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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ------------------------------------------------------
`
` VIDEO DEPOSITION OF JON HUPPENTHAL October 8, 2019
`
` ------------------------------------------------------
`
` MICROSOFT CORPORATION,
`
` Petitioner,
`
` v.
`
` DIRECTSTREAM, LLC,
`
` Patent Owner.
`
` ------------------------------------------------------
`
` IPR2018-01594 (Patent 6,434,687 B1)
`
` IPR2018-01599 (Patent 6,076,152)
`
` IPR2018-01600 (Patent 6,247,110 B1)
`
` IPR2018-01601 (Patent 7,225,324 B2)
`
` IPR2018-01602 (Patent 7,225,324 B2)
`
` IPR2018-01603 (Patent 7,225,324 B2)
`
` IPR2018-01604 (Patent 7,421,524 B2)
`
` IPR2018-01605 (Patent 7,620,800 B2)
`
` IPR2018-01606 (Patent 7,620,800 B2)
`
` IPR2018-01607 (Patent 7,620,800 B2)
`
` ------------------------------------------------------
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 1
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 1
`
`

`

` APPEARANCES:
`
` SIDLEY AUSTIN, LLP
` By Joseph Micallef, Esquire
` By Scott M. Border, Esquire
` 1501 K Street Northwest
` Washington, DC 20005
` Appearing on behalf of Microsoft.
`
` JANIK VINNAKOTA, LLP
` By Rajkumar Vinnakota, Esquire
` By Donald Puckett, Esquire
` 8111 LBJ Freeway, Suite 790
` Dallas, Texas 75251
` Appearing on behalf of DirectStream.
`
` SHORE CHAN DePUMPO, LLP
` By Christopher L. Evans, Esquire
` 901 Main Street, Suite 3300
` Dallas, Texas 75202
` Appearing on behalf of DirectStream.
`
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`Page 2
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 2
`
`

`

` Pursuant to Notice, the video deposition of
`
` JON HUPPENTHAL, called by the Petitioner, was taken on
`
` Tuesday, October 8, 2019, commencing at 9:20 a.m. at 121
`
` South Tejon Street, Suite 900, Denver, Colorado, before Anne
`
` Marie Sager, Court Reporter and Notary Public within and for
`
` the State of Colorado.
`
` I N D E X
`
` VIDEO DEPOSITION OF JON HUPPENTHAL
`
` EXAMINATION BY: PAGE
`
` Mr. Micallef 5, 116
`
` Mr. Vinnakota 111
`
` NO EXHIBITS MARKED
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`Veritext Legal Solutions
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`Page 3
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 3
`
`

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` P R O C E E D I N G S
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` THE VIDEOGRAPHER: Good morning. We are
`
` on the record. My name is Walt Mathern for
`
` Veritext. The date today is October 8th, 2019
`
` and the time is approximately 9:20 a.m.
`
` This deposition is being held in the
`
` office of Agren Blando Court Reporting located
`
` at 121 South Tejon Street, Colorado Springs,
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` Colorado.
`
` The caption of this case is Microsoft
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` Corporation v. DirectStream, LLC, in the
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` United States Patent and Trademark Office. The
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` name of the witness is John Huppenthal.
`
` At this time the attorneys will identify
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` themselves and the parties they represent after
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` which our court reporter, Anne Sager, will swear
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` in the witness and we can proceed.
`
` MR. MICALLEF: Joe Micallef with Sidley
`
` Austin for Petitioner Microsoft.
`
` MR. BORDER: Scott Border also with
`
` Sidley Austin for Petitioner Microsoft.
`
` MR. VINNAKOTA: Rajkumar Vinnakota with
`
` Janik Vinnakota for Patent Owner DirectStream,
`
` and also appearing telephonically, Donald
`
` Puckett with Janik Vinnakota also for Patent
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 4
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 4
`
`

