UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 1
`
`APPLE INC., )
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` )
`
` Petitioner, ) Case IPR2021-00305
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` ) Patent 10,506,325
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`vs. )
`
` ) Case IPR2021-00381
`
`KOSS CORPORATION, ) Patent 10,491,982
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` )
`
` Patent Owner. )
`
` The Zoom video deposition of JOSEPH
`
` McALEXANDER, III, taken before Richard Derrick
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` Ehrlich, Registered Merit Reporter, Certified
`
` Realtime Reporter, taken pursuant to the United
`
` States Patent and Trademark Office Rules, commencing
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` at 9:00 a.m., on the 14th day of December, 2021.
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`Veritext Legal Solutions
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`Apple 1025
`Apple v. Koss
`IPR2021-00381
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`1
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`
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
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`APPLE INC., )
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` )
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` Petitioner, ) Case IPR2021-00305
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` ) Patent 10,506,325
`
`vs. )
`
` ) Case IPR2021-00381
`
`KOSS CORPORATION, ) Patent 10,491,982
`
` )
`
` Patent Owner. )
`
` The Zoom video deposition of JOSEPH
`
` McALEXANDER, III, taken before Richard Derrick
`
` Ehrlich, Registered Merit Reporter, Certified
`
` Realtime Reporter, taken pursuant to the United
`
` States Patent and Trademark Office Rules, commencing
`
` at 9:00 a.m., on the 14th day of December, 2021.
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`Veritext Legal Solutions
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`Apple 1025
`Apple v. Koss
`IPR2021-00381
`
`1
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`Page 2
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` A P P E A R A N C E S
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`On behalf of Apple Inc.:
` Michael T. Pieja
` Jennifer Hartjes
` GOLDMAN ISMAIL TOMASELLI BRENNAN & BAUM LLP
` 200 South Wacker Drive
` 22nd Floor
` Chicago, IL 60606
` mpieja@goldmanismail.com
` jhartjes@goldmanismail.com
`
` Ryan Chowdhury
` Roberto Devoto
` Parvine Ghane
` FISH & RICHARDSON P.C.
` 1000 Main Avenue, SW
` Suite 1000
` Washington, D.C. 20024
` rchowdhury@fr.com
` rdevoto@fr.com
` pghane@fr.com
`
`On behalf of Koss Corporation:
`
` Mark G. Knedeisen
` Michelle Weaver
` K&L GATES LLP
` 210 Sixth Avenue
` Pittsburgh, PA 15222-2613
` mark.knedeisen@klgates.com
` michelle.weaver@klgates.com
`
`Videographer: Justin Henricksen
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` I N D E X
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` Page
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`Exam by Michael Pieja 5
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`Page 3
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` E X H I B I T S
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` Page
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`Exhibit No. 2035 - 12
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`Declaration of Joseph C. McAlexander, III
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`Exhibit No. 2038 - 15
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`Declaration of Joseph C. McAlexander, III
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`Exhibit No. 1004 - 75
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`United States Patent Application Publication
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`Exhibit No. 2036 - 104
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`Declaration of Nicholas S. Blair
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`Page 4
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` VIDEOGRAPHER: Good morning. We are going
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` on the record. The time is 11:32 a.m. on
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` December 14th, 2021.
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` This is Media Unit 1 of the video-recorded
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` deposition of Joseph McAlexander, III, taken by
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` counsel for the petitioner in the matter of
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` Apple Inc. vs. Koss Corporation filed in the
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` United States Patent and Trademark Office, Case
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` No. IPR2021-00381 and IPR2021-00305.
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` This deposition is being held remote Zoom
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` videoconference. My name is Justin Henricksen,
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` and I'm from the firm Veritext, and I'm the
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` videographer. The court reporter is Richard
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` Ehrlich from the firm Veritext.
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` I'm not related to any party in this
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` action, nor am I financially interested in
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` outcome.
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` Counsel and all present in the room,
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` everyone attending remotely will now state their
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` appearances and affiliations for the record. If
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` there are any objections to the proceedings,
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` please state them at the time of your appearance
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` beginning with the taking attorney first.
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` MR. PIEJA: Good morning. Michael Pieja of
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`Page 5
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` Goldman Ismail on behalf of Apple, the
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` petitioner in this action.
