In the Matter of:
`
`Intel Corporation
`v.
`FG SRC LLC
`
`Dr. Stanley Shanfield
`
`May 13, 2021
`
`

`

`Dr. Stanley Shanfield
`
`1 (1)
`5/13/2021
`
` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` - - - - - - - - -x
`
` INTEL CORPORATION,
`
` Petitioner, Case Number:
` IPR2020-01449
` v. Patent Number:
` 7,149,867
` FG SRC LLC,
`
` Patent Owner.
`
` - - - - - - - - -x
`
` Thursday, May 13, 2021
` Videoconference
`
` Deposition of
`
` STANLEY SHANFIELD, PhD
`
` a witness, called for examination by Counsel on
` behalf of Patent Owner FG SRC LLC, pursuant to
` Notice, taken via Zoom Videoconference,
` commencing at approximately 10:08 o’clock a.m.,
` EDT, before Deborah J. J. Borchert, a Certified
` Verbatim Reporter, and an Electronic Notary
` Public in and for the State of Virginia at Large,
` when there were present on behalf of the
` respective parties:
`
` * * * * *
`
`Casamo & Associates
`
`703 837 0076
`
`www.casamo.com
`
`

`

`Dr. Stanley Shanfield
`
`2 (2)
`5/13/2021
`
` Appearances:
`
` Counsel on Behalf of the Petitioner, Intel
` Corporation:
`
` BRIAN C. NASH, ESQUIRE
` Pillsbury Winthrop Shaw Pittman LLP
` 401 Congress Avenue
` Suite 1700
` Austin, Texas 78701
` (512) 580-9600
`
` EVAN FINKEL, ESQUIRE
` Pillsbury Winthrop Shaw Pittman LLP
` 725 South Figueroa Street
` Suite 2800
` Los Angeles, California 90017-5406
` (213) 488-7100
`
` MATTHEW W. HINDMAN, ESQUIRE
` Pillsbury Winthrop Shaw Pittman LLP
` 2550 Hanover Street
` Palo Alto, California 94304
` (650) 233-4500
`
` GEMMA SUH, ESQUIRE
` Intel Corporation
` Managing Counsel
` Intel Litigation Group
` 2200 Mission College Boulevard
` Santa Clara, California 95054
` (408) 765-8080
`
`Casamo & Associates
`
`703 837 0076
`
`www.casamo.com
`
`

`

`Dr. Stanley Shanfield
`
`3 (3)
`5/13/2021
`
` Appearances: [Continued]
`
` Counsel on Behalf of the Patent Owner,
` FG SRC LLC:
`
` HENNING SCHMIDT, ESQUIRE
` JAY P. KESAN, ESQUIRE
` DiMuroGinsberg, PC-
` DGKeyIP Group
` 1750 Tysons Boulevard
` Suite 1500
` Tysons Corner, Virginia 22102
` (703) 289-5118
`
` MICHAEL W. SHORE, ESQUIRE
` ALFONSO G. CHAN, ESQUIRE
` ARI B. RAFILSON, ESQUIRE
` Shore Chan DePumpo LLP
` 901 Main Street
` Suite 3300
` Dallas, Texas 75202
` (214) 593-9110
`
` * * * * *
`
`Casamo & Associates
`
`703 837 0076
`
`www.casamo.com
`
`

`

`Dr. Stanley Shanfield
`
`4 (4)
`5/13/2021
`
` C O N T E N T S
`
` WITNESS PAGE
`
` Stanley Shanfield, PhD
`
` Examination by Mr. Schmidt 6
`
` * * * * *
`
`Casamo & Associates
`
`703 837 0076
`
`www.casamo.com
`
`

`

`Dr. Stanley Shanfield
`
`5 (5)
`5/13/2021
`
` E X H I B I T S
`
` DESCRIPTION PAGE
`
` Deposition Exhibit Number 1001 Premarked
` Patent 7,149,867
`
` Deposition Exhibit Number 1002 Premarked
` Utility Patent Application
` Transmittal
`
` Deposition Exhibit Number 1003 Premarked
` International Conference on
` Computer Design/VLSI in
` Computers and Processors
`
` Deposition Exhibit Number 1004 Premarked
` IEEE Computer Society
` Workshop on VLSI 2000/
` System Design for a System-
` on-Chip Era
`
` Deposition Exhibit Number 1005 Premarked
` Frontiers ‘96/The Sixth
` Symposium on the Frontiers
` of Massively Parallel
` Computing
`
` Deposition Exhibit Number 1006 Premarked
` Shanfield Declaration
` Supporting Intel’s Petition
`
` * * * * *
`
`Casamo & Associates
`
`703 837 0076
`
`www.casamo.com
`
`

