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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`- - - - - - - - - - - - - - - -x
`
`:
`
`Case IPR2018-01594
`
`: Patent 6,434,687
`
`: Case IPR 2018-01599
`
`Patent 6,076,152
`
`MICROSOFT CORPORATION,
`
`:
`
`Petitioner,
`
`: Patent 6,247,110
`
`v.
`
`: Cases IPR2018-01601,
`
`Case IPR 2018-01600
`
`-01602, -01603
`
`DIRECTSTREAM, LLC,
`
`: Patent 7,225,324
`
`Patent Owner.
`
`: Case IPR2018-01604
`
`Patent 7,421,524
`
`:
`
`Cases IPR 2018-01605,
`
`: -01606, -01607
`
`Patent 7,620,800
`
`13 - - - - - - - - - - - - - - - -x
`
`14
`
`15
`
`Friday, October 4, 2019
`
`Washington, D.C.
`
`16 Videotaped Deposition of:
`
`17
`
`TAREK EL-GHAZAWI, Ph.D.,
`
`18 Called for oral examination by counsel for the Petitioner,
`
`pursuant to notice, at the offices of Veritext Legal
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`19 Solutions, 1250 I Street, Northwest, Washington,
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`D.C. 20005, before Christina S. Hotsko, RPR, CRR, of
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`20 Veritext Legal Solutions, a Notary Public in and for the
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`District of Columbia, beginning at 9:02 a.m., when were
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`21 present on behalf of the respective parties:
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`22
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`Page 1
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`Veritext Legal Solutions
`800-336-4000
`Microsoft Corp. v. Directstream, IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1078, p. 1
`
`

`

`A P P E A R A N C E S
`O n b e h a l f o f P e t i t i o n e r :
` J O S E P H M I C A L L E F , E S Q U I R E
` S C O T T M . B O R D E R , E S Q U I R E
` L A U R A H A R R I S , E S Q U I R E
` S i d l e y A u s t i n , L L P
` 1 5 0 1 K S t r e e t , N o r t h w e s t
` W a s h i n g t o n , D . C . 2 0 0 0 5
`( 2 0 2 ) 7 3 6 - 8 4 9 2
`j m i c a l l e f @ s i d l e y . c o m
`s b o r d e r @ s i d l e y . c o m
`
`O n b e h a l f o f P a t e n t O w n e r :
` R A J K U M A R V I N N A K O T A , E S Q U I R E
` D O N A L D P U C K E T T , E S Q U I R E ( V i a T e l e p h o n e )
` J a n i k V i n n a k o t a , L L P
` 8 1 1 1 L B J F r e e w a y , S u i t e 7 9 0
` D a l l a s , T e x a s 7 5 2 5 1
`( 2 1 4 ) 3 9 0 - 9 9 9 9
`k v i n n a k o t a @ j v l l p . c o m
`
`A l s o P r e s e n t :
` O r s o n B r a i t h w a i t e , V i d e o T e c h n i c i a n
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`Page 2
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`Veritext Legal Solutions
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`Microsoft Corp. v. Directstream, IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1078, p. 2
`
`

`

`C O N T E N T S
`
`EXAMINATION BY:
`
` Counsel for Petitioner
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`Veritext Legal Solutions
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`Microsoft Corp. v. Directstream, IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1078, p. 3
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`

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` P R O C E E D I N G S
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` VIDEO TECHNICIAN: Good morning. We are
`
`going on the record at 9:02 a.m. on October 4th,
`
`2019.
`
` Please note that the microphones are
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`sensitive and may pick up whispering, private
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`conversations, and cellular interference. Please
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`turn off all cell phones or place them away from
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`the microphones as they can interfere with the
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`deposition audio.
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` Audio and video recording will continue
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`to take place unless all parties agree to go off
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`the record.
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` This is media unit 1 of the
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`video-recorded deposition of Dr. Tarek El-Ghazawi
`
`in the matter of Microsoft Corporation versus
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`DirectStream, LLC, filed in the United States
`
`Patent and Trademark Office, case IPR2018-01599.
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` This deposition is being held at Veritext
`
`Legal Solutions, located at 1250 I Street,
`
`Northwest, Washington, D.C.
`
` My name is Orson Braithwaite from the
`
`Page 4
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`Veritext Legal Solutions
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`Microsoft Corp. v. Directstream, IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1078, p. 4
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`

