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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` INTEL CORPORATION, ) Case No.
` ) IPR2019-00047
` Petitioner, ) IPR2019-00048
` ) IPR2019-00049
` vs. ) IPR2019-00128
` ) IPR2019-00129
` QUALCOMM INCORPORATED, )
` ) U.S. Patent No.
` Patent Owner. ) 9,154,356
`
` DEPOSITION OF PATRICK FAY, PH.D.
` South Bend, Indiana
` Wednesday, August 7, 2019
`
`Reported by:
`RACHEL F. GARD, CSR, RPR, CLR, CRR
`JOB NO. 165197
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` INTEL CORPORATION, ) Case No.
` ) IPR2019-00047
` Petitioner, ) IPR2019-00048
` ) IPR2019-00049
` vs. ) IPR2019-00128
` ) IPR2019-00129
` QUALCOMM INCORPORATED, )
` ) U.S. Patent No.
` Patent Owner. ) 9,154,356
`
` DEPOSITION OF PATRICK FAY, PH.D.
` South Bend, Indiana
` Wednesday, August 7, 2019
`
`Reported by:
`RACHEL F. GARD, CSR, RPR, CLR, CRR
`JOB NO. 165197
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` P. FAY, PH.D.
`
`Page 2
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` August 7, 2019
` 9:30 a.m.
`
` Deposition of PATRICK FAY, PH.D., at
`Morris Inn, 1399 North Notre Dame Avenue,
`South Bend, Indiana, pursuant to notice before
`Rachel F. Gard, Illinois Certified Shorthand
`Reporter, Registered Professional Reporter,
`Certified LiveNote Reporter, Certified Realtime
`Reporter, Indiana Notary Public.
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` P. FAY, PH.D.
`A P P E A R A N C E S:
` WILMERHALE
` Attorneys for Petitioner
` 1225 17th Street
` Denver, Colorado 80202
` BY: BENJAMIN FERNANDEZ, ESQ.
`
` JONES DAY
` Attorneys for Patent Owner
` 77 West Wacker Drive
` Chicago, Illinois 60601
` BY: THOMAS RITCHIE, ESQ.
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` P. FAY, PH.D.
` I N D E X
`WITNESS PAGE
`PATRICK FAY, PH.D.
`Cross-examination by Mr. Ritchie 5
`
` E X H I B I T S
`INTEL EXHIBIT PAGE
` Exhibit 1002 Declaration in 7
` IPR2019-00047
`
` Exhibit 1102 Declaration in 11
` IPR2019-00048
` Exhibit 1202 Declaration in 13
` IPR2019-00049
`
` Exhibit 1302 Declaration in 15
` IPR2019-00128
` Exhibit 1402 Declaration in 18
` IPR2019-00129
`
` Exhibit 1001 '356 Patent 26
`
` Exhibit 1003 U.S. Patent Application 33
` Publication Number US
` 2011/0217945
`
` Exhibit 1106 U.S. Patent Application 47
` Publication Number US
` 2010/0237947
`
` Exhibit 1004 3GPP TR 36.912 53
` Version 9.1.0, (2009-12)
`QUALCOMM EXHIBIT
` Exhibit 2013 U.S. Patent 9,161,254 78
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` P. FAY, PH.D.
` (Witness sworn.)
`WHEREUPON:
` PATRICK FAY, PH.D.,
`called as a witness herein, having been first
`duly sworn, was examined and testified as
`follows:
` CROSS-EXAMINATION
`BY MR. RITCHIE:
` Q. Would you state and spell your name
`for the record, please.
` A. Yes. I'm Patrick Fay.
`P A T R I C K. Surname is Fay, F A Y.
` Q. And what is your current address?
` A. My home address is 16045 Baywood
`Lane, Granger, Indiana.
` Q. You've been deposed before?
` A. I have.
` Q. So is it fair to say that you
`understand the deposition process?
` A. At some level, yeah.
` Q. You understand that you're
`testifying under oath today?
` A. I do.
` Q. And is there any reason you cannot
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` P. FAY, PH.D.
`testify fully and truthfully today?
` A. No, there's no reason.
` Q. Please let me know if you don't
`understand a question and I will try to clarify
`it for you. If you do answer, I'm going to
`assume you understand -- understood my
`question. Is that fair?
` A. That's fair.
` Q. If you need to take a break, just
`let me know. We can take a break as long as
`there's not a question pending. Okay?
` A. Okay.
