UNITED STATES DISTRICT COURT
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`SOUTHERN DISTRICT OF CALIFORNIA
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`Page 1
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`QUALCOMM INCORPORATED, )
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`)
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`Plaintiff, ) CASE NO.
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`)
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`vs. ) 3:17-CV-1375-DMS-MDD
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`APPLE INCORPORATED, )
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`)
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`Defendant. )
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`)
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`_________________________)
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`)
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`AND RELATED COUNTERCLAIM )
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`_________________________)
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`VIDEOTAPE DEPOSITION OF
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`VINCENT J. MOONEY, III, PH.D.
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`Atlanta, Georgia
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`Thursday, August 2, 2018
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`Reported by:
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`Judith Leitz Moran, CCR, RPR, RSA
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`JOB NO.: 145806
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`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm, Ex. 1012, Page 1
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`SOUTHERN DISTRICT OF CALIFORNIA
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`Page 1
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`QUALCOMM INCORPORATED, )
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`)
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`Plaintiff, ) CASE NO.
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`)
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`vs. ) 3:17-CV-1375-DMS-MDD
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`APPLE INCORPORATED, )
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`)
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`Defendant. )
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`)
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`_________________________)
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`)
`
`AND RELATED COUNTERCLAIM )
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`_________________________)
`
`VIDEOTAPE DEPOSITION OF
`
`VINCENT J. MOONEY, III, PH.D.
`
`Atlanta, Georgia
`
`Thursday, August 2, 2018
`
`Reported by:
`
`Judith Leitz Moran, CCR, RPR, RSA
`
`JOB NO.: 145806
`
`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm, Ex. 1012, Page 1
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`take a server farm for a search engine company, we
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`can think of some names, and that server farm would
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`choose the high frequency, high performance medium
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`power consumption option because they want the
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`fastest searches that are possible and they'll have
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`more complicated packages.
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` The low power option will have lower
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`clock speeds, lower performance, but would be more
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`appropriate for a battery power device.
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` And the fundamental difference, for
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`example, would be in the threshold voltages of the
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`transistors. So for the server one you'd have
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`lower threshold voltages with higher leakage but
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`higher performance. In the low power chips you'd
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`have slightly higher threshold voltages but much
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`lower leakage and that would be to lower overall
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`power.
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` Q The '812 patent -- or excuse me -- the de
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`Cesare family of patents talks about having
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`components in different performance domains; is
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`that correct?
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` A Yes, it talks about different performance
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`domains.
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` Q Is it fair to describe that as having
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`different portions of the chips that are subdivided
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`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm, Ex. 1012, Page 2
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`for performance purposes?
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`A For performance purposes you would take
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`the overall chip and define power domains in
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`portions of the chip.
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`Q Was that known to persons of skill in the
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`art before the de Cesare family? In other words,
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`was it already known you didn't have to run every
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`part of the chip at the same performance level
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`before the de Cesare family?
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`A Prior to the de Cesare patent the idea of
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`having different parts of the chip with different
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`clock voltage frequencies, different performance
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`characteristics was known.
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`Q Was there also before the de Cesare
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`family hardware and/or software that could be used
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`to transition the performance states of different
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`performance domains?
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`A Yes, there was hardware and software to
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`design microchips and have different performance
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`domains with different levels.
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`Q Can you think of any specific examples
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`prior to the de Cesare family of that being the
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`case, having hardware and/or software that changes
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`the performance states of different components on a
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`system on a chip?
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`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm, Ex. 1012, Page 3
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` A So you're asking can I think of examples
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`of hardware and software designs that controlled
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`performance domains.
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` MR. GREEN: Object to the form.
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` A So, for example, one that I looked at in
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`the 2000s was the Intel StrongARM processor and
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`there were ways to have the memory go faster or
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`slower, have different frequencies and voltages for
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`the memory versus the processor.
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`BY MR. DAVIS:
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` Q In the Intel StrongARM design, what was
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`it that caused the memory to go faster or slower
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`based upon the processor performance?