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`firm Veritext Legal Solutions, and I'm the
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`videographer. The court reporter is Christina
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`Hotsko from the firm Veritext Legal Solutions.
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` Counsel and all present in the room will
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`now state their appearances and affiliations for
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`the record.
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` MR. MICALLEF: This is Joe Micallef with
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`Sidley Austin for petitioner Microsoft
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`Corporation.
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` MR. BORDER: Scott Border, Sidley Austin,
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`for Microsoft.
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` MS. HARRIS: Laura Harris, Sidley Austin,
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`for Microsoft.
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` MR. VINNAKOTA: Rajkumar Vinnakota for
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`patent owner DirectStream. And also appearing
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`telephonically, Donald Puckett for patent owner
`
`DirectStream. Both of us from Janik Vinnakota.
`
` VIDEO TECHNICIAN: Thank you. Will the
`
`court reporter please swear in the witness.
`
`Whereupon,
`
` TAREK EL-GHAZAWI, Ph.D.,
`
`being first duly sworn or affirmed to testify to
`
`Page 5
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`Petitioner Microsoft Corp. - Ex. 1078, p. 5
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`the truth, the whole truth, and nothing but the
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`truth, was examined and testified as follows:
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` MR. MICALLEF: Just to be clear, Counsel,
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`he called out one IPR proceeding, but I think this
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`is relevant to all of them, between our respective
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`clients, so --
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` MR. VINNAKOTA: Correct.
`
` MR. MICALLEF: -- just on the record,
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`this testimony is coming in on the following IPR
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`proceedings: IPR2018-01594, 01599, 01600, 01601,
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`01602, 01603, 01604, 01605, 01606, and 01607.
`
` MR. VINNAKOTA: That is correct.
`
` MR. MICALLEF: Great. Thank you.
`
` EXAMINATION BY COUNSEL FOR PETITIONER
`
`BY MR. MICALLEF:
`
` Q. Good morning, Dr. El-Ghazawi.
`
` A. Good morning.
`
` Q. I have placed in front of you a document
`
`entitled, "Declaration of Dr. Tarek El-Ghazawi."
`
`It has been entered as Exhibit 2164 in the IPR
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`proceeding IPR2018-01601.
`
` And I want to ask you first, do you
`
`Page 6
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`Microsoft Corp. v. Directstream, IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1078, p. 6
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`

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`recognize this document?
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` A. I do.
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` Q. Okay. And this is your declaration that
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`you've submitted in these proceedings, correct?
`
` A. That's correct.
`
` Q. Okay. And you've been asked to submit
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`this declaration by the patent owner?
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` A. I was.
`
` Q. Okay. And you are being paid to -- or
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`have been paid to submit this --
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` A. Yes.
`
` Q. -- or will be paid to submit this?
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` A. Yes.
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` Q. Yes, Okay. And your signature appears at
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`the back, just before your CV; is that right?
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` A. Yes.
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` Q. And that's on page 19 of Exhibit 2164?
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` A. Yes.
`
` Q. Okay. And you read this document
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`carefully before signing it?
`
` A. Yes.
`
` Q. Okay. Now, you heard me just call out a
`
`Page 7
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`Veritext Legal Solutions
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`Microsoft Corp. v. Directstream, IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1078, p. 7
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`

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`number of different numbers that identify a number
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`of different IPR proceedings?
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` A. Correct.
`
` Q. And you are submitting the exact same
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`opinions in all of those proceedings; is that
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`right?
`
` A. Let's clarify this question a little bit.
`
` Q. Yeah. Is there another declaration that
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`you have prepared for any of these proceedings
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`other than the one that's in front of you?
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` A. This is the only, you know, actually,
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`declaration that I have for the matter of the
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`IPRs.
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` Q. Okay. Great.
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` You have different ones in the parallel
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`district court litigation, though?
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` A. Yes.
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` Q. Okay.
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` A. That's a different -- yeah.
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` Q. But for the IPRs, this is the only one?
`
` A. This is the only one, yes.
`
` Q. Okay. Thank you.
`
`Page 8
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`Veritext Legal Solutions
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`Microsoft Corp. v. Directstream, IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1078, p. 8
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`

