` U.S. Patent No. 6,651,134
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________________________
`ADVANCED MICRO DEVICES, INC.,
`
` Petitioner
`
`V.
`
`MONTEREY RESEARCH, LLC,
`
` Patent Owner.
`_________________________________________
` IPR2020-00985
` U.S. Patent No. 6,651,134
` Thursday, April 28, 2021
`_________________________________________
` ZOOM VIDEOTAPED DEPOSITION
` OF MICHAEL BROGIOLI, Ph.D., commencing at
` a.m. CST, Thursday, April 28, 2021, 10:00
` before BELLE VIVIENNE, RPR, CRR.
`
`TAKEN BY:
` BRIAN COOK, ESQ.
` ATTORNEY FOR RESPONDENT
`
`REPORTED BY:
`
` BELLE VIVIENNE, CRR
` VERITEXT LEGAL SOLUTIONS
` JOB NO. 4527887
` 866 299-5127
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`Page 1
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`Petitioner AMD Ex-1015, 0001
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` A P P E A R A N C E S
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`F O R T H E P E T I T I O N E R :
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` B R I A N C O O K , E S Q .
` O ’ M E L V E N Y & M Y E R S L L P
` 4 0 0 S o u t h H o p e S t r e e t , 1 8 t h F l o o r
` L o s A n g e l e s , C a l i f o r n i a 9 0 0 7 1
` 2 1 3 . 4 3 0 . 6 0 0 0
` b c o o k @ o m m . c o m
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`F O R T H E R E S P O N D E N T :
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` M I C H A E L W U E S T E , E S Q .
` D E S M A R A I S L L P
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` N e w Y o r k , N e w Y o r k 1 0 1 6 9
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`V I D E O G R A P H E R :
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`Page 2
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`Petitioner AMD Ex-1015, 0002
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` I N D E X
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`T e s t i m o n y o f :
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` M I C H A E L B R O G I O L I , P h . D .
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` M R . C O O K . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
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` E X H I B I T S
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` N o . D e s c r i p t i o n P a g e
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` E x h i b i t ( N O N E ) . . . . . . . . . . . . . . . . . .
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`Petitioner AMD Ex-1015, 0003
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` D E P O S I T I O N S U P P O R T I N D E X
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`D i r e c t i o n s t o W i t n e s s N o t t o A n s w e r
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`P a g e L i n e
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`n o n e
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`R e q u e s t f o r P r o d u c t i o n o f D o c u m e n t s
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`P a g e L i n e
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`n o n e
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`S t i p u l a t i o n s
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`P a g e L i n e
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`n o n e
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`Q u e s t i o n M a r k e d
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`Petitioner AMD Ex-1015, 0004
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` THE VIDEOGRAPHER: Good morning. 10:04:29
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` We are going on the record at 10:04:29
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` 10:04 a.m. on April 28, 2021. This is 10:04:31
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` media unit one of the video recorded 10:04:36
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` deposition of Dr. Michael Brogioli 10:04:38
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` taken by counsel for petitioner in the 10:04:42
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` matter of Advanced Micro Devices, 10:04:45
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` Inc., versus Monterey Research, LLC, 10:04:45
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` filed in the United States Patent and 10:04:51
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` Trademark Office before the Patent 10:04:53
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` Trial and Appeal Board. The Case 10:04:57
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` Number is IPR 2020-00985. 10:04:57
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` This deposition is being held 10:05:03
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` virtually via Zoom. My name is Jeff 10:05:06
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` Nichols from the firm Veritext Legal 10:05:09
`
` Solutions, and I am the videographer. 10:05:11
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` The court reporter is Belle Vivienne 10:05:12
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` from the firm Veritext Legal 10:05:14
`
` Solutions. 10:05:16
`
` Counsel will now please state 10:05:16
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` their appearances and affiliations for 10:05:18
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` the record. 10:05:23
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` MR. COOK: This is Brian Cook 10:05:23
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` with O'Melveny & Meyers for petitioner 10:05:24
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` AMD. 10:05:28
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`Veritext Legal Solutions
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`Page 5
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`Petitioner AMD Ex-1015, 0005
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` MR. WUESTE: Michael Wueste of 10:05:28
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` Desmarais LLP, for patent owner 10:05:30
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` Monterey Research, LLC, and on behalf 10:05:33
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` of the witness. 10:05:34
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` THE VIDEOGRAPHER: Will the 10:05:35
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` court reporter please swear in the 10:05:35
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` witness. 10:05:39
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` MICHAEL BROGIOLI, M.D., 10:05:39
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`having been first duly sworn by the 10:05:39
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`Certified Stenographic Realtime Reporter, 10:05:39
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`testified as follows: 10:05:51
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` THE VIDEOGRAPHER: Thank you. 10:05:51
`
` You may proceed. 10:05:52
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` EXAMINATION 10:05:52
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`BY MR. COOK: 10:05:52
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` Q. Good morning, Dr. Brogioli. 10:05:56
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` A. Good morning. 10:05:58
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` Q. Could you please state your full 10:06:00
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`name for the record? 10:06:01
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` A. Sure. It's Michael Charles 10:06:06
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`Brogioli. It's B-R-O-G-I-O-L-I. 10:06:08
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` Q. Thank you. 10:06:12
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` And have you been deposed 10:06:13
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`before? 10:06:17
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` A. I have, yes. 10:06:18