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` A In the Intel StrongARM processors the
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`software would decide to move either the processor
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`itself or the memory system to a different
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`frequency and voltage.
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` That decision would be implemented by --
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`well, the software would make the decision, would
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`send information down and eventually you'd have
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`hardware gates that would actually, for example,
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`connect a new voltage to the power line or connect
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`a different frequency to the memory or to the
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`processor.
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` The broad name of the technology was
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`Qualcomm, Ex. 1012, Page 4
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`called dynamic frequency and voltage scaling.
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`Q When you say software would cause it, is
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`this operating system software or what exactly do
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`you mean by the software?
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`A The software that would control the power
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`could be the operating system or in the case of an
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`embedded system without a full fledged operating
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`system you could have application software specific
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`to that embedded system making -- making the
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`decision.
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`MR. GREEN: Is it okay if we take a
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`break? I need to run to the restroom and I've lost
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`my real-time feed.
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`MR. DAVIS: Oh, yeah, yeah, that's fine,
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`we can take a break.
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`MR. GREEN: Thank you.
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`VIDEO TECHNICIAN: The time is 10:12 a.m.
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`We're now off the record.
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`(Recess taken.)
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`VIDEO TECHNICIAN: The time is 10:19 a.m.
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`We're back on the record.
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`BY MR. DAVIS:
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`Q Welcome back, Dr. Mooney.
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`A Thank you.
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`Q If you could look at Mooney Exhibit 3
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`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm, Ex. 1012, Page 5
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`when transitions would occur between sleep states
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`and wake states.
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` Q That could also be true for other
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`components like memory, in the state of memory?
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` A Yes, you can have different power states
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`for memory, including sleep and wake states.
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` Q And it's your opinion that a person of
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`skill in the art before the de Cesare patents would
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`know that they can implement these types of state
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`machines either in hardware or in software?
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` MR. GREEN: Object to the form.
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`BY MR. DAVIS:
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` Q Go ahead.
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` A Yes, anyone skilled in the state of the
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`art of electrical engineering and microchip design
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`would know that finite state machines and state
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`transitions can be programmed in software or in
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`hardware.
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` Q The de Cesare patents talk about a power
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`management unit. What's your understanding of --
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`well, let me ask this to start with.
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` Did power management unit exist --
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`management units exist before the de Cesare
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`patents?
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` A Yes, power management units existed
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`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm, Ex. 1012, Page 6
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`before the de Cesare patent.
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` Q What is a power management unit in your
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`opinion as used in the claims?
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` A A power management unit is a section or
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`area on a microchip that controls both the
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`performance and power configurations as well as the
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`transitions between the different configurations at
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`run time.
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` And just -- just for clarity I would like
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`to specify that I hope I said hardware and/or
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`software. And if I didn't that's what I meant to
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`say.
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` Q So is it your opinion that a -- well, let
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`me break down your definition here.
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` When you say section or area on a
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`microchip, what do you mean by that?
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` A There's a defined part of the transistors
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`on a chip that are dedicated to the power
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`management unit function.
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` Q And when you say power management
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`function, what do you mean by that term?
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` A The setting of the power and performance
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`characteristics and transitioning of those
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`characteristics at run time, such as voltage and
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`free -- clock frequency.
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`Qualcomm, Ex. 1012, Page 7
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` Q What do you mean by run time?
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` A At run time I mean during the active use
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`as opposed to boot time when the device is turned
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`on, as opposed to power on or set up time.
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` I mean, the power management may also be
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`part of setting up the initial configuration, but
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`it's used throughout the lifetime of the usage
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`scenarios of a microchip.
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` Q This definition that you just gave, is
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`that the plain and ordinary meaning of power
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`management unit according to a person of skill in
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`the art or is that a particularized meaning in the
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`context of the 8-1 -- or the de Cesare patents?
