CASE NO.
`IPR2019-01526
`
`PATENT NO.
`6,895,519 B2
`
`1
`UNITED STATES PATENT AND TRADEMARK OFFICE
`2
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`3
`---oOo---
`4 ADVANCED MICRO DEVICES, INC.,
`5
`Petitioner,
`6 v.
`7 AQUILA INNOVATIONS, INC.,
`Patent Owner.
`8
`9 ______________________________/
`10
`11
`12
`13
`14
`15
`16
`17
`18 Stenographically Reported By:
`19 LUCY CARRILLO-GRUBBS, CSR #6766, RPR-RMR-CRR-CCRR
`20
`21
`22
`23
`24
`25
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`UCCELLI & ASSOCIATES, INC.
`1243 Mission Road
`South San Francisco, CA 94080
`www.UccelliAssociates.com
`E-mail: info@UccelliAssociates.com
`Tel: 650.952.0774 Fax: 650.952.8688
`
`VIDEOCONFERENCE DEPOSITION OF DAVID ALBONESI, PhD
`THURSDAY, MAY 21, 2020
`
`AQUILA - Ex. 2012
`
`
`IPR2019-01526
`
`PATENT NO.
`6,895,519 B2
`
`1
`UNITED STATES PATENT AND TRADEMARK OFFICE
`2
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`3
`---oOo---
`4 ADVANCED MICRO DEVICES, INC.,
`5
`Petitioner,
`6 v.
`7 AQUILA INNOVATIONS, INC.,
`Patent Owner.
`8
`9 ______________________________/
`10
`11
`12
`13
`14
`15
`16
`17
`18 Stenographically Reported By:
`19 LUCY CARRILLO-GRUBBS, CSR #6766, RPR-RMR-CRR-CCRR
`20
`21
`22
`23
`24
`25
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`UCCELLI & ASSOCIATES, INC.
`1243 Mission Road
`South San Francisco, CA 94080
`www.UccelliAssociates.com
`E-mail: info@UccelliAssociates.com
`Tel: 650.952.0774 Fax: 650.952.8688
`
`VIDEOCONFERENCE DEPOSITION OF DAVID ALBONESI, PhD
`THURSDAY, MAY 21, 2020
`
`AQUILA - Ex. 2012
`
`
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`DAVID ALBONESI, PhD 05-21-2020
` 1 ---oOo---
` 2 I N D E X O F E X A M I N A T I O N
` 3 WITNESS Page
` 4 DAVID ALBONESI, PhD
` 5 EXAMINATION BY ATTORNEY CHERNG 5
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` 7
` 8 ---oOo---
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`650.952.0774 Uccelli & Associates, Inc. 650.952.8688 2
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`DAVID ALBONESI, PhD 05-21-2020
` 1 A P P E A R A N C E S
` 2 FOR PETITIONER:
` 3 DANIEL S. BLOCK, ATTORNEY AT LAW
` 4 LAUREN C. SCHLEH, ATTORNEY AT LAW
` 5 STERNE KESSLER GOLDSTEIN & FOX
` 6 1100 New York Avenue, NW Suite 600
` 7 Washington, DC 20005
` 8 Tel: 202.772.8735
` 9 Email: dblock@sternekessler.com
`10
`11 FOR PATENT OWNER:
`12 GENE CHERNG, ATTORNEY AT LAW
`13 FREITAS & WEINBERG
`14 350 Marine Parkway, Suite 200
`15 Redwood Shores, CA 94065
`16 Tel: 650.593.6300
`17 Email: gcherng@fawlaw.com
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`650.952.0774 Uccelli & Associates, Inc. 650.952.8688 3
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`DAVID ALBONESI, PhD 05-21-2020
` 1 BE IT REMEMBERED THAT, pursuant to the laws
` 2 pertaining to the taking and use of depositions, and on
` 3 THURSDAY, MAY 21, 2020, commencing at the hour of 6:13
` 4 a.m. thereof, at the offices of Carrillo Reporting
` 5 Services, 112 Manzanita Avenue, South San Francisco,
` 6 California, before me, LUCY CARRILLO-GRUBBS, CRP, RMR,
` 7 CRR, RPR, CSR No. 6766, a Certified Shorthand Reporter
` 8 in and for the State of California, personally appeared
` 9 via Zoom
`10
`11 DAVID ALBONESI, PhD
`12
`13 being called as a witness by the Patent Owner, who,
`14 having been by me first duly sworn, was thereupon
`15 examined and interrogated as hereinafter set forth.