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`Page 6
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`Petitioner AMD Ex-1015, 0006
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` Q. Approximately how many times? 10:06:18
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` A. I would say about 40 or so. 10:06:20
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` Q. Okay. Have you -- have you been 10:06:23
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`deposed in this video format, remote video 10:06:24
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`format before? 10:06:27
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` A. I have, maybe six or seven 10:06:29
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`times, something like that. 10:06:31
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` Q. So although this is by video and 10:06:33
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`remote, you understand that you're under 10:06:37
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`oath just as if you were in court or in 10:06:38
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`front of the PTAB? 10:06:41
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` A. Yes, that's correct. 10:06:44
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` Q. And where are you located 10:06:46
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`currently? 10:06:48
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` A. I'm in Austin, Texas, today, 10:06:49
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`USA. 10:06:51
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` Q. And are you in your office or in 10:06:53
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`a home or -- 10:06:55
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` A. I'm not in my office; I'm in my 10:06:57
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`home office today. 10:06:59
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` Q. And in your home office, is -- 10:07:01
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`is anyone else there in the room with you? 10:07:05
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` A. No. 10:07:08
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` Q. Do you have any papers with you? 10:07:10
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` A. No. 10:07:14
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`Page 7
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`Petitioner AMD Ex-1015, 0007
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` Q. Any -- do you have any papers or 10:07:16
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`notes available on your computer with you 10:07:22
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`today? 10:07:25
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` A. No, just the Zoom session. I 10:07:25
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`think we're using Zoom, but yeah. 10:07:29
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` Q. Okay. What about -- other than 10:07:31
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`your -- your -- I guess your cell phone 10:07:34
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`that you're on right now, do you have any 10:07:36
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`other communication devices in the room? 10:07:38
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` A. No. 10:07:39
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` Q. And is your computer hooked up 10:07:41
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`to e-mail right now? 10:07:47
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` A. No. I think I closed that 10:07:49
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`before we started. 10:07:50
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` Q. Okay. Okay. So just especially 10:07:52
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`when we're remote, we have to be extra 10:07:58
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`careful to not talk over each other. And 10:08:01
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`if anything I ask is unclear, if you could 10:08:03
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`just ask for a clarification, otherwise, 10:08:06
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`I'll just assume you've understood it. 10:08:08
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` Is that all right? 10:08:10
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` A. Understood. Sure. 10:08:11
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` Q. And so I'll break approximately 10:08:13
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`every hour or so. If you -- if you need a 10:08:16
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`break or -- and I haven't asked for one or 10:08:18
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`Page 8
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`Petitioner AMD Ex-1015, 0008
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`whatever, just feel free to ask. I would 10:08:22
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`only say that just -- if there's -- if 10:08:23
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`there's a question pending, please answer 10:08:25
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`the question first before you ask for a 10:08:27
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`break. 10:08:29
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` Is that all right? 10:08:29
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` A. Sure. 10:08:30
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` Q. Is there any reason that you 10:08:32
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`cannot give your best testimony today? 10:08:33
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` A. No. 10:08:35
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` Q. And now, you understand today 10:08:44
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`that you're -- that by the rules of the -- 10:08:45
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`of the PTAB, you're not allowed to talk to 10:08:47
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`your attorney about your testimony during 10:08:49
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`the deposition? 10:08:52
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` Understand that? 10:08:52
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` A. Yes, that's my -- that's my 10:08:52
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`understanding, yes. 10:08:54
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` Q. How did you prepare for your 10:08:54
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`deposition today? 10:08:58
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` A. Mostly reviewed -- 10:09:00
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` MR. WUESTE: I'll caution the 10:09:00
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` witness not to reveal the substance of 10:09:01
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` any -- sorry. I'll caution the 10:09:03
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` witness not to reveal the substance of 10:09:04
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`Page 9
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`Petitioner AMD Ex-1015, 0009
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` any attorney communications, but 10:09:06
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` otherwise, you can answer. 10:09:10
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` A. So I reviewed my declaration, 10:09:12
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`the '134 patent at issue; a couple of the 10:09:16
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`prior art references, I'm sure we'll get 10:09:21