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` Also present on the line appearing on
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` behalf of Apple are Jennie Hartjes of Goldman
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` Ismail and Parvine Ghane and Roberto Devoto and
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` Ryan Chowdhury of Fish & Richardson.
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` MR. KNEDEISEN: Mark Knedeisen from K & L
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` Gates for patent owner Koss Corporation. I
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` believe also on the line is Michelle Weaver from
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` K & L Gates.
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` VIDEOGRAPHER: Thank you.
`
` Will the court reporter please swear in the
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` witness?
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` JOSEPH McALEXANDER, DEPONENT, SWORN
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` EXAMINATION
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`BY MR. PIEJA:
`
`Q Good morning, Mr. McAlexander.
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`A I guess it still is. Good morning.
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`Q Indeed. I do apologize for the delay this
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` morning, and I thank you for your patience and
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` appreciate your taking the time to stick with us
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` while we got those administrative issues sorted
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` out.
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` Can you state your full name for the
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` record?
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`A Full name is Joseph Colby McAlexander, III.
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`Q Where are you sitting for your deposition today,
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` sir?
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`A I'm sitting in my home office in Anna, Texas.
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`Q Is there anyone else present with you in the
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` room where you're sitting for your deposition?
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`A No, sir. Nobody.
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`Q And are you communicating with anybody else via
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` any apps on either your phone or your computer
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` or any other electronic device as you sit there
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` to take -- to sit for this deposition?
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`A No.
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` MR. KNEDEISEN: Let me just note, Michael,
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` that I emailed -- sent him two emails with the
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` exhibits.
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` MR. PIEJA: Absolutely. Thank you for the
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` clarification, Mr. Knedeisen.
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`BY MR. PIEJA:
`
`Q Mr. McAlexander, do you understand that you're
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` here today to be deposed in -- with regard to
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` declarations you submitted in connection with
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` two IPR proceedings, IPR2021-305 and
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` IPR2021-381?
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`Page 7
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`A Yes. I have that understanding.
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`Q In both of those proceedings, you submitted a
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` declaration as an external expert on behalf of
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` Koss Corporation, the patent owner, correct?
`
`A Yes, that's correct.
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`Q You have been deposed before, right, sir?
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`A Yes.
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`Q Given that, I won't go through all of the ground
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` rules that I would normally go through at the
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` beginning of a deposition, but let me just touch
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` on one or two things.
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` As I said, I appreciate your patience so
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` far today. It's been a little while, but I will
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` do my best not to keep you sitting in that chair
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` for too long at any one stretch and try to give
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` you a break about every hour or so. If you feel
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` that you need a break earlier than that, just
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` let me know and I'll do my best to get you one
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` just as soon as I can. Okay?
`
`A Sure. Thank you.
`
`Q And I'll do my best to ask you questions that
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` you can understand. If you don't understand my
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` question, just let me know and I'll do my best
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` to rephrase it to get you something that you
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`Page 8
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` feel you can answer. Sound fair?
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`A Yes. That's fair.
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`Q Of course if you don't let me know that you're
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` having trouble understanding my questions, I'll
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` assume that you do know them and can answer them
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` to the best of your ability. Sound fair?
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`A I understand that, yes.
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`Q Sir, can you think of any reason why sitting
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` here today you wouldn't be able to truthfully
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` and fully testify as to the opinions and
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` statements made in the two declarations that I
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` referenced earlier today?
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`A No, I have no reason.
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`Q You're not feeling ill or a doctor hasn't asked
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` you to take any medicine that might impair your
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` ability to either remember the facts relevant to
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` those declarations or to hear the questions I'm
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` asking you?
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`A No, I have no advice to that extent.
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`Q And related to what I mentioned before, you
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` testified and explained that you weren't
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` communicating with anybody using any apps or
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` programs apart from the emails that
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` Mr. Knedeisen had sent you to provide you with
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`Page 9
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` certain exhibits to this deposition, correct?
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`A That is correct, yes.
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`Q And so that we can have a complete record of the
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` proceedings here in the transcript as opposed to
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` externally, will you agree not to communicate
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` with anybody about this deposition either
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` through a chat app or any other means of
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` electronic communication other than speaking on
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` this deposition while we're on the record?
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`A Yes. I agree to that.
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`Q Do you have in front of you either in physical
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` or electronic form copies of the declarations
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` that you submitted in the two IPR proceedings
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` that this deposition is covering?