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` And in all of those IPR proceedings that
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`I called out, you understand that there are a
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`number of different patents at issue?
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` A. I do. That this is the baseline. But I
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`was having very specific thing to address here,
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`not necessarily the patents, per se.
`
` Q. Okay. Have you reviewed all of the
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`patents that are at issue in those IPR
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`proceedings?
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` A. I would say a long time ago, a year ago
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`or something like that.
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` Q. Okay. But you've reviewed all six of
`
`them?
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` A. A year ago I reviewed the majority of
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`them. I can't remember now which is what.
`
` Q. Okay. Have you reviewed the petitions in
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`all of the proceedings I mentioned?
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` MR. VINNAKOTA: Objection to form.
`
` THE WITNESS: Proceedings?
`
`BY MR. MICALLEF:
`
` Q. IPR proceedings that I mentioned.
`
` A. The IPR -- I did not review -- I did not
`
`Page 9
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`Petitioner Microsoft Corp. - Ex. 1078, p. 9
`
`

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`see those, no.
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`Q.
`
`A.
`
`Q.
`
`Did you see any of the petitions at all?
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`No.
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`Okay. Have you reviewed any of the
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`declarations that Microsoft submitted in any of
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`these IPR proceedings?
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`A.
`
`Q.
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`No.
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`Did you review any of the prior art that
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`Microsoft's IPR petitions rely on?
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`A.
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`I was provided, as -- I believe per
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`Exhibit B or something like that here, two pieces
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`of documents that, to my understanding, were
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`perhaps submitted by Microsoft --
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`Okay.
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`-- pertaining to the, I believe, FMC and
`
`Q.
`
`A.
`
`Splash 2.
`
`Q.
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`Have you reviewed any other, other than
`
`those two you just mentioned, prior art?
`
`A.
`
`Q.
`
`No. By Microsoft? No.
`
`Okay. And when you say FMC, are you
`
`referring to the Halverson thesis?
`
`A.
`
`The Halverson thesis, yeah.
`
`Page 10
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`Microsoft Corp. v. Directstream, IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1078, p. 10
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`

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` Q. Had you seen that before your --
`
` A. No.
`
` Q. -- involvement here?
`
` A. No.
`
` Q. Okay. Doctor, you're going to have to
`
`let me finish my question.
`
` A. Oh, I'm sorry. I thought you finished.
`
` Q. That's okay. I'll --
`
` A. Yeah.
`
` Q. -- try to be succinct.
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` A. It was a complete sentence, so, you know,
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`I thought it was done.
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` Q. Okay. You have not seen the Halverson
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`thesis before your involvement in these
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`proceedings?
`
` A. No.
`
` Q. Okay. And had you seen the Splash 2 book
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`before your involvement in these IRP proceedings?
`
` A. I was aware of the Splash 2. I'm not
`
`sure which particular documents I have looked at,
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`you know, because I looked at it in, like, 2007,
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`2008. And prior to that, maybe mid-'90s,
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`Page 11
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`Petitioner Microsoft Corp. - Ex. 1078, p. 11
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`

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`something like that.
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` Q. Okay. And when you say you were aware of
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`the Splash 2, do you mean you were aware of the
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`Splash 2 machine?
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` A. Yeah. The project. The machine.
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` Q. But were you aware of the book, was the
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`question?
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` A. No, I have not read the book before. But
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`I believe I've read papers that pertain to that
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`book. And I really cannot remember because,
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`again, that would have been, at minimum, more than
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`ten years ago.
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` Q. Okay. Okay.
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` A. So actually, I'm citing it -- or I'm
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`citing one of the Splash works in some of the
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`exhibits that I've attached here as well, but I
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`just can't remember right now because that was
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`from 2007, 2008.
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` Q. Right.
`
` So Dr. El-Ghazawi, do you know Harold
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`stone?
`
` A. I met him before. I know of him. Yes.
`
`Page 12
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`Petitioner Microsoft Corp. - Ex. 1078, p. 12
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`