`16
`17 ---oOo---
`18 THE STENOGRAPHER: Good morning, my name is
`19 Lucy Carrillo-Grubbs. I am a California Certified
`20 Stenographic Reporter. My CSR number is 6766.
`21 Before we proceed, I will ask counsel to agree
`22 on the record that under the current national emergency
`23 due to COVID-19, that there is no objection to this
`24 deposition officer administering the oath to the witness
`25 via Zoom.
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` 05:55:36
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`650.952.0774 Uccelli & Associates, Inc. 650.952.8688 4
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`DAVID ALBONESI, PhD 05-21-2020
` 1 Would Counsel please state your agreement on
` 2 the record and also identify yourselves and state whom
` 06:05:46
` 3 you represent.
` 06:13:33
` 4 ATTORNEY CHERNG: This is Gene Cherng from
` 06:13:38
` 5 Freitas & Weinberg representing patent owner Aquila
` 06:13:45
` 6 Innovations, and we have no objections.
` 06:13:46
` 7 ATTORNEY BLOCK: This is Dan Block from the
` 06:13:47
` 8 Sterne, Kessler, Goldstein & Fox on behalf of patent --
` 9 of the Petitioner Advanced Micro Devices. With me today 06:13:51
`10 from -- also from Sterne, Kessler is Lauren Schleh. And 06:13:56
`11 we have no objections.
` 06:14:00
`12 DAVID ALBONESI, PhD,
`13 having been first duly sworn by the Reporter to tell the
`14 truth, the whole truth, and nothing but the truth,
`15 testified as follows:
`16 ---oOo---
` 06:14:25
`17 EXAMINATION BY ATTORNEY CHERNG
` 06:14:25
`18 BY ATTORNEY CHERNG:
` 06:14:26
`19 Q. Good morning, Dr. Albonesi.
` 06:14:27
`20 A. Good morning.
`21 Q. One quick question before we begin, do you have 06:14:28
`22 any materials in front of you right now?
` 06:14:34
`23 A. I do. I have -- I have my declaration. I have 06:14:38
`24 the decision. I have the petition. I have the patent
` 06:14:44
`25 owner's response, and I have the various patents
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`650.952.0774 Uccelli & Associates, Inc. 650.952.8688 5
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`DAVID ALBONESI, PhD 05-21-2020
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` 1 associated with the case.
` 06:14:53
` 2 Q. Okay.
` 06:14:54
` 3 And the nonpatent exhibits, do you have those
` 06:14:56
` 4 as well?
` 06:14:57
` 5 A. I don't know what those are.
` 06:14:59
` 6 Q. Oh, okay. Got it.
` 06:15:01
` 7 But do you have all of the exhibits that were
` 06:15:03
` 8 filed with the petition?
` 06:15:06
` 9 A. I don't have all of the exhibits.
` 06:15:08
`10 Q. Okay, okay.
`11 If I bring one up and you don't have it, let me 06:15:10
`12 know and I can pull it up and share the screen with you
` 06:15:12
`13 so you can -- we can all kind of look at the same
` 06:15:15
`14 document.
` 06:15:20
`15 A. Okay.
` 06:15:20
`16 Q. Okay.
` 06:15:21
`17 Have you ever had your deposition taken before? 06:15:31
`18 A. Yes, I have.
` 06:15:34
`19 Q. And how many times?
` 06:15:35
`20 A. I would say between five and ten. I -- I don't 06:15:36
`21 know exactly. Do you need me to provide an exact
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`22 answer?
` 06:15:51
`23 Q. No.
` 06:15:51
`24 And were those all in connection with patent
` 06:15:52
`25 litigation of some sort?
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`DAVID ALBONESI, PhD 05-21-2020
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` 1 A. Yes.
` 06:15:57
` 2 Q. Okay.
` 06:15:58
` 3 And how many of those were in connection with
` 06:16:01
` 4 inter partes reviews?
` 06:16:04
` 5 A. Zero. So this is -- this is the first one.
` 06:16:11
` 6 Q. Okay.
` 06:16:13
` 7 Have you ever been retained by Advanced Micro
` 06:16:17
` 8 Devices, Inc. before as an expert witness?
` 06:16:19
` 9 A. Yes, I have.