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` A It is my professional opinion that the
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`definition I gave is a plain and ordinary meaning
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`as understood by an ordinary skilled person in the
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`state of the art at the time of the patent.
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` Q Do you have any extrinsic or other
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`support on a -- strike that.
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` Did you cite in your claim construction
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`declaration any extrinsic or other support for your
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`opinion that that would be the plain and ordinary
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`meaning as recognized by persons skilled in the
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`art?
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` A The main citation I have is my own resume
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`Qualcomm, Ex. 1012, Page 8
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`for a lot of person of ordinary skill in the art in
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`the -- in the declaration that I provided on July
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`20th.
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` Q By your resume, you mean your prior
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`experience and your publications and research, and
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`so on and so forth?
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` A Yes. And attending research meetings
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`with DARPA. You know, all of the research and
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`teaching I've done. And the people I've interacted
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`with.
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` Q But your declaration doesn't go forth and
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`particularly analyze any of those particular
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`experiences you've had or papers or et cetera to
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`explain why those demonstrate that that's the
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`proper definition of a power management unit, does
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`it?
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` MR. GREEN: Object to the form.
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` MR. DAVIS: Let me rephrase it because of
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`Mr. Green's objection.
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`BY MR. DAVIS:
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` Q Yeah, I know you've attached your CV to
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`-- your resume to your declaration, but the body of
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`your declaration discussing your claim construction
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`analysis, that doesn't go through the papers and
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`your past experience, and so on and so forth, and
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`Qualcomm, Ex. 1012, Page 9
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`your resume and otherwise, and explain how that
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`supports your opinion about the definition of a
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`power management unit, does it?
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` MR. GREEN: Same objection, but you may
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`answer it if you understand.
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` A I did not cite specific publications of
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`mine or those I've been involved with in the
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`declaration.
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`BY MR. DAVIS:
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` Q And you didn't discuss how your past
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`experiences, any particular past experiences lead
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`to the conclusion that that's the proper definition
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`of a power management unit, did you?
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` MR. GREEN: Same objection.
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` A I did not go into specifics of my past
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`experiences with regard to power management units.
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`For example, I didn't refer to my book Powerware
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`Computing that's under my published books.
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`Actually, it's a book I was an editor of a chapter.
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` I did not refer to -- I was editor of
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`VLSI-SoC, From Systems to Chips in 2006.
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` THE COURT REPORTER: I'm sorry, of what?
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` THE WITNESS: VLSI-SoC, From Systems to
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`Chips. I was an editor of this book that was
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`published 2006.
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`Qualcomm, Ex. 1012, Page 10
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` A But, you know, I did not go through those
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`books and put references to those in my
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`declaration.
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`BY MR. DAVIS:
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` Q Or cite any specific parts of those books
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`or publications, right?
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` A I did not cite parts of those books or
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`publications.
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` Q You testified that in your opinion a
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`power management unit can be hardware and/or
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`software. Is it your opinion that a power
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`management unit can be only software?
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` A It is my professional opinion that a
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`power management unit cannot only be software
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`because the eventual clock signaling, gate
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`signaling to the components that are being
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`controlled would involve boolean logic hardware.
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` So there will always be a small piece of
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`boolean logic in any power management unit, it
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`would not be zero.
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` Q So is it true then -- and I'm looking at
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`Page 10 of your declaration where you have the box,
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`you see at the top of Page 10 there's the box that
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`says Apple's Proposed Construction?
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` A Yes.
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`Qualcomm, Ex. 1012, Page 11
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` Q Do you see that?
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` And you say "hardware and/or software."
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`Is that actually incorrect, it should be hardware
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`or hardware and software based upon your testimony
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`just now that there at least has to be some
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`hardware as part of a power management unit?
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` A If you want to -- if -- I would say we're
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`splitting hairs here a bit. The power management
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`unit in its interface, the interface is going to
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`have hardware, probably boolean logic gates.