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`to today; probably a number of, if not all 10:09:24
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`of the materials, in the materials 10:09:29
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`considered; and then met with counsel for 10:09:30
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`a while yesterday. I guess it would have 10:09:35
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`been Tuesday and then, I believe, for a 10:09:37
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`few hours on Monday as well. 10:09:39
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`BY MR. COOK: 10:09:39
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` Q. And who did you meet with? 10:09:44
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` A. I believe it was Michael Wueste, 10:09:47
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`who is on the call today, and then another 10:09:53
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`gentleman, Theodore, whose last name I 10:09:56
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`will not get correct. It begins, I 10:09:59
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`believe, with a K. It's worse than my 10:10:04
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`last name. 10:10:06
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` Q. And do you recall which prior 10:10:07
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`art references you reviewed? 10:10:09
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` A. It probably would have been all 10:10:10
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`of them. Certainly, the Wada reference 10:10:12
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`and Barrett and so forth and the other 10:10:14
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`ones that I list in my declaration. 10:10:17
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`Page 10
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`Petitioner AMD Ex-1015, 0010
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` Q. If you'll look over at Exhibit 10:10:22
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`Share, I think you should see an exhibit 10:10:24
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`in there, a copy of your declaration in 10:10:27
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`this case. 10:10:30
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` Would you open that up, please? 10:10:30
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` A. Sure. Okay. 10:10:32
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` Q. So is this a complete copy of 10:10:57
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`the declaration you submitted in this 10:10:59
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`matter? 10:11:01
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` A. I'm quickly skimming through it. 10:11:01
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` Yeah, it looks to be correct, 10:11:28
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`yes. 10:11:30
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` Q. And can you just turn to the 10:11:30
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`last page of the declaration and verify 10:11:32
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`whether that's your signature. 10:11:35
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` A. It is, yes. 10:11:37
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` Q. Did you write this declaration? 10:11:41
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` A. I did, yes. 10:11:44
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` Q. You wrote every word of it? 10:11:46
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` A. Yes, I -- the legal sections, I 10:11:49
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`think, may have been, things of that 10:11:53
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`nature, provided by counsel. 10:11:55
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` And then I remember explicitly 10:11:58
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`having some help on formatting, things 10:12:01
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`like that, which I never get right, but, 10:12:03
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`Page 11
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`Petitioner AMD Ex-1015, 0011
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`yeah, drafted myself, formed all my own 10:12:06
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`opinions. In fact, I think I even 10:12:12
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`remember putting together sort of the 10:12:15
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`first -- 10:12:15
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` (Reporter clarification.) 10:12:15
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` A. -- putting together sort of the 10:12:17
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`poorly formatted first draft of it myself. 10:12:19
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`BY MR. COOK: 10:12:19
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` Q. And the annotated figures, did 10:12:26
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`you create those annotations yourself? 10:12:29
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` A. Yes. Typically what I do is say 10:12:32
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`what we want from, for example, a figure 10:12:37
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`in the patent, highlight this box kind of 10:12:39
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`thing. 10:12:42
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` I think maybe a paralegal or 10:12:42
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`someone may have actually assembled them 10:12:45
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`for me, or I may have, you know, submitted 10:12:48
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`a rough version of it. But yes, those 10:12:49
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`would have been my highlights. 10:12:53
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` Q. Are there any opinions in this 10:12:54
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`declaration that you disagree with? 10:12:58
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` A. No. 10:13:02
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` Q. And are all of your opinions 10:13:02
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`included in this declaration? 10:13:07
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` A. Yes. Sitting here today, yes, 10:13:12
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`Page 12
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`Petitioner AMD Ex-1015, 0012
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`that should be the case, yes. 10:13:14
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` Q. So this declaration is a 10:13:16
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`complete statement of your opinions in the 10:13:18
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`case? 10:13:21
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` A. Yes, that's correct. 10:13:22
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` Q. Can you turn to page -- let's 10:13:22
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`see, page 2 of your declaration? 10:13:31
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` A. Okay. 10:13:42
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` Q. On page 2, there's a section 10:13:42
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`called Materials Reviewed. 10:13:45
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` Did you review all -- all of the 10:13:48
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`materials that are mentioned in this 10:13:50