` 06:16:20
`10 Q. Okay.
` 06:16:22
`11 And in connection with that previous work, did
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`12 you also -- sorry.
` 06:16:26
`13 In connection with that previous case, did you
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`14 also submit an expert declaration or expert report?
` 06:16:32
`15 A. I did, yes.
` 06:16:33
`16 Q. And what was the technology area of that case,
` 06:16:37
`17 if you don't mind?
` 06:16:38
`18 A. So that case was -- had to do with bus
` 06:16:42
`19 technology, and in particular, it had to do with
` 06:16:50
`20 cache -- you know, a PCI bus and something called
` 06:16:55
`21 presnooping, where you could snoop in advance the cache
` 06:17:01
`22 in advance on a PCI bus.
` 06:17:03
`23 Q. Okay.
`24 So you have a copy of your declaration in front 06:17:10
`25 of you; is that correct?
` 06:17:13
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`DAVID ALBONESI, PhD 05-21-2020
` 06:17:15
` 1 A. I do, yes.
` 06:17:16
` 2 Q. Okay.
` 06:17:17
` 3 And did you write all of the declaration?
` 06:17:20
` 4 A. I wrote part of it. It was -- well, first of
` 06:17:25
` 5 all, before any of this started, there was a lot of
` 06:17:28
` 6 discussion, lots of back and forth, so I wrote part of
` 06:17:31
` 7 the declaration and part of it was written by attorneys
` 06:17:34
` 8 for Sterne, Kessler.
` 06:17:36
` 9 Q. Okay.
` 06:17:39
`10 And in connection with the -- preparing the
` 06:17:41
`11 declaration, did you review all of the exhibits that
` 06:17:46
`12 were filed with the petition?
` 06:17:48
`13 A. Yes, I did.
` 06:17:49
`14 Q. And how many hours would you say you spent
` 06:17:55
`15 preparing the declaration?
` 06:17:56
`16 A. To be honest, I don't know. It was many hours
` 06:18:01
`17 over -- it was many -- it was over many, many days and
`18 many, many months, so I could not come up with a perfect 06:18:06
`19 number of hours.
` 06:18:09
`20 Q. Okay. And has your -- sorry.
` 06:18:10
`21 Have your opinions in your declaration, have
` 06:18:15
`22 the opinions you expressed in your declaration changed
` 06:18:18
`23 since you submitted the declaration?
` 06:18:20
`24 A. No, they have not.
` 06:18:23
`25 Q. Okay.
` 06:18:25
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`650.952.0774 Uccelli & Associates, Inc. 650.952.8688 8
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`DAVID ALBONESI, PhD 05-21-2020
` 1 If you could turn to paragraph 37 of your
` 2 declaration, please. I'd like to turn your attention
` 3 to -- to the second sentence in that paragraph that
` 4 says: "During that time, the semiconductor technology
` 5 supported, by today's standards, modest clock
` 6 frequencies and levels of chip integration."
` 7 Could you please explain the concept of a chip
` 8 integration?
` 9 A. Sure.
`10 ATTORNEY BLOCK: Objection, form.
`11 THE WITNESS: Yeah, so -- so can you give --
`12 can you rephrase the question? So what -- can you
`13 rephrase the question?
`14 ATTORNEY CHERNG: Sure.
`15 Q. You -- you testified in your declaration that
`16 the semiconductor technology supported modest block
`17 frequencies and levels of chip integration.
`18 A. Right.
`19 Q. And I'm asking you if you can explain what
`20 levels of chip integration -- you know, what chip
`21 integration is and what levels were -- sorry.
`22 I'm asking you to -- let's start with what
`23 exactly do you mean by chip integration?
`24 A. So the levels of chip integration would depend
`25 on the system that we're talking about, first of all.
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`DAVID ALBONESI, PhD 05-21-2020
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` 1 So at the time, if you were talking about a processor
` 06:20:21
` 2 that was designated to go in a PC, then it might have a
` 3 processor and memory controllers and things like that on 06:20:28
` 4 it. Right?
` 06:20:32
` 5 If you were talking about something that was
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` 6 more oriented towards something like a -- like a
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` 7 microcontroller type, then there might be additional
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` 8 levels of integration. So the processor might be
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` 9 simpler. You don't need the high speed that you might
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`10 have in a -- for a PC. Right?