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`A Yes. I have a hard copy of the declaration, of
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` each of those declarations.
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`Q Okay. Do you also have an electronic copy of
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` the two declarations that we're talking about
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` here today?
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`A Well, I have it on my computer. I don't have it
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` in front of me. My understanding is counsel has
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` forwarded a couple of emails to me. So at some
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` point I'm assuming that if I look in those
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` emails, I will find the electronic copies.
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`Page 10
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`Q Perfect. So feel free, obviously, to refer to
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` either the printed copy or the electronic copy
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` of your declarations as needed.
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`A Okay.
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`Q If at any point you do need to take a moment to
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` get the electronic copies up on the screen,
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` please just let me know. I'll take a break and
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` let you get those documents situated and in
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` front of you. Sound fair?
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`A That sounds fair. And I do recognize that I did
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` receive a first email from counsel.
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`Q Just so that the record is clear, is the email
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` you're referring to, Mr. McAlexander, an email
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` from Mr. Knedeisen?
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`A Yes. It's an email that I just received from
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` Mr. Knedeisen effective 11:35 a.m. Central time,
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` and that covers -- it looks like he has attached
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` seven documents.
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`Q So for the record, per the parties' discussion,
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` the emails that you're receiving from
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` Mr. Knedeisen include local PDF copies of
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` documents that I have marked through the Exhibit
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` Share system, all of which are materials that
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` were provided as exhibits in the IPRs at issue
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` here. You can expect, I think, to receive
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` another one of those emails.
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` And, again, if at any point during the
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` deposition you need to refer to the electronic
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` copies of the documents that Mr. Knedeisen has
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` sent you, just let me know and we'll take the
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` time to get that set up and documented on the
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` record. Okay?
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`A All right. Very good. Thank you.
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`Q Let's just set up some terminology before I go
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` any further here. Referring to the first of the
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` two IPRs that you are here to testify about,
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` IPR2021-305, is it your understanding that that
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` IPR involves U.S. Patent No. 10,506,325?
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`A That is correct.
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`Q Is it all right if I refer to that patent as the
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` '325 patent for today's purposes?
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`A Yes. That's perfectly fine.
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`Q You prepared a declaration expressing certain
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` opinions that you had formed in connection with
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` the '325 patent in this proceeding, correct?
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`A Yes. That's correct.
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`Q You have a copy that have declaration -- your
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` '325 declaration in front of you today, sir,
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` correct?
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`A Yes. Yes, I do.
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`Q Okay. The declaration that you prepared in
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` connection with the '325 patent is marked as
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` Exhibit Koss-2035 in the 305 IPR, correct?
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`A That is correct.
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`Q For the purposes of today's proceeding, is it
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` okay if I refer to that declaration as your '325
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` patent declaration?
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`A Yes. That's fine.
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` (Exhibit No. 2035 marked.)
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`BY MR. PIEJA:
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`Q Does the declaration that you filed in
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` connection with the '325 patent include all of
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` the opinions that you had formed and intend to
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` express with respect to that patent in this
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` proceeding?
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`A As of the time of the filing, the answer is yes.
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`Q You haven't prepared any supplemental
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` declarations that you submitted through the
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` patent office subsequent to the filing of your
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` declaration on the '325 patent, have you?
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`A That is correct. I have not.
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` MR. KNEDEISEN: Objection. Form.
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`BY MR. PIEJA:
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`Q Do you presently have an intention to file any
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` additional supplemental -- withdrawn.
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` Do you presently have an intention to
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` prepare any supplemental or additional
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` declarations in support of your positions or
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` opinions on the '325 patent?
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` MR. KNEDEISEN: Objection. Form.
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` THE DEPONENT: Not presently, no.
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`BY MR. PIEJA:
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`Q So as of the current time sitting here today,
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` the declaration that you have submitted to the
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` patent office in connection with the '325 patent
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` contains all of the opinions that you had formed
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` and intend to express with respect to that
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` patent in this proceeding, correct?
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` MR. KNEDEISEN: Asked and answered.
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` Objection. Form.
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` THE DEPONENT: I would say they may not
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` include all of the opinions I have, but they
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` are -- they do contain all the opinions that I
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` intend to express.
`
`BY MR. PIEJA:
`
`Q Okay.
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`Page 14
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`A Other than what may come forth from the
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` deposition today.