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` Owner DirectStream.
`
` (witness sworn in under oath.)
`
` JON HUPPENTHAL,
`
` being first duly sworn in the above cause, was examined and
`
` testified as follows:
`
` EXAMINATION
`
` BY MR. MICALLEF:
`
` Q Just for the record, this testimony is being taken
`
` in the following Inter Partes Review Proceedings
`
` in the PTO, IPR 2018-01594, 01599, 01600, 01601,
`
` 01602, 01603, 01604, 01605, 01606 and 01607.
`
` Good morning, Mr. Huppenthal.
`
` A Good morning.
`
` Q Have you ever testified before?
`
` A Yes, about twenty years ago.
`
` Q Twenty years ago? In what context?
`
` A It was in a HR deposition.
`
` Q Did you testify in a deposition or was it in court
`
` or both?
`
` A No, it was a deposition.
`
` Q That's the only time you have testified?
`
` A Yes.
`
` Q Okay. So you at least have a general idea of what
`
` we're doing here. You understand you need to
`
` answer all of my questions as best you can?
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 5
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 5
`
`

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` A Yes.
`
` Q Okay. That's great. One caution, if you talk
`
` fast or if we talk over each other, the
`
` court reporter is going to get very angry at us,
`
` so can we just agree to try not to do either of
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` those things?
`
` A Right.
`
` Q Okay. Great. I am going to put a document in
`
` front of you that has already been marked in these
`
` proceedings or in the '687 proceeding which is
`
` IPR2018-01594, and it was marked as Exhibit 2084,
`
` and it is entitled Declaration of John Huppenthal,
`
` and I will ask you to take a look at it.
`
` A Okay.
`
` Q Is Exhibit 2084 your declaration, sir?
`
` A Yes, it is.
`
` Q And you have submitted it on behalf of the patent
`
` owner in those proceedings?
`
` A Correct.
`
` Q And you have submitted the same declaration in all
`
` of the proceedings that are listed on the front of
`
` Exhibit 2084, is that right?
`
` A That is correct.
`
` MR. VINNAKOTA: Object to form.
`
` A That's correct.
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 6
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 6
`
`

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` BY MR. MICALLEF:
`
` Q Were you paid to prepare this declaration?
`
` A No.
`
` Q I would like you to turn to page 4 of
`
` Exhibit 2084. In particular, I would like to
`
` direct your attention to paragraph eight and the
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` last sentence in that paragraph which reads, "I
`
` was also responsible for overseeing the entire
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` intellectual property program at SRC."
`
` Do you see that?
`
` A Yes.
`
` Q Can you explain to me what that responsibility
`
` entailed?
`
` MR. VINNAKOTA: Objection to form.
`
` A We had a variety of engineers at the company, and
`
` a lot of different people were involved in coming
`
` up with various developments of the system.
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` And part of my job was to evaluate those
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` different ideas and decide which ones we might
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` want to pursue patents on, and then initiate that
`
` action with our attorneys.
`
` Q Okay. And you had that responsibility from when
`
` you were hired onward?
`
` A We didn't really get into that mode until we had
`
` the first patent start to come up which was in,
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 7
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 7
`
`

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` you know, 1997, early 1997, so this role really
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` didn't exist until that timeframe, but from then
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` on, yes.
`
` Q Do you have that role today?
`
` A No.
`
` Q When did it end?
`
` A Well, when SRC was acquired by DirectStream my
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` position changed, and so that role terminated
`
` at that point.
`
` Q Okay. And this responsibility for overseeing the
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` intellectual property program, was there anyone
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` else that shared that responsibility with you?
`
` A No.
`
` Q It was all you?
`
` A Right.
`
` Q Did you receive any training in intellectual
`
` property law?
`
` A No.
`
` Q Did you receive any training in the regulations of
`
` the United States Patent and Trademark Office?
`
` A No formal training, no.
`
` Q Did you receive any informal training?
`
` A My job in this role was to decide whether or not I
`
` thought an idea was worthy of spending the amount
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` of money needed to actually go after the patent,
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 8
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 8
`
`