` 06:20:57
`11 And so a PC system might have a -- you know,
` 06:21:00
`12 like a single core and have a limited amount of
` 06:21:04
`13 functionality beyond that. Whereas something that's for 06:21:08
`14 a microcontroller, which is not intended to be
` 06:21:12
`15 necessarily the highest speed system, might have more
` 06:21:16
`16 integration. It might have possibilities of, you know,
` 06:21:19
`17 peripheral controllers, possibilities onboard memory, so 06:21:24
`18 it really depends on the system.
` 06:21:30
`19 If we're talking about like a PC, that would be 06:21:32
`20 one level of integration. If you're talking about
` 06:21:34
`21 something like that's in a microcontroller, it would be
` 06:21:36
`22 a different level of integration.
` 06:21:39
`23 Q. Okay.
` 06:21:41
`24 And you were speaking in terms of the
` 06:21:42
`25 mid-1990s?
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`DAVID ALBONESI, PhD 05-21-2020
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` 1 A. Yes.
` 2 Q. Okay.
` 3 If you could turn to paragraph 42 on the
` 4 declaration, please.
` 5 A. Okay.
` 6 Q. And the last sentence in paragraph 42 on page
` 7 15.
` 8 A. Yes.
` 9 Q. Okay.
`10 That sentence mentions a -- an ACPI specific
`11 processor register. What is a register?
`12 ATTORNEY BLOCK: Objection, scope.
`13 BY ATTORNEY CHERNG:
`14 Q. Dr. Albonesi?
`15 A. Yes, yes, I'm thinking about the question.
`16 Q. Oh, I'm sorry, please proceed. Thank you.
`17 A. Yes.
`18 ATTORNEY BLOCK: Calls for a legal conclusion.
`19 THE WITNESS: So register in general, I would
`20 say -- not say, I would say a register in general is --
`21 is some kind of storage.
`22 BY ATTORNEY CHERNG:
`23 Q. Some kind of storage. Any kind of storage?
`24 ATTORNEY BLOCK: Objection, scope.
`25 THE WITNESS: I'm sorry, Dan, go ahead. I
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`DAVID ALBONESI, PhD 05-21-2020
` 06:24:11
` 1 missed your objection.
` 06:24:13
` 2 ATTORNEY BLOCK: Scope.
` 06:24:30
` 3 THE WITNESS: So in this particular context,
` 06:24:32
` 4 this is ACPI, and it says writing ACPI specific
` 06:24:38
` 5 processor registers. So for this particular concept,
` 6 this particular context, this could be a register -- for 06:24:41
` 7 this particular context, this could be a register, it
` 06:24:47
` 8 says within a processor, for this particular context.
` 06:24:50
` 9 BY ATTORNEY CHERNG:
` 06:24:54
`10 Q. Okay. And there are registers that are outside 06:24:54
`11 processors?
` 06:24:57
`12 A. Yes, there are.
` 06:24:58
`13 Q. And how would you describe those? What are
` 06:24:59
`14 those? What is a register that is outside a processor?
` 06:25:03
`15 ATTORNEY BLOCK: Objection, scope.
` 06:25:07
`16 THE WITNESS: So there -- there are many, many
` 06:25:08
`17 such examples of registers that are outside of
` 06:25:22
`18 processors. They could be in a memory controller. They 06:25:25
`19 could be located near a peripheral interface, right? So 06:25:32
`20 there's -- there's many possible examples of registers
` 06:25:39
`21 that are outside of a processor register.
` 06:25:42
`22 BY ATTORNEY CHERNG:
` 06:25:44
`23 Q. Okay. But in general, then, it seems like --
` 06:25:45
`24 I'm sorry.
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`25 It seems like you're aware of what a register
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`DAVID ALBONESI, PhD 05-21-2020
` 1 is in general, and I would like for you to explain what
` 2 a register is.
` 3 ATTORNEY BLOCK: Objection, foundation, scope.
` 4 THE WITNESS: So as I just described, a
` 5 register is -- is some kind of storage.
` 6 BY ATTORNEY CHERNG:
` 7 Q. And what is some kind of storage? Is there a
` 8 specific structure associated with the storage?
` 9 A. So in general, there's not just one particular
`10 way to create a register.
`11 Q. Okay.
`12 Aside from how it's created, is -- is the
`13 register associated with any specific hardware
`14 structure?
`15 ATTORNEY BLOCK: Objection, scope.