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` Could somebody argue that I'm going to
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`define an interface and have that block not be part
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`of the power management unit, I think it's
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`splitting hairs, but they could potentially try to
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`do that.
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` So I would say that there's a variety of
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`hardware/software combinations and you can make
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`them very large amounts of each and that's what I
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`intended by hardware and/or software.
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` Q So in your opinion there can be different
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`proportions or amounts of hardware and software and
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`it could be you have a large portion of hardware
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`and very little software or very large portion of
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`software and only a small amount of hardware?
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` A Yes, that's -- that's my intention behind
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`Qualcomm, Ex. 1012, Page 12
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`hardware and/or software the proportions can change
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`by very large amounts.
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` Q But it's also your testimony that you
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`could have a power management unit that is only
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`hardware?
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` A Absol -- you definitely can have a power
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`management unit that's exclusively hardware. It
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`wouldn't be programmable without -- you know, it
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`wouldn't be software programmable.
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` Q How do I determine as a person -- well,
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`let me ask you this: Page 5 of your report in
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`Paragraph 18. You're discussing certain tenets of
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`claim construction; is that right?
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` A In Paragraph 18 on Page 5 I discuss claim
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`construction and definiteness.
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` Q All right. In the last sentence you say:
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`Instead, the claims, when read in light of the
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`intrinsic record, must provide objective boundaries
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`for those of skill in the art. You wrote that in
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`your report?
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` A Yes, I wrote in my report that the
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`claims, when read in light of intrinsic record,
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`must provide objective boundaries --
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` Q Okay. So --
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` A -- for those of skill in the art.
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`Qualcomm, Ex. 1012, Page 13
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` Q So what's your -- does objective
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`boundaries, that essentially means it can't be in
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`the eye of the beholder, it can't be subjective,
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`there has to be some reasonable understanding?
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` Well, let me strike that.
`
` What's your understanding of objective
`
`boundaries as you used it in that sentence?
`
` A The objective boundaries for those of
`
`skill in the art is related to U.S.C., I believe
`
`it's 102, and specifically in the United States
`
`Patent Code just in layman's terms the claims
`
`should specify what is in the scope of the patent
`
`as well as what's not in the scope of the patent.
`
` Use of vague and ambiguous terms which
`
`don't lead to specific implementations would fall
`
`under indefiniteness.
`
` The way you transition or the way you
`
`understand the words in a claims and how they
`
`provide those objective boundaries is evaluated
`
`under the condition of a person of ordinary skill
`
`in the art reading those claims and with the
`
`knowledge at the time of the patent.
`
` Q So at the time of this patent in April
`
`7th, 2010, how do I know objectively what the
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`boundaries are of the power management unit? In
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`Qualcomm, Ex. 1012, Page 14
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`other words, you said it could either be purely
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`hardware or some combination of hardware and
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`software. So how do I determine what goes inside
`
`and is part of the power management unit and what
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`is not?
`
` A So your question as I understand it
`
`relates to the claims of the '812 patent and I
`
`believe the most important claim, the claim we're
`
`looking at is claim 8 and how would somebody
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`skilled in the art interpret claim 8.
`
` And there were terms used in claim 8
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`including power management unit. And your question
`
`is how would somebody skilled in the state of the
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`art distinguish hardware versus software in their
`
`implementation of the power management unit.
`
` I would say that the implementation of
`
`the power management unit, the parts that are in
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`hardware versus software have flexibility as long
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`as you fulfill the conditions of claim 8.
`
` So I think that somebody skilled in the
`
`state of the art would realize there are parts that
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`can be implemented both in hardware or in software
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`and either way they would fall under the scope of
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`what a power management unit is.
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` Q Well, under your definition or at least
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`Qualcomm, Ex. 1012, Page 15
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`Apple's proposed definition, which I think you've
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`indicated you may disagree with a little bit of
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`hardware and/or software if it can't be purely
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`software, how do I determine in the context of all
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`the different hardware as you called it section or
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`area of the microchip, which areas of that
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`microchip are part of the power management unit and
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`which areas of the microchip are separate from the
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`power management?