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` not to make any legal decisions on whether or not
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` it was ever going to be viable.
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` Q Did you have any familiarity with the requirements
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` of patentability in the law?
`
` A Only what I gained through the course of going
`
` through filing a number of patents and being
`
` involved in that process, but no formal training.
`
` Again, I am not a lawyer. I'm an engineer.
`
` Q And you had filed for patents prior to 1997?
`
` A Yes.
`
` Q And once you identify, I assume, during the period
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` of time that you had that responsibility you in
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` fact identified things that you thought warranted
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` filing for a patent application?
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` A I did, yes. The way that it would typically work
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` is that one of the engineers or a group of
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` engineers who were developing some particular
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` solution to a problem would come up with a new
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` idea.
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` They would bring that to me, and I would
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` either agree or disagree, whatever was appropriate
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` for that particular invention.
`
` Q Okay. And just at a high level, can you tell me
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` what the process would be after that point where
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` you identified something might be worth pursuing?
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 9
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 9
`
`

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` MR. VINNAKOTA: Objection, form.
`
` A After that point the internal process that we used
`
` was that the appropriate engineers would draft a
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` description of what the invention was.
`
` That would then be given to our attorneys
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` who would then take care of all the actual
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` creating of the patent, the claims, everything
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` that went with that.
`
` Q Okay. Did you have any participation in the
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` process for obtaining a patent after you contacted
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` the attorneys?
`
` MR. VINNAKOTA: And I am going to object
`
` only to the extent to caution the witness not to
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` divulge any attorney-client privilege
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` information, but to the extent he can answer
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` that without divulging any attorney-client
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` privileged information, he may answer.
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` A Some of the patents would have office actions,
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` objections, whatever. In some cases some of those
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` objections were returned back to the particular
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` inventors of the patent for some input, but not
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` all cases. That would be the only extent of
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` further involvement after the initial description
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` was provided.
`
` BY MR. MICALLEF:
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 10
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 10
`
`

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` Q Did you have an understanding that part of your
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` responsibility was to select information, prior
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` art information to disclose to the patent office
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` in the course of the application process?
`
` MR. VINNAKOTA: Objection, form.
`
` A Typically, we left that up to the attorneys.
`
` You know, if they found something in their
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` searching that they wanted input on we might
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` provide that input, but, no, the engineers
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` themselves didn't have to go off and do some kind
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` of prior art search with each one. That was left
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` up to the process.
`
` Q I was actually just asking about you personally,
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` whether you understood that to be part of your
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` responsibilities in any particular situation.
`
` MR. VINNAKOTA: Objection, form.
`
` A I did not take that as necessarily part of my
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` responsibilities just because of the way we had
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` put the process together.
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` Clearly we attended a lot of conferences,
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` had a lot of interaction with other people who
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` were in the industry. We had a pretty good idea
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` of what was going on where and knew that what we
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` were doing was totally different from anything
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` else.
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 11
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 11
`
`

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` So to the extent that that kind of
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` knowledge played into it, you know, that may have
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` found its way into some of the descriptions of the
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` patents, particularly when we talk about
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` background information or things like that.
`
` Q Okay. Could I get you to turn to page 18 of
`
` Exhibit 2084?
`
` A Okay.
`
` Q On that page is paragraph 32, and it refers to
`
` what appear to be two different devices, the
`
` bridge chip and a cross bar switch.
`
` Do you see that?
`
` MR. VINNAKOTA: Objection, form.
`
` A I see that it mentions the bridge chip, but the
`
` description is dealing more with the cross bar
`
` switch.
`
` Q Can you explain to me what the bridge chip was?
`
` A As I pointed out in the processor section of this
`
` declaration, we talked about having to develop an
`
` interface to get from the microprocessor's front
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` side bus to an interface that we would connect our
`
` cross bar switch to. That functionality, which is
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` actually in two FPGAs, as I state in here, formed
`
` the bridge chip.
`
` Q So the bridge chip consisted of two FPGAs?
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 12
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 12
`
`