`

`Dr. Stanley Shanfield
`
`6 (6 - 9)
`5/13/2021
`
`Page 6
`
` 1 P R O C E E D I N G S
`
` 2 Whereupon,
`
` 3 STANLEY SHANFIELD, PhD
`
` 4 a witness, was called for examination by Counsel
`
` 5 on behalf of Patent Owner FG SRC LLC, and, after
`
` 6 having been duly sworn by the Electronic Notary
`
` 7 Public, was examined and testified as follows:
`
` 8 EXAMINATION ON BEHALF OF PATENT OWNER
`
` 9 FG SRC LLC
`
`10 MR. SCHMIDT: Good morning, Dr.
`
`11 Shanfield. This is Henning Schmidt, with
`
`12 DiMuroGinsberg, and I’m representing FG Source
`
`13 LLC in this proceeding.
`
`14 With me is my colleague, Jay Kesan.
`
`15 THE WITNESS: Hi.
`
`16 MR. SCHMIDT: Brian, did you want to
`
`17 announce yourself and your team on the record?
`
`18 MR. NASH: Good morning, everyone. This
`
`19 is Brian Nash, here on behalf of the Petitioner.
`
`20 Also with me on the record is Matt
`
`21 Hindman and Evan Finkel; they are also from the
`
`22 Pillsbury law firm.
`
`Page 7
` 1 And we are also joined by Gemma Suh, an
` 2 in-house Counsel for Intel.
` 3 BY MR. SCHMIDT:
` 4 Q Dr. Shanfield, can you hear me okay?
` 5 A Yes.
` 6 Q Great. Am I pronouncing your name
` 7 correctly?
` 8 A Yes, you’ve got it right.
` 9 Q Do you understand that you are under
`10 oath this morning to testify truthfully and
`11 accurately, to the best of your ability?
`12 A Yes, I do.
`13 Q Is there any reason that you may not be
`14 able to testify accurately today?
`15 A No, no reason.
`16 Q Okay. Is there anything that might
`17 impair your ability to so testify?
`18 A No.
`19 Q And you do understand that you are in a
`20 deposition, in a proceeding before the PTAB, and
`21 the rules in this proceeding prevent you from
`22 discussing the substance of this deposition with
`
`Page 8
` 1 your Counsel until the end of the day, and the
` 2 close of this deposition; do you understand?
` 3 A Yes, I do.
` 4 Q Okay. So you’ve stated already you have
` 5 the exhibits handy. Do you have Exhibit 1006 in
` 6 this IPR handy, which is your Declaration?
` 7 A Yes, I do.
` 8 Q And I guess, for the record, let me
` 9 state the full title. It’s in IPR 2020-01449,
`10 regarding Patent Number 7,149,867. We are
`11 looking at Exhibit 1006, which is the Declaration
`12 of Stanley Shanfield, PhD, concerning U. S.
`13 Patent 7,149,867.
`14 MR. SCHMIDT: And Deb, can you hear me
`15 okay?
`16 COURT REPORTER: I can hear you fine,
`17 Counsel.
`18 MR. SCHMIDT: If I end up going too
`19 fast, or you have a difficult time understanding
`20 me or the witness, please let me know.
`21 COURT REPORTER: Yes, sir; thanks.
`22 MR. SCHMIDT: Thank you.
`
`Page 9
`
` 1 BY MR. SCHMIDT:
` 2 Q Dr. Shanfield, did you prepare for this
` 3 deposition?
` 4 A Yes, I did.
` 5 Q What did you do to prepare?
` 6 A I talked to Counsel, my Counsel, and
` 7 read the patent, read supporting materials that
` 8 are listed in the exhibits. And I think I have a
` 9 list in my Declaration of the materials I
`10 reviewed.
`11 Q Did you review any other materials, in
`12 addition to those?
`13 A No.
`14 Q Did you meet with anyone, telephonically
`15 or otherwise, to prepare?
`16 A Other than Counsel, no.
`17 [Audio interruption.]
`18 BY MR. SCHMIDT
`19 Q I’m sorry, I could not understand that.
`20 A I said, other than Counsel, no, I did
`21 not meet with anybody.
`22 Q Yes, I understood you. Somebody else
`
`Casamo & Associates
`
`703 837 0076
`
`www.casamo.com
`
`