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` Q. You wrote a paper with him once, didn't
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`you?
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` A. That also would have been -- you know, I
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`mean, I wrote more than 300 papers, so that
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`probably would be, I would say, also more than ten
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`years ago.
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` Q. When you wrote the paper with --
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` A. Something like that. More or less,
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`something like that.
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` Q. You agree he's a very smart man?
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` A. He's a smart man.
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` Q. You agree he knows a lot about computer
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`architectures?
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` A. He does. Dr. Stone, of course, is --
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`work in that domain has been, I would say, a while
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`back. He worked in -- you know, so I don't know
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`anything about his work, for example, that
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`pertains to FPGE or reconfigurable computing, for
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`instance.
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` Q. You don't know anything one way or the
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`other about his experience in that area?
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` A. I know that he has authored an
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`Page 13
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`Petitioner Microsoft Corp. - Ex. 1078, p. 13
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`architecture book, but he, you know, does work in
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`many areas. So he does work in image processing
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`as well.
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` Q. He knows an awful lot about electrical
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`engineering, doesn't he?
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` MR. VINNAKOTA: Objection to form.
`
` THE WITNESS: Sure. I mean, he has a
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`Ph.D. in electrical engineering from a very good
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`school.
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`BY MR. MICALLEF:
`
` Q. Do you know Steve Trimberger?
`
` A. So I know also of Steve. I don't
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`think -- I don't know if we have met even before.
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`I know that I met Dr. Stone multiple times a while
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`back, but I don't know if I met Steve before.
`
` Q. But you've heard of him?
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` A. Of course, yes.
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` Q. And you heard of him before your
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`involvement with these patents?
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` A. I did. Yeah. But again, I was not -- we
`
`did not really interact like I -- in any project,
`
`for example, for me to know him.
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`Page 14
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` Q. What were the circumstances under which
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`you heard of him?
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` A. So there's nothing in particular I can
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`point right now in exact terms. I know that he
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`works in the field. But we have not, again,
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`interacted or worked on any joint project.
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` Q. Do you agree he's been well known in the
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`field of reconfigurable computing for a while?
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` MR. VINNAKOTA: Objection. Form.
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` THE WITNESS: There are lots of people
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`who are actually very well known in that field.
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`BY MR. MICALLEF:
`
` Q. And Mr. Trimberger would be one of them.
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`Agree to --
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` A. Sure.
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` Q. And he's been one of them for a couple of
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`decades or so?
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` MR. VINNAKOTA: Objection. Form.
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` THE WITNESS: Sure. There are many of us
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`who are designated IEEE fellows for that, like in
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`my case, for example.
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`BY MR. MICALLEF:
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` Q. You are designated a fellow in what?
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` A. In reconfigurable computing.
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` Q. In reconfigurable computing. Okay.
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` When did that --
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` A. And high-performance computing, actually,
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`as well.
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` Q. And high-performance -- go ahead. Finish
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`your -- would you just state your answer again so
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`we get it on the record.
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` A. Right. So, you know, IEEE fellow in --
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`you know, for my work in reconfigurable computing
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`and high-performance computing as well.
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` Q. And are those two different awards?
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` A. Well, it's a citation that tries to, you
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`know, sort of bring up what have you contributed
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`to the field. You know.
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` Q. Okay.
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` A. Or in which areas you have contributed in
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`particular.
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` Q. But, I mean, is it two citations or --
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` A. It's one citation that grabs -- I can't
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`even remember the exact citation. I remember
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`reconfigurable and parallel programming or
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`high-performance computing, something like that,
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`which are all parts of the same thing.
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` Q. Okay.
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` THE REPORTER: Doctor, I need to ask you
`
`to slow down a little bit.
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` THE WITNESS: Okay.