` Q. You understand that this deposition
`pertains to your declarations in five IPR
`proceedings. Those matters are numbered:
`IPR2019-00047, IPR2019-000489, IPR2019-00049,
`IPR-00128 [sic], and IPR2019-00129.
` You understand that this deposition
`pertains to your declarations in those five
`matters?
` A. Yes.
` Q. Now, I may refer to the patent,
`which is the subject of your declarations,
`which is U.S. Patent 9,154,356. I may refer to
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` P. FAY, PH.D.
`that as the '356 Patent. When I say the '356
`Patent, will you understand that I'm referring
`to U.S. Patent 9,154,356?
` A. Yes, I will.
` Q. Thank you.
` (INTEL Exhibit 1002 marked
` for identification.)
` Q. I've handed you what has been marked
`as Exhibit INTEL 1002. Do you recognize
`Exhibit INTEL 1002 as the declaration you
`submitted in IPR2019-00047?
` A. Yes, I recognize this document.
` Q. And this document sets forth your
`opinions in their entirety concerning the
`validity of the '356 Patent in connection with
`IPR2019-00047?
` MR. FERNANDEZ: Objection. Form.
` A. This document states my opinions
`with regard to the validity of the '356 Patent
`as related to the reference of Uehara and the
`other cited references that are contained in
`the declaration.
` Q. Yes. And this is a -- this is the
`complete set of your opinions with respect to
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` P. FAY, PH.D.
`those references that are addressed in
`IPR2019-00047?
` MR. FERNANDEZ: Objection. Form.
` A. With respect to the reference that I
`cite by Uehara and the 3GPP Feasibility Study,
`the reference by Parumana, the reference by
`Youssef, and related combinations, this
`document sets forth my opinions.
` Q. And those are the only references
`your declaration cites with respect to
`IPR2019-00047; is that correct?
` A. I'm sorry. Could you repeat the
`question for me?
` Q. You identified several references.
`And my question was: Those are the only
`references your declaration cites with respect
`to IPR2019-00047, correct?
` MR. FERNANDEZ: Objection. Form.
` A. I believe the references I listed
`previously --
` Q. Let me retract that.
` A. Okay.
` Q. It's not trying to be a trick
`question. For IPR2019-00047 that's on the
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` P. FAY, PH.D.
`front, this is a complete statement of your
`opinions for that matter? There are four other
`matters. We're going to address those.
` MR. FERNANDEZ: Objection. Form.
` A. My opinions on the invalidity of the
`'356 Patent with respect to the references
`cited within this document are all listed here
`in this declaration.
` Q. Thank you. You've signed this
`document; that's your signature at the end?
`Page 121.
` A. Yes, that is my signature.
` Q. Are you aware of any mistakes or
`errors in this document?
` A. I have found a few typographical
`errors but nothing that affects the substance
`or that makes a material difference to the
`rationale or the bases of the declaration.
` Q. That's fair. Now, in Paragraphs 10
`and 11, you identified that you -- materials
`that you have reviewed for this declaration in
`IPR2019-00047. That's a complete list of the
`materials that you've reviewed for this
`declaration?
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` P. FAY, PH.D.
` A. Sorry. Did you say Page 10?
` Q. Paragraphs 10 and 11.
` A. Oh, excuse me. I thought you said
`"page." Excuse me.
` The references and documents
`described in Paragraphs 10 and 11 are those on
`which I rely for my declaration.
` Q. My -- you substituted the word
`"rely" for "review."
` My question was: Did you review any
`other materials in connection with preparing
`this declaration?
` MR. FERNANDEZ: Objection. Form.
` A. I have reviewed and read a number of
`other documents and things, but I don't rely on
`them for this declaration.
` Q. What does that mean, you don't rely
`on them?
` A. The rationale -- as you see in my
`declaration, these are the ones that I cite to
`that I quote that I find show various aspects.
`Other things that I may have reviewed, I don't
`rely on for the purposes of this declaration.
` Q. What other materials did you review
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` P. FAY, PH.D.
`in connection with this declaration?
` A. I don't know that I have a list for
`you. I read a bunch of things.
` Q. Do you have them -- do you have a
`list somewhere, just not with you today?
` A. No. I'm not sure I have a list
`even.
` Q. So you don't know what other
`materials you've reviewed in connection with
`this declaration?
` A. In connection with this declaration,
`the content of this declaration comes from the
`references that I've listed here. Anything
`else was -- I found I did not need to rely upon
`to form this declaration.
` Q. You can set that aside for the
`moment.