`

`Dr. Stanley Shanfield
`
`7 (10 - 13)
`5/13/2021
`
`Page 10
` 1 spoke. I don’t know who spoke, or what they
` 2 said.
` 3 COURT REPORTER: I didn’t catch it
` 4 either; it was Cody Gartman. I don’t know what
` 5 was said.
` 6 MR. NASH: I think it might have just
` 7 been background.
` 8 MR. SCHMIDT: Oh, okay. All right,
` 9 we’ll move on then.
`10 BY MR. SCHMIDT:
`11 Q Dr. Shanfield, would you mind taking a
`12 look at the 867 patent, which is Exhibit 1001?
`13 A Sure.
`14 Q You have reviewed this patent, and this
`15 is the subject of your Declaration; right?
`16 A Yes, that’s correct.
`17 Q What is your understanding of this
`18 patent, or the invention of this patent?
`19 VOICE: Objection, form.
`20 THE WITNESS: Well, I think it’s
`21 described in the abstract that describes a
`22 reconfigurable processor, includes a
`
`Page 11
` 1 computational unit, data prefetch unit, coupled
` 2 to the computational unit, et cetera.
` 3 COURT REPORTER: I don’t know who
` 4 objected; they didn’t flash up on the screen.
` 5 MR. NASH: Hi, Deb, this is Brian Nash
` 6 for Pillsbury.
` 7 COURT REPORTER: Thank you, sir.
` 8 MR. NASH: I’m going to be the one
` 9 that’s speaking on behalf of the Petitioner
`10 today. So to the extent you hear an objection,
`11 it’s likely from me.
`12 COURT REPORTER: Thank you.
`13 Sorry, Counsel, for the interruption.
`14 MR. SCHMIDT: I guess for everyone else
`15 on the call, if you speak up, then it might make
`16 sense to announce who you are. For the most part
`17 it will be Brian and myself. But if anybody else
`18 speaks up, it will be helpful to announce who.
`19 BY MR. SCHMIDT:
`20 Q Okay, thanks Dr. Shanfield. So you
`21 mentioned a reconfigurable processor that
`22 includes certain components.
`
`Page 12
`
` 1 So specifically, the reconfigurable
` 2 processor of the 867 patent includes
` 3 computational units; right?
` 4 MALE VOICE: Objection, form.
` 5 THE WITNESS: Computational units are
` 6 mentioned in some of the claims.
` 7 BY MR. SCHMIDT:
` 8 Q I’m sorry, did you hear my question,
` 9 whether or not the configurable processor
`10 includes computational units?
`11 I believe that’s what you just said;
`12 right?
`13 MR. NASH: Objection, misstates
`14 testimony.
`15 THE WITNESS: So in the abstract, if I
`16 read a little further, it’s a reconfigurable
`17 processor that includes a computational unit, and
`18 a data prefetch unit coupled to the computational
`19 unit, where the data prefetch unit receives data
`20 from a memory, and supplies data to the
`21 computational unit.
`22 So clearly, there is a computational
`
`Page 13
`
` 1 unit being discussed in the 867.
` 2 Q Okay. And that computational unit
` 3 discussed in 867 is included in the
` 4 reconfigurable processor?
` 5 MR. NASH: Objection, form.
` 6 THE WITNESS: Well, I think you’d have
` 7 to be more specific. If I look at the definition
` 8 of a computational unit — I’m looking now in
` 9 column 5.
`10 And you asked does a reconfigurable
`11 processor include a computational unit? Am I
`12 hearing you correctly?
`13 BY MR. SCHMIDT:
`14 Q Yes.
`15 A So in column 5, starting at line 26 in
`16 the 867, a reconfigurable processor is defined as
`17 a computing device that contains reconfigurable
`18 components, such as FPGAs. So it contains
`19 reconfigurable components.
`20 And it can, through reconfiguration,
`21 instantiate an algorithm as hardware.
`22 So that’s my understanding of the
`
`Casamo & Associates
`
`703 837 0076
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`www.casamo.com
`
`