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`paragraph? 10:13:52
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` A. That's correct, yes. And the 10:13:52
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`Appendix B, yes. 10:14:04
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` Q. Okay. And the Appendix B you 10:14:06
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`mentioned, I believe that's on page 141. 10:14:09
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` Could you turn to that? 10:14:14
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` A. Okay. Okay. 10:14:16
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` Q. So on page 141, we have Appendix 10:14:27
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`B, Materials Reviewed. Can you take a 10:14:30
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`look through those and verify those are 10:14:32
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`all the materials that you reviewed 10:14:35
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`forming your opinions in this case? 10:14:37
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` A. Yes, these look like additional 10:14:49
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`Page 13
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`Petitioner AMD Ex-1015, 0013
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`materials that I reviewed as part of 10:14:51
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`drafting the declaration. 10:14:54
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` Q. And is this the complete list of 10:14:55
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`all the materials that you reviewed? 10:15:00
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` A. These would be, yes, materials 10:15:03
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`reviewed, materials relied upon. I don't 10:15:06
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`think -- or at least it wasn't my 10:15:10
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`intention -- if there's something I 10:15:12
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`reference in the declaration not listed 10:15:13
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`here, I would think it should be listed 10:15:16
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`here. 10:15:18
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` Q. Other than that, are there any 10:15:18
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`other materials that you reviewed that are 10:15:21
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`not listed here that you're aware of? 10:15:22
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` A. Not that I recall, no. 10:15:26
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` Q. Were there any materials that 10:15:27
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`you would have liked to review but were 10:15:32
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`unable to? 10:15:36
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` A. Not that I recall, no. 10:15:38
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` Q. Are there any errors in your 10:15:39
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`declaration? 10:15:47
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` A. Not that I found leading up to 10:15:48
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`prepping for today. We may, I'm sure find 10:15:53
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`some typos or something, but there's 10:15:56
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`nothing that sort of I found to bring -- 10:15:58
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`you know, bring to the table today, no. 10:16:01
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` Q. Okay. So you -- you stand by 10:16:03
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`all of your opinions in this declaration? 10:16:08
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` A. Yes, I do. 10:16:10
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` Q. Dr. Brogioli, are you familiar 10:16:14
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`with the term "static random access 10:16:20
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`memory"? 10:16:26
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` A. Yes, I think I even discuss it 10:16:26
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`in my declaration. 10:16:27
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` Q. And that's commonly referred to 10:16:32
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`as "SRAM"; is that right? 10:16:35
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` A. That's right. 10:16:37
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` Q. And are you familiar with 10:16:37
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`"dynamic random access memory"? 10:16:39
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` A. I am, yes. 10:16:45
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` Q. And that's commonly referred to 10:16:46
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`as "DRAM"; is that correct? 10:16:49
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` A. That's right. Different flavors 10:16:52
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`of it, but that's right. 10:16:54
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` Q. What are some of the different 10:16:56
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`flavors of DRAM? 10:16:57
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` A. There's been different -- I 10:16:59
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`think I mentioned some in my -- in the 10:17:01
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`declaration, but there's been different 10:17:03
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`iterations, DRAM 3, DRAM 4, there's DRAM 10:17:06
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`tailored to graphics, things like that. 10:17:12
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` Q. What's -- what about the term 10:17:15
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`"SDRAM"; are you familiar with that term? 10:17:19
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` A. Yes, usually referred -- or used 10:17:21
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`to refer to synchronous DRAM. 10:17:23
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` Q. So SDRAM is another type of 10:17:26
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`DRAM? 10:17:29
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` A. That's correct. 10:17:29
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` Q. What's the -- what's the 10:17:39
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`difference been SRAM and DRAM? 10:17:39
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` A. I talk about a few of these 10:17:42
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`differences in the declaration here. Let 10:17:43
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`me scroll to that section for you, but 10:17:47
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`they typically use a different circuit 10:17:49
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`design. There's tradeoffs between the 10:17:51
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`two. 10:17:54
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` One difference that I think 10:17:56
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`Dr. Baker and I point out with DRAM is it 10:17:57
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`needs to be periodically refreshed. 10:18:00
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`There's a number of other differences and, 10:18:02
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`generally, they're suited to -- one or the 10:18:04