` (INTEL Exhibit 1102 marked
` for identification.)
` Q. I'm handing you what's been marked
`as INTEL 1102. Do you recognize Exhibit INTEL
`1102 as the declaration you submitted in
`IPR2019-00048?
` A. Yes, this looks like the declaration
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` P. FAY, PH.D.
`that I submitted in response to that petition.
` Q. This document sets forth your
`opinions in their entirety concerning
`IPR2019-00048?
` MR. FERNANDEZ: Objection. Form.
` A. Yes. This document does set forth
`my opinions as related to that, the IPR that
`you quoted, the 00048, yes.
` Q. And that's your signature at the end
`on Page 116?
` A. Yes, that is my signature.
` Q. Other than typographical mistakes,
`are you aware of any mistakes or errors in this
`document?
` A. No, other than typographical errors,
`I am not aware of any material errors in this
`document.
` Q. In Paragraphs 10 and 11, you
`identify materials that you have reviewed in
`connection with this IPR. Is that a complete
`list of materials that you reviewed for this
`IPR?
` MR. FERNANDEZ: Objection. Form.
` A. Paragraphs ...
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` P. FAY, PH.D.
` The list here in Paragraphs 10 and
`11 are the documents on which I relied when I
`formulated this declaration.
` Q. And you reviewed other materials in
`connection with this declaration that are not
`listed here?
` A. It is -- yes. Yes, I did.
` Q. And as before, you don't have a list
`of those materials?
` A. I do not.
` Q. You can set that aside for the
`moment.
` (INTEL Exhibit 1202 marked
` for identification.)
` Q. Handing you what has been marked as
`INTEL 1202, do you recognize Exhibit INTEL 1202
`as the declaration you submitted in Case
`IPR2019-00049?
` A. Yes, I recognize this document as
`the declaration that I prepared in response to
`this IPR.
` Q. This document sets forth your
`opinions in their entirety concerning
`IPR2019-00049?
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` P. FAY, PH.D.
` MR. FERNANDEZ: Objection. Form.
` A. This document sets forth my opinions
`with respect to the IPRs 2019-00049 as it
`relates to the combination of Jeon, Xiong, and
`the combination also with the 3GPP Feasibility
`Study. And I guess I -- yes, yes.
` Q. And this is the complete set of your
`opinions with respect to those combinations
`that you identified?
` MR. FERNANDEZ: Objection. Form.
` A. This declaration sets forth my
`opinions with respect to these specific claims
`and those specific references.
` Q. And it's complete? You have no
`other opinions on these references outside of
`what you've identified in this document?
` MR. FERNANDEZ: Objection. Form.
` A. This document outlines the opinions
`I have as of this time for these matters.
` Q. That's your signature at the end on
`Page 123?
` A. Yes, that is my signature.
` Q. And in Paragraphs 10 and 11, you
`identify materials that you have reviewed for
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` P. FAY, PH.D.
`your declaration in IPR2019-00049. Are the
`materials that you have identified in
`Paragraph 10 and 11 a complete list of the
`materials that you reviewed for this
`declaration?
` MR. FERNANDEZ: Objection. Form.
` A. The documents listed in
`Paragraphs 10 and 11 are the -- is a complete
`list of the documents upon which I relied when
`I prepared this declaration.
` Q. And you've reviewed additional
`materials in preparing this declaration, but
`you don't have a list of those?
` A. I have reviewed additional
`materials, but I don't rely on any of them for
`purposes of this declaration.
` Q. And you don't have a list of those
`additional materials?
` A. No, I do not.
` (INTEL Exhibit 1302 marked
` for identification.)
` Q. Handing you what has been marked as
`Exhibit INTEL 1302, do you recognize Exhibit
`INTEL 1302 as the declaration you submitted in
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` P. FAY, PH.D.
`Case IPR2019-00128?
` A. Yes, I recognize this as the
`declaration that I filed in association with
`the IPR you quoted.
` Q. This document sets forth your
`opinions in their entirety concerning
`IPR2019-00128?
` MR. FERNANDEZ: Objection. Form.
` A. This document sets forth my opinions
`at the present time with respect to the '356
`Patent and its obviousness and how -- and how
`it's -- how should I say this? This document
`sets forth my opinions at the present time with
`respect to the anticipation and obviousness
`analysis that I did with respect to the claims
`listed here in view of Lee and the 3GPP
`Feasibility Study.
` Q. And that was done in connection with
`IPR2019-00128?
` A. Yes, that's correct.
` Q. And that's your signature at the end
`on Page 95?