`

`Dr. Stanley Shanfield
`
`8 (14 - 17)
`5/13/2021
`
`Page 14
`
` 1 reconfigurable processor.
` 2 Q Does reconfigurable components include
` 3 computational units?
` 4 MR. NASH: Objection, form.
` 5 THE WITNESS: Like I said, I think we
` 6 have to get — you have to get more specific about
` 7 which system you’re referring to, and that way I
` 8 can answer your question.
` 9 It’s such a general question that I
`10 can’t give you a useful answer.
`11 BY MR. SCHMIDT:
`12 Q All right. You did say a minute ago, or
`13 you quoted to the abstract that said a
`14 reconfigurable processor that includes the
`15 computational unit and a data prefetch unit; did
`16 you not?
`17 MR. NASH: Objection —
`18 THE WITNESS: I did.
`19 MR. NASH: — misstates testimony.
`20 THE WITNESS: So could you repeat your
`21 statement? I’m sorry, I’d like to hear what you
`22 asked one more time.
`
`Page 15
`
` 1 BY MR. SCHMIDT:
` 2 Q I just want to understand if, in your
` 3 opinion, the reconfigurable processor can include
` 4 a computational unit, or does include a
` 5 computational unit.
` 6 A What I said came directly from the
` 7 abstract, that a reconfigurable processor that
` 8 includes a computational unit and a data prefetch
` 9 unit, coupled to the computational unit.
`10 That that is what’s being described in
`11 the patent. That was in answer to your original
`12 question.
`13 Q Okay. So just to get things clear. The
`14 question is, the 867 patent discloses a
`15 reconfigurable processor that includes the
`16 computational unit; is that correct?
`17 A That’s what it says in the abstract,
`18 yes.
`19 Q And do you agree that is what’s
`20 disclosed here in this patent?
`21 MR. NASH: Objection, form.
`22 THE WITNESS: Again, you’re asking a
`
`Page 16
` 1 general question, and I’m telling you what the
` 2 abstract describes as the subject matter.
` 3 So you need to be specific about what
` 4 system you’re referring to, as to whether or not
` 5 this particular reconfigurable processor includes
` 6 a computational unit.
` 7 There are certainly descriptions of that
` 8 in the patent, but I need a specific — a context
` 9 to tell you whether it’s present or not.
`10 Q So the 867 patent discloses at least
`11 some reconfigurable processors that include
`12 computational units; is that correct?
`13 A That include the computational unit.
`14 Right, that’s correct.
`15 Q Thank you. Can you point me to any
`16 instance in which 867 patent discloses a
`17 reconfigurable processor that does not include a
`18 computational unit?
`19 MR. NASH: Objection, form.
`20 THE WITNESS: I would have to think
`21 carefully about that. I hadn’t considered that
`22 in detail, and so I’d have to review each of the
`Page 17
`
` 1 descriptions.
` 2 I don’t know that you want me to be
` 3 spending that time reviewing the patent, because
` 4 it would take me a while to decide.
` 5 Q So as you sit here right now, with the
` 6 preparation that you have done so far, you cannot
` 7 immediately identify a reconfigurable processor
` 8 disclosed in the 867 patent that does not include
` 9 a computational unit; is that correct?
`10 A No, it’s not correct.
`11 Q Then can you please identify a
`12 reconfigurable processor disclosed in this patent
`13 that does not include a computational unit?
`14 A What I said was, it would take me a few
`15 minutes to identify and point out where, in the
`16 patent, it doesn’t include a computational unit.
`17 And that I didn’t — or I’m assuming
`18 you’re not going to give me the time to do that
`19 reviewing, because it would take a while.
`20 Q Okay. So that means right now you are
`21 not sure whether not the 867 patent discloses a
`22 reconfigurable processor that does not include a
`
`Casamo & Associates
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`703 837 0076
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`