`16 THE WITNESS: So register is a general term.
`17 And register -- as I just mentioned, registers can be
`18 found in many different places in a computer system.
`19 ATTORNEY CHERNG: Okay.
`20 Q. And you've just mentioned it's a general term,
`21 and what is the definition of that general term?
`22 ATTORNEY BLOCK: Objection, scope.
`23 THE WITNESS: As I mentioned, it's a -- it's a
`24 storage element. It's -- it's storage bits, let's put
`25 it that way. If we want to get specific, it stores
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`DAVID ALBONESI, PhD 05-21-2020
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` 1 bits. That's what a register is, it stores bits.
` 06:27:39
` 2 BY ATTORNEY CHERNG:
` 06:27:39
` 3 Q. I'm sorry, you're saying it's storage bits or
` 06:27:42
` 4 it stores bits?
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` 5 A. Stores bits.
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` 6 Q. Okay, I got it, thank you.
` 06:27:47
` 7 A. Yeah, yeah.
` 06:27:47
` 8 Q. And is it your understanding that a -- I'm
` 06:28:03
` 9 sorry, so isn't it true that a register is hardware?
` 06:28:10
`10 ATTORNEY BLOCK: Objection, mischaracterizes,
` 06:28:19
`11 scope.
`12 THE WITNESS: So in the examples I mentioned, a 06:28:43
`13 register would be hardware.
` 06:28:45
`14 BY ATTORNEY CHERNG:
` 06:28:47
`15 Q. Are there instances in which a register isn't
` 06:28:47
`16 hardware?
` 06:28:50
`17 ATTORNEY BLOCK: Objection, scope.
` 06:28:51
`18 THE WITNESS: So I'm going to -- so I'm not
` 06:28:52
`19 sure that this is within the scope of this particular -- 06:30:08
`20 this particular case.
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`21 BY ATTORNEY CHERNG:
` 06:30:22
`22 Q. Are you refusing to answer?
` 06:30:22
`23 A. Could you repeat your question?
` 06:30:24
`24 Q. Are there instances in which a register isn't
` 06:30:34
`25 hardware?
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`DAVID ALBONESI, PhD 05-21-2020
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` 1 ATTORNEY BLOCK: Objection, scope.
` 06:30:44
` 2 But you can answer to the extent you have
` 06:30:48
` 3 knowledge.
` 06:30:48
` 4 THE WITNESS: Okay. Okay. Thanks for that.
` 06:30:51
` 5 So, you know, there are -- yeah, I'm going to
` 06:31:15
` 6 think about this.
` 06:31:17
` 7 BY ATTORNEY CHERNG:
` 06:31:18
` 8 Q. Is it a particularly difficult question,
` 06:31:22
` 9 Professor Albonesi, whether --
` 06:31:23
`10 A. I'm trying to think of instances, you know,
` 06:31:26
`11 where it could be a software register, for instance.
` 06:31:29
`12 Q. And you can't think of any --
` 06:31:30
`13 A. Software --
` 06:31:32
`14 Q. -- as --
` 06:31:32
`15 ATTORNEY BLOCK: Object, objection,
` 06:31:33
`16 mischaracterizes.
`17 He's trying to answer your question, let him -- 06:31:34
`18 let him consider it and then he will give you his
` 06:31:37
`19 answer. Please stop interrupting him.
` 06:31:40
`20 THE WITNESS: So, you know, there's ways for -- 06:31:48
`21 for software to use like -- you know, to communicate,
` 06:31:57
`22 for instance, and they communicate through these --
` 06:32:07
`23 through some, you know, like -- like a register, right?
` 06:32:09
`24 So I think, you know, there may be a software
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`25 concept of register, but, you know, in the context that
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`DAVID ALBONESI, PhD 05-21-2020
` 06:32:32
` 1 we're talking about here, so if you want to talk about
` 06:32:34
` 2 the specific context, writing ACPI specific processor
` 06:32:41
` 3 registers, in this particular context, that would be
` 06:32:43
` 4 hardware.
` 06:32:46
` 5 ATTORNEY CHERNG: Thank you.
` 06:32:48
` 6 Q. Moving on to paragraph 44 of your declaration,
` 06:32:54
` 7 please.
` 06:32:55
` 8 A. Sure.
` 9 Q. You mention techniques that turned off or dated 06:32:59
`10 the clock or reduced its frequency?
` 06:33:01
`11 A. Yes.