`
` A Okay. So the question is how do we
`
`determine what parts are in the power management
`
`unit and which are outside the power management
`
`unit.
`
` Q Yes, sir.
`
` A May I refer to Figure 1 --
`
` Q Yes.
`
` A -- in the patent?
`
` In Figure 1 in the '812 patent there is a
`
`box PMU 28.
`
` Q Yes.
`
` A And that box describes power management
`
`functionality. This box can be mapped to a
`
`specific embodiment of a chip and an embodiment of
`
`the patent and the patent teaches ways to implement
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`PMU 28 and what it does and parts of that may be
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`Qualcomm, Ex. 1012, Page 16
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`hardware or software. What determines that it
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`falls under the power management unit is the
`
`functionality.
`
` Q Let me maybe ask it -- this a different
`
`way. If you go back and look at Apple's proposed
`
`construction, it's hardware and/or software that
`
`causes a performance domain to transition to a
`
`performance state. Did I read that correctly?
`
` A Yes, you read that correctly.
`
` Q And at least under Apple's proposed
`
`construction because it's hardware and/or software
`
`that pretty much means anything that causes a
`
`performance domain to transition to a -- and I
`
`understand that to mean a different performance
`
`state; is that fair?
`
` A I would not use the phrase "anything."
`
` Q So what's excluded from hardware and/or
`
`software? In other words, a transistor is
`
`hardware, right?
`
` MR. GREEN: Object to the form of the
`
`question.
`
`BY MR. DAVIS:
`
` Q What is excluded from hardware and/or
`
`software?
`
` MR. GREEN: Same objection. You may
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`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm, Ex. 1012, Page 17
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` A Yes, I've opined on what is a performance
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`domain.
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` Q And you said that a performance domain,
`
`this is at Page 7 of your report, is "one or more
`
`components that may be controlled as a unit or
`
`independently for performance configuration
`
`purposes"; is that correct? That's Apple's
`
`proposed construction?
`
` A Yes, the proposed construction is "one or
`
`more components that may be controlled as a unit or
`
`independently for performance configuration
`
`purposes."
`
` Q And in this definition because the
`
`proposed construction says controlled is a unit or
`
`independently, that really just means controlled,
`
`right, because there's no other way to control
`
`something other than as a unit or independently,
`
`correct?
`
` MR. GREEN: Object to the form.
`
`BY MR. DAVIS:
`
` Q Did you understand my question?
`
` A I do not understand the exact question.
`
` Q Is there any way to control a component
`
`other than as a unit or independently with other
`
`components?
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`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm, Ex. 1012, Page 18
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` A The question is, is there any way to
`
`control a component other than as a unit or
`
`independently.
`
` Yeah, the components may be controlled in
`
`subgroups. If you take the definition of unit as
`
`you can define it in any different ways then you
`
`can have different subgroupings that are
`
`controlled.
`
` I believe you can also have components
`
`that are not controlled so you can leave like an
`
`always on section.
`
` Q Okay.
`
` A And that would not be controlled at all,
`
`but it might -- it might be a necessary part of the
`
`functionality of a domain.
`
` Q But for the components that are
`
`controlled for power management purposes, there's
`
`no other -- there's no way to control them other
`
`than either as a unit or independently; isn't that
`
`true?
`
` A Yeah, right now I cannot think of other
`
`ways to control it other than independently or in
`
`some type of a grouping you control it.
`
` Q So doesn't Apple's proposed construction
`
`or performance domain then essentially reduce down
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`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm, Ex. 1012, Page 19
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`to one or more units that are controlled for
`
`performance configuration purposes because there's
`
`no other way to do it other than as a unit or
`
`independently --
`
` MR. GREEN: Object to the form.
`
`BY MR. DAVIS:
`
` Q -- at least in your opinion?
`
` MR. GREEN: Object to the form.