`

`Dr. Stanley Shanfield
`
`9 (18 - 21)
`5/13/2021
`
`Page 18
`
` 1 computational unit?
` 2 MR. NASH: I’m going to object as beyond
` 3 the scope. I gave you some leeway here, Henning,
` 4 but you know the purpose of a cross-examination
` 5 is to be the scope of his Declaration.
` 6 So if you want to point to something
` 7 about the Declaration that’s on the subject — I
` 8 did let this proceed, but I feel like you’re
` 9 asking a lot of questions, and he’s saying he’s
`10 not going to give you an opinion off the seat of
`11 his pants. And I think that’s a prudent thing
`12 for an expert to say, so beyond the scope.
`13 BY MR. SCHMIDT:
`14 Q Dr. Shanfield, do you need me to restate
`15 the question?
`16 A Well, please do.
`17 Q So as you sit here right now, you are
`18 not sure whether the 867 patent does or does not
`19 disclose a reconfigurable processor that does not
`20 include a computational unit?
`21 MR. NASH: Objection, form, beyond the
`22 scope.
`
`Page 19
` 1 THE WITNESS: So it was not something I
` 2 considered in my analysis, and therefore, I would
` 3 require some time to do that right now. So I
` 4 can’t give you an answer until I do that
` 5 analysis.
` 6 It wasn’t something that I had discussed
` 7 in my Declaration, and I hadn’t done any analysis
` 8 of that question.
` 9 Q So to the best of your recollection, in
`10 your Declaration you did not identify any
`11 reconfigurable processor in this patent that does
`12 not include a computational unit; is that right?
`13 MR. NASH: Objection form; beyond the
`14 scope.
`15 THE WITNESS: There’s probably a long
`16 list of things that wasn’t analyzed in my
`17 Declaration.
`18 But what I did analyze was what was
`19 pertinent to the question of whether prior art
`20 existed already that was consistent with the 867
`21 patent. And that’s where my analysis went.
`22 BY MR. SCHMIDT:
`
`Page 20
`
` 1 Q I’m only asking about one specific
` 2 component. So I’m asking about a reconfigurable
` 3 processor that does not include a computational
` 4 unit. Is that described in your report or not?
` 5 MR. NASH: Objection, form.
` 6 THE WITNESS: Like I said, I did not
` 7 analyze that question, and I would need some time
` 8 to decide if that was the case.
` 9 BY MR. SCHMIDT:
`10 Q I’m asking you only what is in your
`11 report or not right now.
`12 A Well, if I didn’t analyze it, it’s not
`13 my report. But the — so it didn’t mean — it
`14 doesn’t mean I can’t do that at the moment, if
`15 you’d like me to.
`16 Q Okay. So it sounds like what you’re
`17 saying is that in your report you did not
`18 identify any reconfigurable processor in this
`19 patent that does not include a computational
`20 unit; is that correct?
`21 MR. NASH: Objection, form. I think
`22 there was like four double-negatives in there.
`Page 21
` 1 THE WITNESS: Right. And the answer is
` 2 no, anyway.
` 3 BY MR. SCHMIDT:
` 4 Q All right. Can you go back to the
` 5 definition that you were looking at a minute ago
` 6 on column 5 of the patent, line 25?
` 7 A Yes.
` 8 Q Can you give me your understanding of
` 9 what it means to instantiate an algorithm as
`10 hardware, in the context of this patent?
`11 MR. NASH: Objection, form.
`12 THE WITNESS: I think probably the best
`13 place to describe that is in the definition in
`14 the column 5, beginning at line 26, of a
`15 reconfigurable processor.
`16 It’s a computing device that contains
`17 reconfigurable components, such as FPGAs, and
`18 can, through reconfiguration, instantiate an
`19 algorithm as hardware.
`20 So that’s my understanding of what the
`21 term instantiate an algorithm as hardware means.
`22 BY MR. SCHMIDT:
`
`Casamo & Associates
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`703 837 0076
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`www.casamo.com
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`