` A. Yes, that is my signature.
` Q. Other than typographical errors, are
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`you aware of any mistakes or errors in this
`document?
` A. No. Other than those sorts of minor
`errors that don't affect the substance of the
`analysis, I'm not aware of any errors.
` Q. In Paragraphs 10 and 11, you
`identify materials that you reviewed in
`connection with this declaration. Are the
`materials identified in Paragraphs 10 and 11 a
`complete list of the materials that you
`reviewed in connection with this declaration?
` MR. FERNANDEZ: Objection. Form.
` A. The documents listed in Paragraphs
`10 and 11 are the full set of documents that I
`rely on for the declaration.
` Q. In connection with this declaration,
`you reviewed additional materials not
`identified in Paragraphs 10 and 11?
` A. I certainly read additional
`materials not listed here, but those references
`that are listed there are those on which I rely
`for the declaration.
` Q. And as before, you don't have a list
`of those additional materials that you
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`reviewed?
` A. I do not.
` (INTEL Exhibit 1402 marked
` for identification.)
` Q. Handing you what has been marked as
`INTEL 1402, do you recognize Exhibit INTEL 1402
`as the declaration you submitted in Case
`IPR2019-00129?
` A. Yes. I recognize this document as
`the declaration I submitted in relation to the
`IPR, Case IPR2019-00129.
` Q. And Exhibit INTEL 1402 sets forth
`your opinions in their entirety in connection
`with IPR2019-00129?
` MR. FERNANDEZ: Objection. Form.
` A. This declaration sets forth my
`opinions at the present time with respect to
`this IPR.
` Q. And that's your signature at the end
`on Page 103?
` A. That is my signature.
` Q. And other than typographical
`mistakes, are you aware of any other mistakes
`or errors in this document?
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` P. FAY, PH.D.
` A. I am not aware of any mistakes
`besides typographical-type errors.
` Q. In Paragraphs 10 and 11 of Exhibit
`INTEL 1402, you identify materials that you
`have reviewed for this declaration. Do
`Paragraphs 10 and 11 contain a complete list of
`materials that you reviewed for this
`declaration?
` MR. FERNANDEZ: Objection. Form.
` A. Paragraphs 10 and 11 list the
`documents that I reviewed and rely on for the
`declaration.
` Q. But you did review additional
`materials in connection with this declaration
`that are not identified in Paragraphs 10 and
`11?
` A. I did review additional materials,
`but the documents listed here in Paragraphs 10
`and 11 are those on which I rely for the
`declaration.
` Q. And you don't have a list of those
`additional materials, correct?
` A. I do not.
` Q. Now, in connection with these five
`
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` P. FAY, PH.D.
`declarations that we've just discussed, did
`anyone assist you in your research,
`investigation, or testing?
` MR. FERNANDEZ: Objection. Form.
` A. Could you repeat the question for
`me, please?
` Q. In connection with these
`declarations that you've prepared in these five
`IPRs, did anyone assist you in your research,
`investigation, or testing to prepare these
`declarations?
` MR. FERNANDEZ: Same objection.
` A. Yes.
` Q. Who assisted you in your research,
`investigation, or testing in preparing these
`declarations?
` A. I received assistance from the
`counsel for the petitioner.
` Q. Did anyone assist you in formulating
`your opinions in connection with these five
`IPRs?
` A. The opinions in these five -- that
`are delineated in these five declarations are
`my own.
`
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` P. FAY, PH.D.
` Q. Did anyone assist you in preparing
`these five declarations?
` A. I prepared these five declarations,
`but I did have assistance from staff at the
`petitioner's counsel.
` Q. You have in front of you Exhibit
`INTEL 1402, I think?
` A. Yes, that's correct.
` Q. In Paragraph 56 of that declaration,
`you identified the level of ordinary skill in
`the art, correct?
` A. Yes, that's right. At Paragraph 56,
`I identify the level of ordinary skill in the
`art.
` Q. And one of the things you said in
`that paragraph was a person of ordinary skill
`in the art at the time of the alleged invention
`would have had experience with the structure
`and operation of RF transceivers and related
`structures, correct?
` MR. FERNANDEZ: Objection. Form.
` A. That's not quite exactly what I
`said.
` Q. That was one of the things you said.
`
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` P. FAY, PH.D.
`But you want to go ahead and correct me and
`tell me what you did say there.
` MR. FERNANDEZ: Objection. Form.