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` THE REPORTER: Just so I can make sure I
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`can get you.
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` THE WITNESS: Sure.
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`BY MR. MICALLEF:
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` Q. And how long have you been working in
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`that field?
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` A. Well, I mean, if you look back at my
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`publications, it will be from the '90s, 1990s.
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` Q. Okay. Mid-1990s?
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` A. Yes.
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` Q. Okay. Do you know Scott Hauck?
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` A. I also know of Scot Hauck, yeah.
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` Q. Have you ever met him personally?
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` A. I don't think we have met also
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`personally, but I know of him, yes.
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`Q.
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`He is also well known in the field of
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`reconfigurable --
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`A.
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`Q.
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`A.
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`Q.
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`A.
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`Q.
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`A.
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`Q.
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`He is also well known --
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`-- computing?
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`-- in the field, yes.
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`Okay. Do you know Peter Athanas.
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`I know Peter. Yes.
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`You've met him a number of times?
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`I know Peter well, yeah.
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`He is a scientist at Virginia Tech
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`University?
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`A.
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`Q.
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`A.
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`Q.
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`He's a professor at Virginia Tech, yes.
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`Been there a while?
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`He has.
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`And a smart guy?
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`MR. VINNAKOTA: Objection. Form.
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`THE WITNESS: Everybody in this field is
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`smart. It's a difficult field.
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`BY MR. MICALLEF:
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`Q.
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`And he's been working in reconfigurable
`
`computing for some time?
`
`A.
`
`Yes.
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` Q. He's been working in high-performance
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`computing, too? Do you agree with that?
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` MR. VINNAKOTA: Objection. Form.
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` THE WITNESS: This is a difficult
`
`question to answer because that characterization
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`is not really very accurate, if you will, because
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`there's an "as well," okay, that you added.
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` So there are people who have contributed
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`to reconfigurable computing, contributed to
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`high-performance computing, and contributed to the
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`two jointly when they join together. I can think
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`of these people as -- as well. Okay? But other
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`than that, I would probably say somebody
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`contributed to reconfigurable computing.
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` Like, for example, Dr. Athanas does not
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`publish his work in high-performance computing
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`conferences, for example.
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`BY MR. MICALLEF:
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` Q. Okay.
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` A. He publishes mainly in reconfigurable
`
`computing.
`
` Q. He knows --
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` A. Very well known in that area.
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` Q. He knows a lot about, for example,
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`programming FPGAs?
`
` A. Programming FPGAs? Yes.
`
` Q. Is it appropriate to say programming
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`FPGAs or configuring FPGAs or is either okay?
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` MR. VINNAKOTA: Objection. Form.
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` THE WITNESS: You have to define the term
`
`if you want to really use, it to be concise. So
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`you could use it to -- interchangeably, if you
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`would like to, but you could actually mean
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`programming as literally writing code. Okay? So
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`the term in FPGA is actually, when it comes to
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`programming, it does not necessarily -- it could
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`in one context mean something; in another context,
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`mean the other.
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` So programming could mean that you could
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`change what it does. Programming could mean the
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`act of writing code and translating that code to
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`make that FPGA work.
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`BY MR. MICALLEF:
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` Q. Okay. Either way, Mr. Athanas -- or
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`Dr. Athanas is knowledgeable about all of it?
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` A. Of course.
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` MR. VINNAKOTA: Objection. Form.
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`BY MR. MICALLEF:
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` Q. He's a recognized expert in the field,
`
`isn't he?
`
` A. He is a recognized expert. Sure.
`
` Q. So you use this phrase high-performance
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`computing. If we could go back to the mid-1990s,
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`who was out there working in the field of
`
`high-performance computing in the mid-1990s?
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` MR. VINNAKOTA: Objection. Form.