`

`Dr. Stanley Shanfield
`
`10 (22 - 25)
`5/13/2021
`
`Page 22
`
` 1 Q The lines you have read give a
` 2 description of a reconfigurable processor. And
` 3 it says the capability of that processor is to
` 4 instantiate an algorithm as hardware.
` 5 I’m asking you what does it mean to
` 6 instantiate an algorithm as hardware?
` 7 MR. NASH: Objection, asked and
` 8 answered.
` 9 THE WITNESS: Yeah. I think I’ve given
`10 you the answer. An FPGA is a good example of how
`11 an algorithm can be instantiated as hardware.
`12 BY MR. SCHMIDT:
`13 Q Can you describe what is an FPGA?
`14 A It is a reconfigurable component, and it
`15 can be configured to instantiate an algorithm.
`16 Q And reconfigurable in this context,
`17 means it can instantiate different algorithms; is
`18 that correct?
`19 A Yes, that is correct. In other words,
`20 the algorithm that it was configured with can be
`21 reconfigured into another algorithm in logic.
`22 Q Can you give me an example of an
`
`Page 23
` 1 algorithm that can be instantiated as hardware?
` 2 A Yes. So if you go to page 56 of my
` 3 Declaration, paragraph 128, I am describing how
` 4 Zhang discloses a reconfigurable processor that
` 5 instantiates an algorithm as hardware.
` 6 And as I explained, the 867 patent
` 7 defines a reconfigurable processor as a computing
` 8 device that contains reconfigurable components,
` 9 such as FPGAs.
`10 Now FPGAs are integrated circuits that
`11 contain reconfigurable blocks of logic.
`12 The interconnects are also
`13 reconfigurable, and so it has the ability to be
`14 reprogrammed to instantiate a computer algorithm
`15 as hardware. And that is comprised of the
`16 reconfigurable logic circuits.
`17 Q My question was whether you could give
`18 me an example of an algorithm that can be
`19 instantiated as hardware.
`20 MR. NASH: Objection, asked and
`21 answered.
`22 [Pause]
`
`Page 24
` 1 MR. NASH: Is there a question pending,
` 2 Henning?
` 3 MR. SCHMIDT: Yes.
` 4 BY MR. SCHMIDT:
` 5 Q Dr. Shanfield, do you recall my
` 6 question?
` 7 MR. NASH: You just made a statement. I
` 8 don’t think you actually asked a question.
` 9 THE WITNESS: Maybe you could repeat
`10 yourself.
`11 BY MR. SCHMIDT:
`12 Q My question is still, can you give me an
`13 example of an algorithm that can be instantiated
`14 as hardware?
`15 MR. NASH: Objection, asked and
`16 answered.
`17 BY MR. SCHMIDT:
`18 Q Dr. Shanfield, if you’re having trouble
`19 coming up with an algorithm that you could give
`20 as an example, let me ask you this. Are you
`21 familiar —
`22 A I’m not.
`
`Page 25
`
` 1 Q I’m sorry; go ahead.
` 2 A I’m not, I was deciding what I was going
` 3 to say, but go ahead.
` 4 Q Are you familiar with an algorithm
` 5 called the bubble sort?
` 6 A The bubble sort?
` 7 Q Uh-huh.
` 8 A No.
` 9 Q Are you familiar with any kind of
`10 sorting algorithm?
`11 A Yes.
`12 Q Can you give me an example of a sorting
`13 algorithm?
`14 A Well, I’d rather finish my answer, since
`15 you cut me off. I’d like to go and give you the
`16 example which I was about to discuss. Would that
`17 be all right?
`18 Q Sure.
`19 A So probably the best or cleanest example
`20 of this is taught in Zhang. If you go to
`21 paragraph 137 in my Declaration, it’s on page 62.
`22 Zhang is teaching this reconfigurable
`
`Casamo & Associates
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`703 837 0076
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`