` A. Paragraph 56 reads: A person of
`ordinary skill in the art at the time of the
`alleged invention would have had at least an
`M.S. degree in electrical engineering or
`equivalent experience and would have had at
`least 2 years of experience with the structure
`and operation of RF transceivers and related
`structures or the equivalent.
` Q. Thank you.
` Dr. Fay, do you consider yourself an
`expert in the structure and operation of RF
`transceivers?
` A. Yes.
` Q. Are you familiar with LTE wireless
`systems?
` A. I am familiar with some aspects of
`LTE wireless systems, yes.
` Q. What aspects of LTE wireless systems
`are you familiar with?
` A. I am familiar with the hardware, the
`supporting LTE communications systems, and in
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` P. FAY, PH.D.
`particular in receivers.
` Q. Do you consider yourself an expert
`in the structure and operation of LTE wireless
`systems?
` A. That's very vague.
` Q. And why is that vague?
` A. "Systems" is a very vague word.
` Q. Do you consider yourself an expert
`in the structure and operation of LTE wireless
`communications?
` A. I don't understand the question.
` Q. You said you were familiar with
`hardware, in particular receivers, in LTE
`systems. Is that right?
` A. I am familiar with the hardware and,
`in particular, receivers for wireless
`communications such as LTE, that's right.
` Q. Do you consider yourself an expert
`in the hardware and, in particular, receivers
`of wireless communications such as LTE?
` A. Yes.
` Q. Are there any other aspects of LTE
`wireless communications that you consider
`yourself an expert in?
`
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` P. FAY, PH.D.
` MR. FERNANDEZ: Objection. Form.
` A. As I sit here today, that sounds --
`that hardware and -- hardware and, in
`particular, receivers for wireless
`communications I think is an accurate
`description of my expertise, my relevant
`expertise at least for the '356 Patent. I'd
`have to think more about whether there are
`other areas that are relevant to LTE where I
`have expertise.
` Q. Are you familiar with carrier
`aggregation in LTE?
` MR. FERNANDEZ: Object to form.
` A. I am familiar with carrier
`aggregation.
` Q. Do you consider yourself an expert
`in carrier aggregation with respect to LTE
`wireless communications?
` A. Yes. I consider myself an expert
`with respect to carrier aggregation.
` Q. Do you have any research experience
`directed to carrier aggregation?
` MR. FERNANDEZ: Objection. Form.
` A. I have considerable research
`
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` P. FAY, PH.D.
`experience and publications in devices and
`circuits devoted to receivers and applicable to
`receivers in wireless communication systems.
`While my -- carrier aggregation has not been a
`focus of any particular paper, the devices and
`other research that I have done is applicable
`to carrier-aggregated systems.
` Q. Do you have any teaching experience
`directed to carrier aggregation?
` MR. FERNANDEZ: Objection to form.
` A. I teach two circuit design courses
`that, while we don't explicitly cover carrier
`aggregation, we do cover at the undergraduate
`level circuit design techniques for designing
`low-noise amplifiers that would be perfectly
`suitable for carrier-aggregated systems.
` Q. Have you authored any publications
`that explicitly reference carrier aggregation?
` A. I would have to review them.
`Sitting here today, I'm not certain if any of
`them include that or not.
` Q. Prior to being retained to offer
`opinions relating to the '356 Patent, had you
`heard the term "carrier aggregation"?
`
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`Qualcomm 2014, p. 25
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` P. FAY, PH.D.
` A. Yeah, I believe I had.
` Q. And when would -- when did you first
`hear the term carrier aggregation?
` A. I'm not certain.
` Q. Can you say approximately?
` A. Not with any certainty, no.
` (INTEL Exhibit 1001 marked
` for identification.)
` Q. Handing you what's been marked as
`INTEL 1001. Do you recognize INTEL 1001 as the
`'356 Patent?
` A. Yes, I recognize this as the '356
`Patent.
` Q. And you reviewed and considered the
`'356 Patent during your analysis?
` A. Yes, I reviewed and considered the
`'356 Patent for my analysis.
` Q. And you reviewed and considered the
`'356 Patent's prosecution history during your
`analysis as well?
` A. Yes. I did review the prosecution
`history of the '356 Patent during the course of
`my analysis.
` Q. I'd like to direct your attention to
`
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` P. FAY, PH.D.
`Figure 6A of the '356 Patent. Let me know when
`you're there.
` A. Yes, I'm there.
` Q. Figure 6A shows a number of things.
`But one of the things it shows is two amplifier
`stages identified as 650a and 650b, correct?