`
` A What I would say is that from the point
`
`of view of the power engineering during the chip
`
`design, the power engineer wants maximum
`
`flexibility to control clock -- clock frequency,
`
`voltage scaling, memory configurations. Each of
`
`those variables to the extent that the silicone
`
`supports it I would like to -- as a power engineer
`
`I'd like to define those performance domains as
`
`flexibly as possible based on the application
`
`constraints.
`
` So, yes, they are configurable, they can
`
`be defined after the silicone is fabricated. Once
`
`defined and put into registers and into
`
`programmable hardware and into software, then those
`
`are fixed at run time.
`
` Q I appreciate your answer, but I don't
`
`think you answered my question.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Qualcomm, Ex. 1012, Page 20
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` So my question is, because for the
`
`control -- components that are controlled for power
`
`management purposes, because you've said you can't
`
`think of any way to control those components other
`
`than as a unit or independently, isn't it true that
`
`Apple's proposed construction then reduces down to
`
`one or more components that may be controlled for
`
`performance configuration purposes?
`
` MR. GREEN: Object to the form.
`
` A I would not phrase it as one or more
`
`units that can be controlled for performance
`
`purposes because that leaves out the part that
`
`there can be additional performance domains where
`
`those independent components are -- have say a
`
`different clock frequency or different voltage.
`
`BY MR. DAVIS:
`
` Q So you're saying Apple's proposed
`
`construction is incomplete?
`
` A No, on the contrary I'm saying it's
`
`complete.
`
` Q Well, then, I'm still not sure I
`
`understand your answer so I'm going to ask the
`
`question again, and I apologize for just not
`
`getting through to me.
`
` But since in your opinion for performance
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`TSG Reporting - Worldwide 877-702-9580
`
`Qualcomm, Ex. 1012, Page 21
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`purposes components can only be controlled either
`
`as a unit or independently, I think we agree on
`
`that, correct?
`
` A I'd agree that components can be
`
`controlled as a unit or independently.
`
` Q And you haven't thought of any other way
`
`to perform control, is what I'm --
`
` A I mentioned not controlling.
`
` Q Not controlling.
`
` A Yeah.
`
` Q But I'm saying for the ones that are
`
`controlled, for the components that are controlled,
`
`they have to either be controlled as a unit or
`
`independently, correct?
`
` A They can be controlled as a unit or
`
`independently, yes.
`
` Q Okay. So because the components that are
`
`controlled have to be controlled either as a unit
`
`or independently, isn't Apple's proposed
`
`construction then essentially "one or more
`
`components that may be controlled for performance
`
`configuration purposes"?
`
` MR. GREEN: Object to the form. You may
`
`answer.
`
` A So I understand the question to be is not
`
`TSG Reporting - Worldwide 877-702-9580
`
`Qualcomm, Ex. 1012, Page 22
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`the statement "one or more components that may be
`
`controlled as a unit or independently for
`
`performance configuration purposes" equivalent to
`
`"one or more units that may be controlled for
`
`performance configuration purposes."
`
`BY MR. DAVIS:
`
` Q One or more components that may be
`
`controlled for performance configuration purposes?
`
` A Agreed. So the reason I want to keep in
`
`in my opinion "as a unit or independently" is for
`
`configurability of different types of performance
`
`domains even over the same set of components using
`
`the independent control in the sentence.
`
` Q Well, I understand that maybe you want to
`
`include that, but I'm just asking what the
`
`difference is. What's the difference between a
`
`definition that says "one or more components that
`
`may be controlled as a unit or independently for
`
`performance configuration purposes" and "one or
`
`more components that may be controlled for
`
`performance configuration purposes"?
`
` A The difference as I see it is that
`
`omitting the "as a unit or independently" from the
`
`statement allows you to say that, well, if I have
`
`three components they must always be controlled
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`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm, Ex. 1012, Page 23
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`only as a unit, they cannot be controlled with
`
`different values in different performance domains.