` 06:33:06
`12 Q. Can you please explain the concept of clock
` 06:33:06
`13 gating, please.
` 06:33:09
`14 A. Sure. So when you're designing a system with a 06:33:10
`15 global clock, so, you know, you bring in -- you bring in 06:33:16
`16 the -- the clock to like the central place, and then you 06:33:23
`17 distribute the clock, there's this thing called an H
` 06:33:30
`18 tree, which is a way to distribute the clock to, you
` 06:33:33
`19 know, try to get it to all of the -- the idea is you
` 06:33:36
`20 want to get it to all of -- all of the flip-flops and
` 06:33:39
`21 all of the memory locations and all of that at the same
` 06:33:42
`22 time. And then typically you would -- you would have
` 06:33:46
`23 some ability to -- to turn off that clock.
` 06:33:48
`24 Now, it has to be done very, very carefully, so 06:33:52
`25 there's a way to gate the clock. Typically do it in
` 06:33:54
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`DAVID ALBONESI, PhD 05-21-2020
` 06:33:58
` 1 some kind of region. And so -- so -- so you would --
` 06:34:06
` 2 you would have the ability to turn off the clock to
` 06:34:11
` 3 particular areas of the chip.
` 06:34:15
` 4 In terms of reducing the frequency, so, you
` 5 know, there's been this technique that's been around for 06:34:20
` 6 decades called dynamic voltage and frequency scaling, so 06:34:23
` 7 voltage is often scaled as well. The dynamic frequency
` 06:34:28
` 8 scaling, where you dynamically change the clock
` 06:34:32
` 9 frequency on the fly. So you might do this -- so we
` 06:34:34
`10 talked about desktop and laptop systems, so you might do 06:34:42
`11 this based on activity, for instance. You might do this 06:34:48
`12 for other reasons as well.
` 06:34:54
`13 Q. Okay.
` 06:34:58
`14 And you mentioned that the clock can be gated
` 06:34:58
`15 to particular areas of the chip and the clock is -- is
` 06:35:02
`16 it correct, then, that the areas for which the clock is
` 06:35:06
`17 gated off, there -- there is no clock being supplied to
` 06:35:08
`18 that gated area that's been gated?
` 06:35:13
`19 ATTORNEY BLOCK: Objection, scope.
` 06:35:19
`20 THE WITNESS: You're talking about a particular 06:35:20
`21 area where you've got -- where you've got a clock
` 06:35:27
`22 source, right? Yeah, so if there's a particular area
` 06:35:29
`23 with the clock source that goes to all -- that
` 06:35:31
`24 particular area, then you would -- you would -- you
` 06:35:34
`25 would gate the clock to that particular region.
` 06:35:38
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`DAVID ALBONESI, PhD 05-21-2020
` 06:35:41
` 1 ATTORNEY CHERNG: Okay.
` 06:35:41
` 2 Q. And then the clock would not be supplied to
` 06:35:43
` 3 that particular region when it's gated?
` 06:35:49
` 4 ATTORNEY BLOCK: Objection, scope.
` 06:35:50
` 5 THE WITNESS: Yeah, the clock would be -- the
` 06:35:57
` 6 clock would be turned off to that region, that's
` 06:35:59
` 7 correct.
` 06:35:59
` 8 ATTORNEY CHERNG: Okay, thank you.
` 06:36:00
` 9 THE WITNESS: Yeah.
` 06:36:00
`10 BY ATTORNEY CHERNG:
`11 Q. Moving on to section C of your declaration, the 06:36:12
`12 next immediately following section about power
` 06:36:15
`13 management libraries using C.
` 06:36:20
`14 I'm just curious, what is your understanding of 06:36:25
`15 the term "library"?
` 06:36:29
`16 ATTORNEY BLOCK: Objection, scope.
` 06:36:34
`17 THE WITNESS: So the example I give of Texas
` 06:36:34
`18 Instruments in paragraph 47. So in this -- in this
` 06:36:44
`19 particular example of Texas Instruments they developed
` 06:36:55
`20 these power management libraries, and in this particular 06:37:02
`21 instance, this would be -- in this particular instance
` 06:37:07
`22 that I'm talking about Texas Instruments, what they did
` 06:37:25
`23 is they created like a -- a C library, right? Something 06:37:28
`24 that you could call; in this particular instance, of
` 06:37:33
`25 Texas Instruments.