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`other is typically better suited to a 10:18:07
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`different use within a given system design 10:18:09
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`or system architecture. 10:18:13
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` Q. You mentioned refresh. 10:18:18
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` What -- what do you mean by 10:18:19
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`"refresh"? 10:18:20
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` A. So I think if you go to the 10:18:22
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`section in my declaration around the 10:18:25
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`memory devices, I think it starts page 16, 10:18:29
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`maybe paragraph 50, that -- I mention that 10:18:33
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`because a DRAM or cell design includes a 10:18:36
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`capacitor, you've got this periodic 10:18:41
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`recharge or refresh so you can maintain 10:18:43
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`the state that's in those memory cells; 10:18:45
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`something you have to kind of deal with if 10:18:48
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`you're using DRAM. 10:18:51
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` Q. So when would this -- when does 10:18:53
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`this refresh happen? 10:18:57
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` MR. WUESTE: Objection, form. 10:19:00
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` A. The refresh is typically 10:19:03
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`performed pretty rapid interval for cells 10:19:06
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`in a DRAM chip or in a DRAM device. 10:19:11
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` (Reporter clarification.) 10:19:11
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` A. And that sort of refreshing to 10:19:24
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`maintain the state in those cells. It's 10:19:27
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`pretty rapid interval. I don't know if I 10:19:31
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`have the actual various timings from the 10:19:34
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`JEDEC standards, but we can go there and 10:19:36
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`take a look. 10:19:39
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`BY MR. COOK: 10:19:39
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` Q. Yeah, that isn't necessary right 10:19:40
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`now. 10:19:42
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` When a DRAM is being refreshed, 10:19:45
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`can you read or write to it? 10:19:47
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` MR. WUESTE: Objection, form. 10:19:51
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` A. So tip -- typically that's one 10:19:52
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`of the things that I think even the 10:19:55
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`background of some of the prior art 10:19:57
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`references talk about is, if you're doing 10:20:00
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`reads and writes to a DRAM, or a region of 10:20:03
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`DRAM that needs refreshing at that time, 10:20:06
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`it can intervene with the read or write 10:20:08
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`which, as the references talk about, 10:20:11
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`trying to do a burst there. 10:20:14
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` It can interfere with things so 10:20:15
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`it's something you -- you need to take 10:20:17
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`into account when designing these devices 10:20:18
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`in systems. 10:20:20
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`BY MR. COOK: 10:20:20
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` Q. And what do you mean "interfere 10:20:22
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`with things"? 10:20:24
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` A. Well, for example, I think even 10:20:26
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`the background of the '134 talks about if 10:20:28
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`you're trying to do, you know, these types 10:20:32
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`of bursts and a refresh is occurring, that 10:20:35
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`can interfere with the burst itself, you 10:20:38
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`know, if you're overlapping in regions and 10:20:43
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`memory that are being accessed or 10:20:45
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`refreshed, that kind of thing. 10:20:47
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` Q. So I'm just trying to understand 10:20:51
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`what "interfere" means. 10:20:53
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` Does that mean you cannot write 10:20:55
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`to that region if you're refreshing it? 10:20:57
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` MR. WUESTE: Objection, form. 10:20:59
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` A. Well, I think it's even -- even 10:21:00
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`Dr. Baker is saying that if you're trying 10:21:03
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`to access one of these regions or the 10:21:06
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`bursting, you know, when you're in this 10:21:09
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`refresh, there are sort of adverse effects 10:21:12
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`that can occur there; that's one of the 10:21:17
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`things that the various -- the background 10:21:19
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`of the patent talks about and so forth. 10:21:21
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`BY MR. COOK: 10:21:21
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` Q. What kind of adverse things can 10:21:28
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`happen if you're trying to refresh an area 10:21:30
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`in DRAM? 10:21:31
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` A. Well, it sort of can have timing 10:21:37
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`implications on things or interrupt a 10:21:39
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`burst, kind of things. It's something 10:21:42
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`that needs to be accounted for, just in 10:21:44
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`the general memory design, system design, 10:21:45
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`things like that. 10:21:47
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` Q. So you mentioned the refresh can 10:21:54
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`interrupt the burst. 10:21:58