`
` So leaving independently allows for those
`
`three components to be controlled differently in
`
`different performance domains.
`
` VIDEO TECHNICIAN: You got five minutes.
`
` MR. DAVIS: Okay. We can take a break
`
`now if that works.
`
` MR. GREEN: Sure.
`
` VIDEO TECHNICIAN: This is the end of
`
`Media 1 in the deposition of Dr. Vincent Mooney.
`
`The time is the 11:06 a.m. We're now off the
`
`record.
`
` (Recess taken.)
`
` VIDEO TECHNICIAN: This is the beginning
`
`of Media 2 in the deposition of Dr. Vincent Mooney.
`
`The time is 11:18 a.m. We're back on the record.
`
`BY MR. DAVIS:
`
` Q Welcome back, Dr. Mooney.
`
` A Thank you.
`
` Q When we left off we were talking about
`
`the definition of performance domain.
`
` In Paragraph 27 of your report for the
`
`proposition you cite '812 Patent at column 4, lines
`
`20 to 25; is that right?
`
`TSG Reporting - Worldwide 877-702-9580
`
`Qualcomm, Ex. 1012, Page 24
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` A I cited in Page 8 of my declaration the
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`'812 patent, column 4, lines 20 to 25.
`
` Q And you cite that portion of the patent
`
`for the proposition that components in a
`
`performance domain may be controlled as a unit or
`
`independently; is that right?
`
` A I cited the -- that section of the patent
`
`to point out that the patent talks about -- yes,
`
`both as a unit and independently from each other
`
`components being controlled in performance domains.
`
` Q Okay. And you said something important
`
`here, you said performance domains, right, plural?
`
` A Yes.
`
` Q Okay. My question is, how does the
`
`portion of the '812 patent that you cite here,
`
`columns 4, lines 20 to 25, support the proposition,
`
`if at all, that components within a single
`
`performance domain can be controlled independently?
`
` Actually, let me ask it. Strike that.
`
`I'll ask a different question.
`
` The first sentence that you cite here
`
`from the patent says: The components that form a
`
`performance domain may transition together from one
`
`performance state to another performance state.
`
`Did I read that correctly?
`
`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm, Ex. 1012, Page 25
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` A Yes, you read that correctly.
`
` Q So that's talking about all components
`
`within one performance domain transitioning
`
`together; is that right?
`
` A Yes, it talks about all components within
`
`a performance domain transitioning together.
`
` Q Okay. And then the patent goes on to
`
`contrast by saying: On the other hand, components
`
`in different performance domains may be independent
`
`of each other, at least from the standpoint of
`
`hardware, and may have independently-determined
`
`performance states. Did I read that correctly?
`
` A You read that correctly.
`
` Q So that sentence is talking about the
`
`fact that at least from the standpoint of hardware,
`
`the hardware can signal one performance domain to
`
`do a transition and then later or independently
`
`send a signal, a different performance domain, to
`
`do a different transition, correct?
`
` A The one performance domain and associated
`
`set of components may be transitioned to a set of
`
`new values in a new performance domain.
`
` I'm sorry, can we -- can you repeat the
`
`question.
`
` Q Yeah. So in that second sentence it's
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`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm, Ex. 1012, Page 26
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`talking about the fact that the hardware can signal
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`performance domain, let's say A and its components
`
`to go to one state, and then independently signal
`
`components B in performance domain B to go to a
`
`different state, right, independently?
`
` A The signals, the low level signals that
`
`control the performance characteristics of a
`
`performance domain can change and indicate
`
`different performance levels in different
`
`performance domains.
`
` Am I understanding your question?
`
` Q I think so.
`
` A Okay.
`
` Q So that second sentence is talking about
`
`two different performance domains, right?
`
` MR. GREEN: Object to the form.
`
`BY MR. DAVIS:
`
` Q It says "different performance domains."
`
` A The second sentence talks about
`
`components in different performan
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