` 06:37:37
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`DAVID ALBONESI, PhD 05-21-2020
` 06:37:38
` 1 ATTORNEY CHERNG: Okay.
` 06:37:39
` 2 Q. So a C library is something that you can call?
` 06:37:42
` 3 ATTORNEY BLOCK: Objection, scope,
` 06:37:44
` 4 mischaracterizes.
` 06:37:50
` 5 THE WITNESS: So not in general. I mean, I'm
` 06:37:52
` 6 saying that for this particular example, Texas
` 06:37:55
` 7 Instruments, they talked about it's a power management
` 06:38:00
` 8 library in the C language. So in this particular case,
` 06:38:05
` 9 this would have a library that would be compiled and
` 06:38:16
`10 stored for this particular case.
` 06:38:26
`11 BY ATTORNEY CHERNG:
` 06:38:33
`12 Q. Okay. Let's move on to -- further down that
` 06:38:37
`13 paragraph is what I would like to explore. You've
`14 testified that table 48 in Exhibit 1018 shows an example 06:38:41
`15 of three functions that call the library with the
` 06:38:46
`16 specific frequency values. And could you please explain 06:38:49
`17 what calling a library or calling that particular
` 06:38:56
`18 library entails?
` 06:38:59
`19 A. In this particular case, so we're talking about 06:39:00
`20 figure 1 here; is that correct? 1018, is that what
` 06:39:09
`21 you're directing me to?
` 06:39:13
`22 Q. Paragraph 49 of your declaration.
` 06:39:16
`23 A. Oh, paragraph 49.
` 06:39:21
`24 Q. Yes, it cites to Exhibit 1018 on page 19. It
` 06:39:22
`25 says: "Exhibit 1018 shows an example of three functions 06:39:29
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`DAVID ALBONESI, PhD 05-21-2020
` 1 that call the library PSL_changeSetpoints with different 06:39:36
` 2 frequency values."
` 06:39:40
` 3 A. I see.
` 06:39:44
` 4 So in this particular case, for this particular 06:40:02
` 5 system, the Texas Instruments system, so these libraries 06:40:04
` 6 might be called -- these three functions might be called 06:40:13
` 7 from -- from an application program. So an application
` 06:40:22
` 8 program might have these libraries as compiled, is
` 06:40:30
` 9 complied library, an application program may able to --
` 06:40:37
`10 in this particular case, for this particular system, be
` 06:40:44
`11 able to call these libraries.
` 06:40:46
`12 Q. And what is -- I'm sorry, what does "call the
` 06:40:48
`13 libraries" mean?
` 06:40:51
`14 ATTORNEY BLOCK: Objection, scope.
` 06:40:52
`15 THE WITNESS: So -- so for this particular
` 06:40:53
`16 system, this TI system, the libraries would be like
` 06:41:01
`17 compiled in with the program. And the application
` 06:41:08
`18 program would then be able to refer to these libraries.
` 06:41:12
`19 That's for this particular system.
` 06:41:16
`20 BY ATTORNEY CHERNG:
` 06:41:20
`21 Q. Okay. Dr. Albonesi, what is a driver?
` 06:41:26
`22 ATTORNEY BLOCK: Objection to scope, form.
` 06:41:50
`23 THE WITNESS: Well, I'll give you an example of 06:42:07
`24 a driver for input/output systems. So for input/output
` 06:42:45
`25 systems, a driver would be some level of software that
` 06:42:51
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`DAVID ALBONESI, PhD 05-21-2020
` 06:42:58
` 1 allows for interaction with those input/output systems.
` 2 That would be an example of a driver for an input/output 06:43:03
` 3 system.
` 06:43:06
` 4 ATTORNEY CHERNG: Okay.
` 06:43:08
` 5 Q. And if you generalize that -- is it correct to
` 06:43:09
` 6 generalize that to define a driver as "some level of
` 06:43:16
` 7 software that allows for some interaction with
` 06:43:21
` 8 hardware"?
` 06:43:24
` 9 ATTORNEY BLOCK: Objection, scope, foundation.
` 06:43:25
`10 THE WITNESS: Hardware's kind of a general
` 06:43:30
`11 term. That's a very broad term. I'm not sure -- you
` 06:43:38
`12 have to -- you have to give me a little more clarity on
` 06:43:41
`13 what you mean by hardware. Hardware is -- there's a lot 06:43:44
`14 of hardware. So what do you mean specifically?