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` A Right. It was bridging from the microprocessor's
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` front-side bus to our protocol for the switch.
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` Q For some reason it wasn't called the "bridge
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` chips"?
`
` A It wasn't, because it started off as the bridge
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` chip thinking it would fit in one, and it didn't.
`
` Q Oh, I see. Okay. And can you explain to me what
`
` the cross bar switch was?
`
` MR. VINNAKOTA: Objection, form.
`
` A The cross bar switch was the primary interconnect
`
` in our architecture that allowed our processors to
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` connect to the memory resources and any other
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` resources in the system.
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` Again, as I state in here, we were building
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` a large symmetric multi-processor. That requires
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` that all the resources have access to each other.
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` You do that through a cross bar switch.
`
` Q And what is a cross bar switch?
`
` A A cross bar switch is just that. It's a switch
`
` that a variety of devices can connect to,
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` processors, memory banks, reconfigurable
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` processors, whatever you want in the system, and
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` it allows them an electrical path to communicate
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` between each other and any point can get to any
`
` other point.
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 13
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 13
`
`

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` Q Cross bar switches were known before 1997?
`
` A They were.
`
` MR. VINNAKOTA: Objection, form.
`
` BY MR. MICALLEF:
`
` Q On page 19 of Exhibit 2084 there is a figure
`
` entitled "Multi-Segment Interconnect."
`
` Do you see that?
`
` A Yes.
`
` Q Is the bridge chip depicted in this figure?
`
` A No.
`
` Q Why not?
`
` A The bridge chip resides in the -- where we show
`
` the group of 20 processors. Those would be 20
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` individual boards.
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` The bridge chip resided down on those
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` boards, and was at a lower level than what is
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` shown at this particular level.
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` Each of these squares in this case
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` represents a group of functionality, so the
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` cross bar switch in this case is actually made up
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` of all these processor switches coupled to all the
`
` memory switches, and this only amounts to really
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` half of the interconnect that was the outbound
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` path and the return path was a duplicate.
`
` Q Okay. So let me see if I understand that. Each
`
`Veritext Legal Solutions
`800-336-4000
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`Page 14
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`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 14
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` of these boxes that says 20 processors has 20
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` boards?
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` A Correct.
`
` Q Each with one processor on it?
`
` A Correct. Well, we talk about two different
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` processor designs. There's a single processor
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` design where the board also accommodated the I/O
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` capabilities for the system. There is a quad
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` processor design. The 20 processors is the sum of
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` those two.
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` So if you looked at the quad processor
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` design board, it would have four processors and
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` four bridge chips and four ports to connect to the
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` cross bar switch. The I/O processor, the single
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` processor board, would only have one set of ports
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` to connect to the switch.
`
` Q And what you just described, would that have
`
` existed at the beginning of 1997?
`
` MR. VINNAKOTA: Objection, form.
`
` A What do you mean by "existed"?
`
` BY MR. MICALLEF:
`
` Q Well, when did that system, that structure that
`
` you just talked about, when did it actually exist
`
` in the real world for the first time?
`
` MR. VINNAKOTA: Objection, form.
`
`Veritext Legal Solutions
`800-336-4000
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`Page 15
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 15
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` A Well, for the first time they didn't exist
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` until -- I would say it probably would have been
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` later in '97 because we'd only conceptualized the