` A. Yes, the patent identifies 650a and
`650b as amplifier stages.
` Q. And in particular on the figure,
`650a is identified as Amplifier Stage 1 and
`650b is identified as Amplifier Stage 2,
`correct?
` A. I don't recall them making those
`labels. I don't recall them being labeled as
`Stage 1 and Stage 2.
` Q. If you look at Figure 6A, do you
`agree with me that --
` A. Oh, I'm sorry.
` Q. -- figure shows Amplifier Stage 1 as
`650a and Amplifier Stage 2 as 650b?
` A. Yes, on the figure. I now see what
`you're pointing to, yes. Yeah, Amplifier Stage
`1 in the Figure 6A is identified as 650a, and
`650b is identified as Amplifier Stage 2.
`
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` P. FAY, PH.D.
` Q. And Amplifier Stage 650a amplifies
`an RF input signal and provides a first output
`signal -- a first output RF signal, I'm sorry,
`to a Load Circuit 690a, correct?
` A. Not in all cases, no.
` Q. In what cases does it provide an
`output signal to Load Circuit 690a?
` A. I'm sorry. I didn't catch your
`question exactly. Could you rephrase it or
`repeat it for me?
` Q. You had responded "Not in all
`cases." And my question was: In what cases
`does Amplifier Stage 650a provide a first
`output RF signal to Load Circuit 690a?
` A. The Amplifier Stage 650a provides an
`output signal to Load Circuit 690a when an RF
`input signal is provided and when the amplifier
`stage is enabled.
` Q. And with respect to Amplifier
`Stage 2, when it's enabled and when an RF input
`signal is provided, it provides an output
`signal -- an output RF signal to load circuit
`690b, correct?
` A. Your question was long enough, could
`
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`Qualcomm 2014, p. 28
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` P. FAY, PH.D.
`you just repeat it for me to make sure I have
`it correctly?
` Q. Sure.
` Talking about Amplifier Stage 2.
`And Amplifier Stage 2 amplifies an RF input
`signal and provides an output RF signal to load
`circuit 690b when it's enabled, correct?
` A. Amplifier -- Amplifier Stage 2
`provides an output signal to Load Circuit 690b
`in response to the RF input signal when
`Amplifier Stage 2 605b is enabled.
` Q. According to the patent -- and I'm
`looking at column 8, row 12. According to the
`patent, Amplifier Stage 650a may be
`independently enable or disabled via switch
`658a. Correct?
` A. Could you repeat your question for
`me, please?
` Q. According to the patent, Amplifier
`Stage 650a may be independently enabled or
`disabled via switch 658a?
` A. In the particular embodiment shown
`in Figure 6A, they show switch 658a configuring
`the enablement or disablement of Amplifier
`
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` P. FAY, PH.D.
`Stage 650a.
` Q. And more specifically, the patent
`says that that switch may be used to
`independently enable or disable Amplifier
`Stage 650a?
` A. Yes, that switch may independently
`enable or disable that Amplifier Stage 650a.
` Q. And switch 658b may be used to
`independently enable or disable Amplifier
`Stage 650b?
` A. Was there a question?
` Q. Yes.
` And do you agree that switch 658b
`may be used to independently enable or disable
`amplifier stage 650b?
` A. The patent says it a little bit
`differently. But my interpretation is that
`switch 658b may be used to independently enable
`or disable Amplifier Stage 658b.
` Q. Amplifier Stage 650b, correct?
` A. Did I misspeak? 650b is what I
`meant to say for amplifiers, for the amplifier
`stage.
` Q. Now, if you turn to claim 1, which
`
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` P. FAY, PH.D.
`is in column 20, and I'm looking at the first
`limitation that starts at Line 44, and it
`recites, and I'm going to read just a part of
`that first limitation it recites -- claim 1 of
`the '356 patent recites: A first amplifier
`stage configured to be independently enabled or
`disabled, comma, the first amplifier stage
`further configured to receive and amplify an
`input radio frequency, paren, RF, close paren,
`signal and provide a first output RF signal to
`a first load circuit when the first amplifier
`stage is enabled.
` Did I read that first part of that
`limitation correctly?
` A. I believe you read that first part
`of that limitation correctly.
` Q. You offered opinions in your
`declarations about the prior art with respect
`to that portion of the limitation, correct?
` MR. FERNANDEZ: Objection. Form.
` A. Yes. In my declaration, I offer --
`I show where prior art discloses that
`limitation.
` Q. For the opinions that you offered in
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