`Dr. Stanley Shanfield
`
`11 (26 - 29)
`5/13/2021
`
`Page 26
` 1 processor that includes a data prefetcher. And
` 2 that happens to be the claimed prefetch unit
` 3 which is coupled to the first memory in claim 1.
` 4 So it’s performing an algorithm, which
` 5 is prefetching, to move data between members of
` 6 the memory hierarchy; the L1 and L2 memory.
` 7 Q So in your opinion, the data prefetch
` 8 unit is implementing an algorithm here?
` 9 MR. NASH: Objection form; misstates
`10 testimony.
`11 THE WITNESS: What I said was that Zhang
`12 is teaching a reconfigurable processor that
`13 includes a data prefetcher, and that data
`14 prefetcher is this claimed data prefetch unit.
`15 The algorithm is what is moving, or the
`16 method of which the prefetcher — and I think the
`17 example I provide further on is in a matrix
`18 multiplication, as far as matrix multiplication
`19 algorithm for moving data from the L2 memory to
`20 the L1 memory, moving data only.
`21 That’s an algorithm that’s been
`22 instantiated in hardware.
`
`Page 27
`
` 1 BY MR. SCHMIDT:
` 2 Q What would you call that particular
` 3 algorithm?
` 4 Can we assign it a name, just for ease
` 5 of reference, like the prefetching algorithm for
` 6 example, or something like that?
` 7 MR. NASH: Objection, form.
` 8 THE WITNESS: Yeah, all right. That’s
` 9 shorthand, that’s fine.
`10 Q Okay. So the prefetching algorithm is
`11 exclusively instantiated in the data prefetch
`12 unit; is that correct?
`13 MR. NASH: Objection, form.
`14 THE WITNESS: So the data prefetch unit,
`15 if you go back to column 5, starting at line 40,
`16 it’s a functional unit that moves data between
`17 members of a memory hierarchy.
`18 You’re trying to equate that with the
`19 algorithm? Could you ask your question again?
`20 BY MR. SCHMIDT:
`21 Q Yes. My question was not related to the
`22 term, data prefetch unit, used in the 867 patent,
`
`Page 28
`
` 1 but to the term, data prefetch unit, in your
` 2 paragraph 137.
` 3 So the data prefetcher that you’re
` 4 describing here in the first sentence of
` 5 paragraph of 137, is where that prefetching
` 6 algorithm is instantiated; is that right?
` 7 MR. NASH: Objection, form.
` 8 THE WITNESS: That’s not what I said.
` 9 BY MR. SCHMIDT:
`10 Q Okay. Can you please clarify what you
`11 said then? I may have misunderstood.
`12 A Actually, it says it pretty clearly in
`13 paragraph 137, that Zhang is teaching a
`14 reconfigurable processor that includes a data
`15 prefetcher that is the claimed data prefetch unit
`16 which is coupled to a first memory.
`17 It is a functional unit configured to
`18 move data between members of the memory
`19 hierarchy.
`20 Q So the prefetching algorithm we
`21 discussed, is it instantiated in the
`22 reconfigurable processor, or is it instantiated
`Page 29
`
` 1 in the data prefetcher?
` 2 MR. NASH: Objection, form.
` 3 THE WITNESS: Well, I don’t know how to
` 4 answer that question, since it’s — you’re taking
` 5 a term that I am not sure I understand the
` 6 meaning of.
` 7 BY MR. SCHMIDT:
` 8 Q Which term?
` 9 A Because the reconfigurable processor
`10 includes a data prefetcher, trying to — I mean,
`11 essentially, that’s what I’m saying.
`12 That is the claimed data prefetch unit
`13 in the case that I’m talking about, with respect
`14 to claim 1, a data prefetch unit coupled to a
`15 first memory.
`16 I was attempting to create a context for
`17 your question, and I’m talking specifically about
`18 the statement in claim 1.
`19 So your general questions, I guess I
`20 have trouble answering, because there’s much too
`21 much latitude in the meaning of the words. So
`22 I’m focusing on a specific claim element which
`
`Casamo & Associates
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`Dr. Stanley Shanfield
`
`12 (30 - 33)
`5/13/2021
`
`Page 30
`
` 1 uses the words you’re using.
` 2 Q Let’s take a look at the Zhang reference
` 3 itself. Do you have that handy?
` 4 A Yes.
` 5 Q Okay. Could you take a look at Figure
` 6 2? It’s on page 152 of the reference.
` 7 A Yes.
` 8 Q Could you please describe what this
` 9 figure shows?
`10 MR. NASH: Objection, form.
`11 THE WITNESS: So I would refer you to my
`12 paragraph 125 in my Declaration, where I’ve given
`13 a description, and even some color-coding in
`14 Figure 2.
`15 If you look at Figure 2 — it’s just
`16 below or in the middle of paragraph 125 — I’m
`17 showing like components.
`18 A reconfigurable processor, which is not
`19 in Figure 2, a processor/CPU, that’s what’s in
`20 yellow, and a first level cache.
`21 And then the processor main memory is in
`22 green. So that’s what my description is of
`
`Page 31
`
` 1 Figure 2.
` 2 BY MR. SCHMIDT:
` 3 Q So looking at your paragraph 125,
` 4 showing the annotated or highlighted version of
` 5 Figure 2 of Zhang shows a CPU there. Do you see
` 6 that?
` 7 A Yes.
` 8 Q That stands for central processing unit;
` 9 is that right?
`10 A Yes. Processor, CPU, yes.
`11 Q Is the central processing unit,
`12 disclosed in Zhang, reconfigurable in your
`13 opinion?
`14 MR. NASH: Objection, form.
`15 THE WITNESS: It is. And that’s what —
`16 underneath the CPU, the box says, programmable
`17 logic, and that indicates that it is.
`18 BY MR. SCHMIDT:
`19 Q So it is your opinion that the CPU,
`20 disclosed in Zhang, is a reconfigurable processor
`21 by itself?
`22 MR. NASH: Objection, form.
`
`Page 32
` 1 THE WITNESS: So again, you’re asking a
` 2 very general question. And the answer is that
` 3 Zhang discloses a reconfigurable processor.
` 4 And the variety of disclosures he makes
` 5 is probably the best way to go, in terms of
` 6 deciding how much of it is reconfigurable, or
` 7 what that box means.
` 8 But there’s no question, in my mind,
` 9 about what Zhang is disclosing, which is a
`10 processor that’s reconfigurable. And that’s what
`11 that box indicates.
`12 BY MR. SCHMIDT:
`13 Q In your paragraph 125, you say, Relevant
`14 figures are produced below, and have been color-
`15 coded to show the configurations of like
`16 components: reconfigurable processor (pink).
`17 So in Figure 1, is pink referring to the
`18 co-processor, the box that’s highlighted?
`19 A Well, it is in Figure 1, yeah.
`20 Q Okay. In Figure 2 you drew a pink
`21 rectangle around the entire figure. So is that
`22 what you identify as a reconfigurable processor?
`Page 33
`
` 1 A Yes.
` 2 Q So the reconfigurable processor includes
` 3 CPU, cache, memory, network interface, and the
` 4 programmable logic, and the flexible interconnect
` 5 that’s depicted here; yes?
` 6 A That’s correct.
` 7 Q Okay. So this reconfigurable processor
` 8 you have identified includes a component that is,
` 9 in fact, a CPU; is that correct?
`10 MR. NASH: Objection, form.
`11 THE WITNESS: What Zhang is attempting
`12 to illustrate in a diagram here, is the fact that
`13 the CPU is programmable or the processor is
`14 programmable.
`15 And also the memory, the cache, it’s
`16 programmable, it can be.
`17 The network interface contains
`18 programmable logic, so it is hardware that can be
`19 programmed. That’s all that’s implied in the
`20 fact that I put a pink box around Figure 2.
`21 Everything in there has programmable
`22 logic associated with it, meaning it can be
`
`Casamo & Associates
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`