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` design in 1996, so it would take time for the
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` design to be completed and then fabricated and
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` gotten in-house.
`
` Q And when did the design become complete?
`
` MR. VINNAKOTA: Objection, form.
`
` A I don't know that I have that date.
`
` BY MR. MICALLEF:
`
` Q A rough guess?
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` MR. VINNAKOTA: Objection, form.
`
` A Sometime prior to having the boards in-house, but
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` I couldn't say exactly when.
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` BY MR. MICALLEF:
`
` Q Okay.
`
` A The designs also went through many iterations, so
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` the first boards you got in-house weren't
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` necessarily the end of the design. They were
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` typically then refined.
`
` Q And so just back to this figure at the top of
`
` page 19 of Exhibit 2084, if I understood you
`
` correctly, if I drew a box around all of the boxes
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` that have memory switch or processor switch in
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` them, collectively you would consider that the
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`Veritext Legal Solutions
`800-336-4000
`
`Page 16
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 16
`
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` cross bar switch?
`
` MR. VINNAKOTA: Objection, form.
`
` BY MR. MICALLEF:
`
` Q Is that fair?
`
` A All those together would make up the system-level
`
` cross bar switch, but you could have smaller
`
` configurations of the system.
`
` For example, this shows how we could have
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` up to 16 segments making up a system. You could
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` have a system that only had one segment in which
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` case only the switches appropriate in that segment
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` would make up the cross bar switch for that size
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` system.
`
` Q Okay. But in the figure that's depicted here, if
`
` I drew that box, that would be the cross bar
`
` switch for this system?
`
` MR. VINNAKOTA: Objection, form.
`
` A That would be -- this would be half of the
`
` cross bar switch as I talk about it. There is a
`
` duplicate coming back the other direction.
`
` So if you drew those, you would have
`
` captured all the read switches or all the write
`
` switches in this particular figure.
`
` Q Okay. So I understand that there is ellipses in
`
` there, but what are depicted here, there's three
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 17
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 17
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` memory switch boxes and three processor switch
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` boxes, correct?
`
` MR. VINNAKOTA: Objection, form.
`
` A Correct.
`
` Q And you're saying that would be -- those six boxes
`
` would be only for read operations or only for
`
` write operations, is that correct?
`
` MR. VINNAKOTA: Objection, form.
`
` A No. They would be for the read direction or the
`
` write direction. When you do a read, you have to
`
` issue a write first, but the paths through the
`
` switches are all uni-directional. So for data to
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` flow out, you need an outbound switch, and to come
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` back, you need a return switch.
`
` Q I see. And I noticed there is a reference in this
`
` figure to trunk lines.
`
` Do you see that?
`
` A Right.
`
` Q Can you explain what a trunk line is?
`
` A That was just the name of the interconnect lines
`
` we gave that went between the switch tiers.
`
` Q I'm sorry. I didn't hear.
`
` A It was the interconnect lines we gave for the
`
` connections between the switch tiers. It was just
`
` an internal name.
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 18
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 18
`
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` Q And physically what were they?
`
` A Cables. So they would connect from one connector
`
` on the processor switch, for example, to one
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` connector on the memory switch.
`
` Q And would that be one conductor?
`
` A No. At this point in time these cables would have
`
` at least 72 conductors in them.
`
` Q Each trunk line would have 72 conductors?
`
` A Correct.
`
` Q And just to be clear, at this point in time, 1997?
`
` A Yeah.
`
` Q Okay. And they would be used in a uni-directional
`
` sense?
`
` A Correct.
`
` Q Okay. Can you explain how the switches, either
`
` the processor switch or the memory switch, you
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` tell me, how it actually made the connections, how
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` it decided how to switch things?
`
` A Sure.
`
` MR. VINNAKOTA: Objection, form.
`
` A When you look at the actual switch and we show a
`
` figure of one on page 20, actually it shows a
`
` physical figure of the switch.
`
` You can see there is a group of connectors
`
` at the bottom in this figure. In this case, those
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 19
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 19
`
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` happen to be the processor connections, and then
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` there is a group at the top which happen to be the