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` What do you mean by that? 10:21:59
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` A. Well, I think if we're talking 10:22:00
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`about the '134 or the idea of, in your use 10:22:03
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`of burst here, perhaps accessing a DRAM, 10:22:12
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`when you're accessing a DRAM, which is 10:22:15
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`going to require a burst, you know, it can 10:22:17
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`be difficult. 10:22:20
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` (Reporter clarification.) 10:22:20
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` A. I think I'm talking about 10:22:20
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`paragraph 72, and so if you're talking 10:22:38
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`about a burst in the context of a burst 10:22:45
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`DRAM, as the '134 talks about, you can 10:22:49
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`have, you know, as I say here, quoting 10:22:54
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`from the reference, can be difficult 10:22:55
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`because of the need to do that refresh 10:22:57
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`that we just talked about for data in 10:22:59
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`those cells in the DRAM. 10:23:01
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`BY MR. COOK: 10:23:14
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` Q. So I think you're in paragraph 10:23:15
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`72. Are you referring to this sentence 10:23:17
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`conventional DRAM was difficult because of 10:23:22
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`the need to refresh data within the memory 10:23:24
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`cell"? 10:23:26
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` A. That's at least, yeah, one or 10:23:27
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`part of one of the sentences I was 10:23:29
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`referring to. 10:23:31
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` Q. And then you -- it goes on to 10:23:36
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`say "which might necessitate interrupting 10:23:37
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`the burst application and thus greatly 10:23:39
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`lengthen the amount of time required for 10:23:52
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`accessing data." 10:23:55
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` (Reporter clarification.)
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`BY MR. COOK:
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` Q. Let me read that again.
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`"Greatly lengthen the amount of time for
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`accessing data."
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` A. Yes, that's the second part of 10:24:01
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`that sentence. 10:24:04
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` Q. So what happens if a DRAM 10:24:14
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`refresh cycle occurs to a region of memory 10:24:16
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`that's currently undergoing a burst 10:24:20
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`operation? 10:24:22
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` A. So just as it says here, you 10:24:27
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`may -- in sort of the prior art, would 10:24:32
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`have to interrupt that burst, it -- 10:24:34
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`perhaps lengthen the amount of time 10:24:37
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`required for accessing data, things of 10:24:39
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`that nature. 10:24:41
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` You know, there's a little bit 10:24:42
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`more variability there versus knowing the 10:24:43
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`amount of time that, for instance, the 10:24:47
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`burst in this context would take, things 10:24:49
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`like that. 10:24:51
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` Q. Now, SRAM does not have to be 10:25:01
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`refreshed; is that right? 10:25:05
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` A. The SRAM design uses a different 10:25:06
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`structure. Typically, I think Dr. Baker 10:25:11
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`even agrees, without the capacitor effect 10:25:14
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`so you're not refreshing. 10:25:17
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` Q. Is that why it's called "static" 10:25:21
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`instead of "dynamic"? 10:25:24
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` A. Yeah, I think that's correct, 10:25:26
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`yes. 10:25:28
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` Q. If you'll look over at the 10:25:28
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`Exhibit Share, I'm adding an exhibit 10:25:49
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`there. This is previously marked Exhibit 10:25:52
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`1001, which is the '134 patent. 10:25:54
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` Would you open that up? 10:26:03
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` A. Okay. Okay. 10:26:05
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` Q. So is it your understanding that 10:26:37
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`the '134 patent -- one of the issues the 10:26:38
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`'134 patent is addressing is this 10:26:43
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`interruption of burst because of DRAM 10:26:46
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`refresh? 10:26:48
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` MR. WUESTE: Objection, form. 10:26:50
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` A. So -- so just to confirm, the -- 10:26:53
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`the -- the latest document I downloaded 10:26:56
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`is -- looks to be the '134 patent. 10:26:58
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`BY MR. COOK: 10:26:58
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` Q. Thank you. 10:27:01
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` A. And so -- sorry. Can I hear 10:27:03
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`your question again? 10:27:07
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` Q. Yeah. We were -- we were 10:27:09
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`talking about DRAM refresh and how that 10:27:09
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`causes interruptions to burst reads -- 10:27:14
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`burst reads and writes; is that righ