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` THE WITNESS: There are lots of people,
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`really. It's a -- you know, it's a big field.
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`BY MR. MICALLEF:
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` Q. Can you name some?
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` A. So if you take high-performance computing
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`only, okay, you will find people like Thomas
`
`Sterling, Jack Dongarra. There are lots of people
`
`really that are working just strict in
`
`high-performance computing.
`
` I, personally, work in both fields, so I
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`have contributions to each one of the fields, with
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`well-established specifics that we have
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`contributed. Like, for example, when you asked me
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`about -- the reason I was actually objecting to
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`"as well," that for instance I have developed a
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`parallel programming for high-performance
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`computers only. And there is a textbook and
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`there's a language and there are phrases that I
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`have invented and things of that sort. And that
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`did not involve, for instance, actually, FPGAs.
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`And then I did things that involved FPGAs as well.
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` Q. Were you aware of anybody else in the
`
`mid-1990s who were -- who was working in both
`
`high-performance computing and reconfigurable
`
`computing?
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` MR. VINNAKOTA: Objection. Form.
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` THE WITNESS: So this is -- I mean,
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`people see what they are doing really in the way
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`they want to see it. Okay? So I don't want to
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`start naming people. But there are definitely
`
`lots of people that, you know, work on the two.
`
`Yes.
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`BY MR. MICALLEF:
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` Q. In the mid-1990s?
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` MR. VINNAKOTA: Objection. Form.
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` THE WITNESS: In the mid-1990s I would
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`say -- the only people would be, you know, people
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`like, for example -- I would say, like, Dr. Buell,
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`who is actually one of my coauthors in the two
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`documents that I have actually attached, and also
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`the program manager for Splash 2. So there are
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`some of the people in that group that were also
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`working on both, in the intersection between the
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`two.
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`BY MR. MICALLEF:
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` Q. And by "that group," do you mean the
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`Splash 2 group?
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` A. I mean, yes, the Splash 2 group.
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` Q. Would you agree a Splash 2 computer was a
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`high-performance computer?
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` MR. VINNAKOTA: Objection. Form.
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` THE WITNESS: So if you really look at
`
`the two exhibits that I have attached -- and
`
`Dr. Buell actually was the coauthor -- we termed
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`the Splash 2 as an attached machine or, in other
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`words, a -- you know, very much a -- the simplest
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`form, if you will, of a core processor or a -- you
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`know, you can think of it that way, but again,
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`that would be the most kind of basic, you know,
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`form.
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` And we actually intentionally even say in
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`those articles that we do not cover these types;
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`we go more to the more contemporary
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`high-performance computers, and will specify which
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`ones in those articles.
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`BY MR. MICALLEF:
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` Q. Splash 2 had very high performance, at
`
`least in some applications. Do you agree --
`
` A. Yeah. Sure. I mean --
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` MR. VINNAKOTA: Objection. Form.
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` THE WITNESS: -- see -- you know, I
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`respect all research -- serious research efforts.
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`Splash 2 was a serious research effort. And every
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`research effort contributes something. The
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`question is, you know, any -- you know, does it
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`contribute something new, different? And all --
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`they all contribute different things.
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` So yes, it was definitely a good piece of
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`work and it does contribute. You know, there's no
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`doubt.
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`BY MR. MICALLEF:
`
` Q. Came out of the Supercomputer Research
`
`Center? Agree with --
`
` A. It came out of that group, yes.
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` Q. You call it a supercomputer?
`
` A. So that's -- I mean, nobody has a good
`
`definition of what a supercomputer is. I actually
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`defined that personally in my classes as, like, a
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`moving target, because that would -- would change,
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`you know, every day.
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` So the performance of it can be seen as a
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`supercomputer in certain applications, I would
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`imagine. But definitely it cannot accommodate at
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`the time, I believe -- for me to be able to term
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`it that, I would be able to take a supercomputing
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`application from legacy codes and try to transport
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`that there; it would work and it would give me a
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`supercomputing, you know, performance.
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`Q.