`
` trunk connections, and then a big array of FPGAs
`
` in the center to make up the physical switch.
`
` What the switch would do, the circuitry
`
` that was distributed across those FPGAs would look
`
` at the header of the packet, the electrical packet
`
` provided by the processor that would tell it which
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` trunk line it needed to go out on.
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` It would then take all the communication
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` that was supposed to go to that same trunk line.
`
` It would arbitrate between them to determine which
`
` one can go out that particular trunk line first
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` and which one can go second, because only one can
`
` go at a time, and then it would send it on its
`
` way. That happened across all of these 16
`
` channels shown here.
`
` Q And so the communications between the processors
`
` and the memory banks were packetized?
`
` A That's correct.
`
` Q Were they packetized according to any particular
`
` standard?
`
` A No.
`
` MR. VINNAKOTA: Objection, form.
`
` A No. We developed internal very low latency, low
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 20
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 20
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` overhead packet format that we've used and still
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` use today.
`
` Q So help me understand how that works. Let's just
`
` take a memory write operation.
`
` You obviously have to have address
`
` information in a memory write operation, correct?
`
` A That's correct.
`
` Q And you need to have control information in a
`
` memory write operation?
`
` A Not necessarily.
`
` Q Not necessarily?
`
` A I don't know what you mean by "control
`
` information."
`
` Q Well, how about chip select?
`
` MR. VINNAKOTA: Objection, form.
`
` A The address determines that.
`
` Q Okay. How about random access strobe -- excuse me
`
` -- row address strobe?
`
` A No. This was an SRAM-based system.
`
` Q I see.
`
` A So there was no row and column addressing.
`
` Q So obviously if you're going to write, you're
`
` going to have to send data along as well?
`
` A Correct.
`
` Q Would you send anything else? Well, first of all,
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 21
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 21
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` would the address and data information be in the
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` same packet?
`
` A Yes.
`
` Q Okay. Is there anything else in that packet?
`
` A The packet had provisions to allow us to send
`
` things -- like specify if that was going to be a
`
` semaphore or not a semaphore, was it truly just
`
` raw data.
`
` So there were some other things that were
`
` relative to other system features, but the primary
`
` elements were the address header and the data.
`
` Q Okay. And how wide was the address?
`
` MR. VINNAKOTA: Objection, form.
`
` A In this case, the addresses evolved over time, but
`
` we were primarily using a 64 bit address. The
`
` early processors only had capability to go to a 36
`
` bit address, but we could over commit that through
`
` the bridge chips to create a full 64 bit address
`
` even though the processor couldn't take advantage
`
` of it. So the field in the packets through there
`
` were 64 bit addresses.
`
` Q And then how wide was the data?
`
` A The data was also 64 bits of data, but because we
`
` ran SECDED through the system, that's single error
`
` correction, double error detection, you picked up
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 22
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 22
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` another 8 bits, so the actual number of bits
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` moving was 72 bits wide for both the address and
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` the data.
`
` Q So you couldn't send a whole packet over a single
`
` trunk line?
`
` A Yes, you could.
`
` Q I'm sorry. You couldn't send a whole packet over
`
` a single trunk line at the same time?
`
` MR. VINNAKOTA: Objection, form.
`
` A Yes, you could.
`
` Q Well, I thought you said the address is 72 bits
`
` and the data is 72 bits, and that's all in the
`
` packet?
`
` A That's correct.
`
` Q And the trunk line is 72 conductors?
`
` A That's correct.
`
` Q And so wouldn't you have to send --
`
` A No, it's a packet. It's not a continuous wide
`
` word. So the first element of the packet, when
`
` you have a packet you have a certain number of
`
` elements that make it up.
`
` So we would have an element that was the 72
`
` bits that contained the address followed by a
`
` number of elements that were data words.
`
` So when we sent an address that was a
`
`Veritext Legal Solutions
`800-336-4000
`
`Page 23
`
`Microsoft Corp. v. Directstream, LLC
`IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1073, p. 23
`
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` starting address for the data movement, and it
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` could contain up to sixteen data words behind it,
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` and those all went out sequentially, so your
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` packet was a 72 bit wide thing that was 17
`
` clocks -- total clocks long.
`
` Q Okay. Maybe I don't understand what you said or
`
` maybe my question was inexact, so let me see if I
`
` can do it again.
`
` Over a single trunk line are you saying
`
` you'd send 72 bits of address at a first point in
`
` time?
`
` A First clock.
`
` Q Followed by 72 data bits at the next clock?
`
` MR. VINNAKOTA: Objection, form.
`
` A Th

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