all dependent on Claim 8, which is a methods claim.
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`And this methods claim is the methods variant of --
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`in my view, of Claim 1. So the analysis that I've
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`done with respect to that claim and saying that a
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`POSA would not have combined Steinacker, Doyle and
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`Park in the manner that's proposed by the
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`petitioner, would equally apply to this independent
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`claim, and therefore to the corresponding subsequent
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`dependent claims, 9, 12, 13, 16 to 22.
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` Q. Dr. Pedram, is it your understanding that
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`Claims 17 to 22 are dependent claims of Claim 8?
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` MR. SAUER: Objection; form.
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` THE WITNESS: 16 is clearly a method
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`claim -- a method of Claim 8. 17, you're -- is not.
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`So 17 to 22 -- again, 17 is an independent claim. I
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`stand corrected. Up to 22, which are dependent
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`Massoud Pedram, Ph.D. - June 5, 2019
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`claims from 17, it looks like. Yes.
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` Q. Do you agree that your declaration does not
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`include any additional analysis for Claims 17 to 22
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`to address the fact that those claims are
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`means-plus-functions claims?
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` A. That is correct. I do not consider
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`means-plus-function issues related to Claim 17, for
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`example, in this case or the -- or the dependent
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`claims that come from it.
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` But again, the basis for my declaration
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`here with regard to this particular combination is
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`that the POSA would have not combined these
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`references in the manner proposed by the petitioner.
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`In my view, that equally applies to 1, 5, 8, 9, 12,
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`13, 16, also 17 up to 22. Because the point is that
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`this combination is not something that a POSA would
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`do.
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` I'm not getting into details of
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`means-plus-functions or apparatus claim limitations
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`of any of these claims.
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` Q. That's because your analysis in this case
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`focused on whether a person skilled in the art would
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`have made the proposed combination, and not whether
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`any specific elements of the claims at issue was
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`found in either of those combinations; correct?
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` MR. SAUER: Objection; form.
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` THE WITNESS: I have not opined on whether
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`this particular combination would have met various
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`limitations of these claims and, therefore, would
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`have rendered them obvious. I just did not opine on
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`that subject matter.
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` Q. When you say this particular combination,
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`do you mean to include both of the proposed
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`combinations in the '1315 and '1316 petitions?
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` A. Can you elaborate? What both combinations
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`are you talking about? The Stein- --
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` We're talking about Steinacker, Doyle and
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`Park, yes.
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` Q. Are you aware that both '1315 and '1316
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`include two different combinations, the AAPA in
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`combination with Majcherczak, and Steinacker in
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`combination with Doyle and Park?
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` A. Yeah, but this is -- statement
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`paragraph 120 is only related to Steinacker, Doyle
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`and Park. It has nothing to do with the Majcherczak
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`and AAPA reference.
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` Q. Okay. My reference to that paragraph was
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`intended to identify for you the claims that were at
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`issue in the '1316 case, and not any specific
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`combination.
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` Do you agree that the claims that you
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`addressed in the '1316 case are Claims 8, 9, 12, 13
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`and 16 to 22?
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` A. Yes, I think these are the claims, yes.
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` Q. Do you agree that you did not perform any
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`analysis specific to the means-plus-function aspect
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`of Claims 17 to 22 for either of the combinations at
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`issue in the '1316 case?
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` A. I did not do that analysis, no.
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` Q. I'm going to focus my questions on your
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`declaration submitted in the '1315 case. If at any
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`point you notice some aspect of the discussion that
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`would not relate to the '1316 case equally, will you
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`please let me know?
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` A. Sure.
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` Q. Are you able to describe the materials that
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`you reviewed -- or identify the materials that you
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`reviewed in arriving at the opinions that are set
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`forth in your declaration, Exhibit 2002?
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` MR. SAUER: Objection; form.
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` THE WITNESS: In paragraph 3, I do provide
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`a list of material I have considered in preparing my
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`declaration. It starts from the '674 patent itself
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`and goes to decision by the I- -- inter partes
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`review to institute an IPR proceedings, and finally
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`concludes at any other materials referenced in my
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`declaration here.
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` Q. Are you aware of any materials that you
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`reviewed in connection with your opinions in the
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`'1315 and '1316 cases that are not listed on Pages 1
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`to 2 of Exhibit 2002?