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`So let's see if we can -- if you would
`
`tell me some of the organizations that were
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`working on high-performance computing in the
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`mid-1990s.
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`MR. VINNAKOTA: Objection. Form.
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`BY MR. MICALLEF:
`
`Q.
`
`We just mentioned the Supercomputer
`
`Research Center. I guess that would be one.
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`Agree to that?
`
`A.
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`Well, basi- -- yeah. Sure. I mean,
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`there are lots, actually. I mean, NASA Goddard --
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`you know, if you're talking about organizations,
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`not industry. You know, so NASA Goddard was --
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`actually was working on that. You know, lots of
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`different NASA locations actually were working on
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`that. You know, definitely, you know, other
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`defense, you know, I would say security types of
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`installations in the Beltway here are as well.
`
`Q.
`
`A.
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`Okay. What about universities?
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`Well, universities -- a lot of
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`universities, you know, definitely. So the -- the
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`field is really full of universities. Illinois is
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`one, you know. So many universities, actually.
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` Q. So I'm talking about the mid- to late
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`1990s, though, not today.
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` MR. VINNAKOTA: Objection. Form.
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` THE WITNESS: Right.
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`BY MR. MICALLEF:
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` Q. Yeah. Okay. Was GW University working
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`on high-performance computing back then?
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` A. Yeah. We actually -- in fact, you know,
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`we -- NASA Goddard would show around 1996 a map of
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`the entire country that would show you, actually,
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`which are the universities that have the first
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`computer clusters, and GW would be there, you
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`know. So we were funded at the time from NASA
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`Goddard in many actual, you know, instances to do
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`work with them and -- particularly in remote
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`sensing and the like. And we built actually for
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`them a computer cluster and applications as well.
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` Q. And at the time, GW was also working on
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`using reconfigurable computing with high --
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` A. In the -- also, actually, in the late
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`1990s, yes, we did.
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` Q. Were there other universities that were
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`doing that?
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` MR. VINNAKOTA: Objection.
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` THE WITNESS: Sure. There are other
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`universities, yes.
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`BY MR. MICALLEF:
`
` Q. At the time?
`
` A. Yeah.
`
` Q. Okay. What about industry, as you put
`
`it? Who were the -- who were the high-performance
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`computing players in the industrial world in the
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`mid-to late 1990s?
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` MR. VINNAKOTA: Objection. Form.
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` THE WITNESS: The high-performance
`
`computing players in -- actually in industry would
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`be -- in the 1990s, actually, Intel was still a
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`player. You know, HP. You know, and you had Cray
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`actually has been from even way before them.
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` You had, you know, even companies that
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`came and left, like Kendall Square, you know.
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`Kendall -- these are some of the companies that
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`came in -- you know. MasPar. These are some of
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`the companies actually that even came and left,
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`you know, things of that sort. Thinking Machines
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`was one of the ones that came and left, could not
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`continue.
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` So there were lots of players.
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`BY MR. MICALLEF:
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` Q. IBM?
`
` A. And IBM, of course. Yeah.
`
` Q. Are you aware --
`
` A. Actually, in that -- if I remember
`
`correctly, in that period of time, we even had
`
`some of the IBM supercomputers in GW.
`
` Q. And did they include reconfigurable
`
`computing elements?
`
` A. No.
`
` Q. Are you aware of any of those
`
`organizations you just mentioned augmenting their
`
`systems with some kind of reconfigurable computing
`
`element?
`
` MR. VINNAKOTA: Objection. Form.
`
` THE WITNESS: I was --
`
`BY MR. MICALLEF:
`
`Page 29
`
`Veritext Legal Solutions
`800-336-4000
`Microsoft Corp. v. Directstream, IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1078, p. 29
`
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` Q. Excuse me, I just want to make sure, in
`
`the mid-to late 1990s.
`
` A. Right.
`
` MR. VINNAKOTA: Same objection.
`
` THE WITNESS: I was aware of an attempt
`
`by -- from -- actually, from vendors that, you
`
`know, we knew. I was aware that -- you know,
`
`actually, there was an Oak Ridge machine that was
`
`actually done by SRC.
`
`BY MR. MICALLEF:
`
` Q. And anybody else?
`
` A. I was aware -- again, as reconfigurable
`
`computers -- only reconfigurable computers, I was
`
`aware of, you know, the Splash 2 and the -- you
`
`know, the fact that it was actually about to be --
`
`and actually a commercialization, actually, effort
`
`of it. I was aware of some DARPA, you know,
`
`actually, initiatives and, you know, universities
`
`and -- and government labs and perhaps also some
`
`industry participating in some of that.
`
` But the DARPA effort was not necessarily
`
`high performance at the time. It was just
`
`Page 30
`
`Veritext Legal Solutions
`800-336-4000
`Microsoft Corp. v. Directstream, IPR2018-01605, -01606, -01607
`Petitioner Microsoft Corp. - Ex. 1078, p. 30
`
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`reconfigurable computing.
`
` Q. Any others that you're aware of?
`
` MR. VINNAKOTA: Objection. Form.
`
` THE W

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