`Dr. Stanley Shanfield
`
`13 (34 - 37)
`5/13/2021
`
`Page 34
`
` 1 programmed in hardware.
` 2 Q So are you saying that the CPU has
` 3 programmable logic associated with it?
` 4 A What Zhang is attempting to illustrate
` 5 in the diagram is that it’s a processor, and he
` 6 uses the term CPU. And that processor is
` 7 programmable, it’s reconfigurable.
` 8 And that’s why I enclose it in a pink
` 9 box.
`10 Q Can you take a look at page 151 of
`11 Zhang, the paragraph 2.2, Co-processing?
`12 A Yes.
`13 MR. NASH: Sorry, Henning, I’m trying to
`14 follow along. Can you just tell me where we’re
`15 at? I was opening that document.
`16 MR. SCHMIDT: Yeah, sure. Page 151 of
`17 Zhang, Exhibit 1003, Section 2.2 Co-processing.
`18 MR. NASH: Great, thank you so much.
`19 MR. SCHMIDT: Sure.
`20 BY MR. SCHMIDT:
`21 Q Dr. Shanfield, so this section here
`22 reads, The most common architecture in embedded
`Page 35
` 1 computing systems to exploit programmable logic
` 2 can be characterized as one of co-processing,
` 3 i.e., a processor working in conjunction with
` 4 dedicated hardware assists, to deliver a specific
` 5 application.
` 6 The hardware assists are built using
` 7 programmable circuit blocks for easy
` 8 interpretation with the predesigned CPU. Do you
` 9 see that?
`10 A Yes.
`11 Q What is your understanding of the
`12 predesigned CPU that is referenced here?
`13 A Zhang’s point comes in the last sentence
`14 of that paragraph where he says, This — meaning
`15 this arrangement — presents an obstacle of
`16 exploiting programmable logic for general-purpose
`17