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` A. I tried to be comprehensive and tried to
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`include everything. This last item, K, is just in
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`case I missed something, but I've tried to be
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`comprehensive, include everything.
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` Q. Exhibit K refers to other materials
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`referenced in the declaration itself; correct?
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` A. Yes.
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` Q. If there are no other materials referenced
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`in the declaration itself, then would the list on
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`Pages 1 to 2 accurately reflect the complete list of
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`materials you reviewed in the '1315 and '1316 cases?
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` A. I believe so, yes.
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` Q. Can you please turn to appendix A of
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`Exhibit 2002.
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` A. Yes.
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` Q. And is this an accurate copy of your CV?
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` A. Yes, ma'am.
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` Q. Does your CV accurately reflect your
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`experience in the field relating to the '674 patent?
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` A. This is my general CV. I didn't put it
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`together to highlight any specific expertise that I
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`have. It just -- with regards to different fields
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`or subfields within analytical and computer
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`engineering. You can see, for example, on Page 1 of
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`my CV, I talked about impact on the field and my
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`research interests, rather than all the different
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`areas in which I have expertise.
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` So I guess by looking at my publication
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`list, my training, education, the courses I teach,
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`the totality of my CV and my life's career, one
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`could see relevant expertise and experience that I
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`have with respect to '674, but it's not explicitly
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`spelled out here.
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` Q. Are there any other significant experiences
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`that you've had that are not listed on your CV that
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`have informed your opinions in this case?
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` A. Of course, yes. I mean, again, in my CV
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`I -- for example, if you look, I don't list the
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`project fundings that I have from DAPRA, Defense
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`Advance Projects Research Agency, of the U.S.
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`government or from NSF, the National Science
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`Foundation, or the SRC, Semiconductor Research
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`Corporation, and many other funding services.
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` And usually, as part of those projects, I
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`build systems, I model them, I simulate them, I
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`fabricate them and I test them. And a lot of that
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`experience has informed my opinions today on this
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`matter and any other related matter. And that's not
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`listed in my CV. It's not something that you put in
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`your CVs.
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` This is a -- mostly I think of a CV that we
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`have as our publication list. This list of awards
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`and professional service that we do, some talks we
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`give. We don't try to make it a comprehensive list
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`of all the different projects that we have
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`undertaken or the different things we have done.
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` And as you probably recall from the past,
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`I -- I'm teaching VLSI design courses in which the
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`students learn about electronics, VLSI circuits,
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`including power on-off detectors, voltage converters
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`of different types, interface circuitry
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`microprocessors, adders, multipliers, registers. I
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`teach both undergraduate and graduate-level courses.
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` We actually design chips, we sometimes fab
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`them, we test them. I do projects in which I've
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`built complete systems, including power on-off
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`detector circuitry, that was used as part of the
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`system. Voltage-level converters, what they call
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`electrical fencing around voltage domains, and the
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`like.
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` So there's a lot of other things that goes
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`into my expertise that is not listed explicitly in
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`my CV.
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` Q. You described some of those activities in
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`your declaration itself, paragraphs 4 through 18.
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` A. Yes.
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` Q. In those paragraphs, have you intended to
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`capture the aspects of your experience that are
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`relevant to the opinions that you provided in the
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`'1315 and '1316 cases?
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` A. Again, in a generic fashion, without trying
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`to go into any details. If you look at the list of
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`paragraphs that you mentioned, a lot of this is
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`about the awards I received from various, I guess,
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`organizations, about the books and the archival
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`publications and my patents, and when I received my
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`doctorate, this and that.
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` I do have a paragraph, I think mostly
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`paragraph 5, that talks about I'm an expert in EDA,
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`VLSI, digital integrated circuits and semiconductor
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`memory, energy-efficient design, power thermal
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`modeling, voltage regulation, multiple supply
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`voltage domain, and the like. I have also worked on
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`voltage regulation conversion, power management
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`nanoelectronic circuits, this and that.
`
` But again, it's a very generic description.
`
`I'm not trying to highlight here my specific
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`expertise related to power on-off detection
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`circuitry. I'm just saying I've been teaching this
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`for 25 years, I've been practicing it, I've been
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`doing research in this field. I've had 60-plus
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`Ph.D. students graduating from my group in the last
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`25 years.
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