` 06:43:47
`15 BY ATTORNEY CHERNG:
` 06:43:50
`16 Q. Do you think I mean nails or something?
` 06:43:51
`17 ATTORNEY BLOCK: Objection, argumentative.
` 06:43:54
`18 ATTORNEY CHERNG: I mean, sorry, withdraw that. 06:43:57
`19 Q. So a driver -- the verb is a driver -- what is
` 06:43:58
`20 a driver driving? Is it driving a -- is a driver --
` 06:44:02
`21 isn't it correct that a driver is software that drives a 06:44:06
`22 particular piece of hardware that it's designed to
` 06:44:09
`23 drive?
` 06:44:12
`24 ATTORNEY BLOCK: Objection, form, foundation,
` 06:44:13
`25 scope.
` 06:44:15
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`DAVID ALBONESI, PhD 05-21-2020
` 1 THE WITNESS: As I mentioned before, driver,
` 2 for example, for an input/output system is -- is
` 3 low-level software that allows you to interact with the
` 4 input/output system.
` 5 BY ATTORNEY CHERNG:
` 6 Q. What is low-level software?
` 7 ATTORNEY BLOCK: Objection, scope.
` 8 THE WITNESS: So it's something that's --
` 9 that's -- you know, that's kind of close to the
`10 hardware, right? So generally applications are not --
`11 you know, cannot change pieces of the IO system, for
`12 instance. The driver can do that.
`13 BY ATTORNEY CHERNG:
`14 Q. So how does the driver change pieces of the IO
`15 system?
`16 ATTORNEY BLOCK: Objection, incomplete
`17 hypothetical.
`18 THE WITNESS: So it really depends on what
`19 output system. If you're talking about a disk
`20 controller, for instance, you know, there's typically
`21 some registers associated with the disk controller and
`22 the driver can interact with those registers.
`23 BY ATTORNEY CHERNG:
`24 Q. And the interaction with the registers changes
`25 the behavior of the disk controller?
`
` 06:44:16
` 06:44:19
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` 06:44:30
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` 06:44:34
` 06:44:42
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` 06:45:00
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` 06:45:11
` 06:45:13
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`DAVID ALBONESI, PhD 05-21-2020
` 1 A. So there's a few types of registers. There are 06:45:46
` 2 registers that are readable to get status and there are
` 06:45:53
` 3 registers where you can control the disk controller.
` 06:45:56
` 4 Q. So in your declaration, you expressed certain
` 06:45:59
` 5 opinions about the validity of the claims of the '519
` 06:46:50
` 6 patent; is that correct?
` 06:46:56
` 7 A. Yes, that's correct.
` 06:46:58
` 8 Q. Okay.
` 06:46:59
` 9 Specifically, is this your opinion, that claim
` 06:47:02
`10 1 of the '519 patent is obvious over Ober in view of
` 06:47:09
`11 Nakazato?
` 06:47:12
`12 A. That is my opinion, yes.
` 06:47:15
`13 Q. Okay.
` 06:47:16
`14 Is it your opinion that Ober lacks -- does not
` 06:47:18
`15 disclose certain limitations of claim 1 of the '519
` 06:47:22
`16 patent?
` 06:47:25
`17 A. So Ober -- so if we go through claim 1, let's
` 06:47:26
`18 walk through claim 1. And let me get to my -- part of
` 06:47:34
`19 my declaration where I talk about this.
` 06:47:46
`20 Okay, so first of all, the preamble says a
` 06:48:02
`21 system LSI having a plurality of ordinary operation
` 06:48:06
`22 modes and a plurality of special modes in response to
` 06:48:09
`23 clock frequency supplied to the central processing unit
` 06:48:14
`24 comprising. So -- so Ober -- I mean, I could walk
` 06:48:17
`25 through all of those one by one, I won't do that.
` 06:48:27
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`DAVID ALBONESI, PhD 05-21-2020
` 1 But Ober -- Ober renders obvious this preamble. 06:48:30
` 2 In terms of a first memory that stores a clock control
` 06:48:41
` 3 library for controlling a clock frequency transition,
` 06:48:44
` 4 Ober also renders that obvious.
` 06:48:49
` 5 In -- well, let me make sure I'm looking at my
` 06:48:52
` 6 report.
` 06:49:04
` 7 I would need to go to the nex
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