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`Q Now, the second of the two IPRs that you are
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` here to testify about is IPR2021-381, correct?
`
`A That is correct.
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`Q That IPR involves U.S. Patent No. 10,491,982,
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` correct?
`
`A Correct.
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`Q Is it all right with you if I refer to that
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` patent as the '982 patent for today's purposes?
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`A Yes.
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`Q And you prepared a declaration expressing
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` certain opinions that you had formed in
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` connection with the '982 patent in this
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` proceeding, correct?
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`A That is correct.
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`Q You have a copy of your declaration with respect
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` to the '982 patent in front of you today, sir,
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` correct?
`
`A Yes, I have a hard copy in front of me.
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`Q And the declaration that you prepared in
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` connection with the '325 patent is marked as
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` Exhibit Koss-2038 in the 381 IPR, correct?
`
`A 2038, yes.
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` (Exhibit No. 2038 marked.)
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`BY MR. PIEJA:
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`Q For the purposes of today's proceeding, is it
`
` okay if I refer to that declaration as your '982
`
` patent's declaration?
`
`A Yes. That's fine.
`
`Q Does the declaration that you filed in
`
` connection with the '982 patent include all of
`
` the opinions that you have formed and intend to
`
` express with respect to the '982 patent in this
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` proceeding?
`
`A The same answer to a prior question. They may
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` not contain all of the opinions that I have
`
` formed, but certainly with regard to those that
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` I intend to express, they are contained in this
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` document.
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`Q You haven't prepared any supplemental
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` declarations that you have submitted or intend
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` to submit to the patent office with respect to
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` the '982 patent, correct?
`
`A That is correct.
`
`Q You don't presently have an intention to prepare
`
` any such declarations, correct?
`
`A Not presently.
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`Q If you could get out your '325 declaration, if
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` you could. Let me know when you have that in
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`Page 16
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` front of you.
`
`A I have it.
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`Q Would you turn, sir, to internal page 44 of your
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` '325 patent declaration?
`
`A Internal page what?
`
`Q 44, sir.
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`A 44?
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`Q Yes, sir.
`
`A All right. The only thing I printed was up
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` through my signature page, page 40. So let me
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` see if that has been presented here in the
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` emails.
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` MR. KNEDEISEN: It's in the second email.
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`BY MR. PIEJA:
`
`Q I'll represent to you, sir, that page 44 of
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` Exhibit 2035, which is your '325 declaration, is
`
` the first page of Appendix A, which is styled
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` "Curriculum Vitae of Joseph McAlexander, III."
`
`A Okay.
`
`Q Let me know if you're able to bring that up in
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` digital form.
`
` MR. KNEDEISEN: That's probably in the
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` first email we sent.
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` THE DEPONENT: It looks like in the first
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` email that was sent, it was the 381 declaration.
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` MR. KNEDEISEN: It should be in the second
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` email. Did you get that yet?
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` THE DEPONENT: No, sir. That hasn't come
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` in yet. Let me refresh.
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`BY MR. PIEJA:
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`Q The good news, Mr. McAlexander, is that if you
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` don't have the declaration in the 305
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` proceeding, I can ask this set of questions just
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` as easily with respect to the declaration that
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` you do have from the 381 proceeding.
`
`A Okay.
`
`Q So let me know -- if you haven't gotten your
`
` '325 declaration in yet, just let me know and
`
` we'll flip over and ask the questions for the
`
` one you do have. Okay?
`
`A All right. It still has not been received, so
`
` let's look at the Koss 2038 declaration.
`
`Q Yes. So just for the record, Mr. McAlexander,
`
` please get your '982 patent's declaration in
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` front of you. I'm going to direct you within
`
` that declaration to page 61. Let me know when
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` you're there.
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`A So this is PDF page 61, which is the first page
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` of my CV. I have it in front of me now.
`
`Q So as you said, Mr. McAlexander, page 61 of your
`
` '982 patent declaration is entitled "Curriculum
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` Vitae," correct?
`
`A Yes, that's correct.
`
`Q The pages from 61 to 91 of your '982 patent
`
` declaration all comprise various parts of your
`
` curriculum vitae, correct?
`
`A That is correct.
`
`Q The curriculum vitae that you submitted with
`
` your '982 declaration was accurate and complete
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` to the best of your ability at the time you
`
` signed that declaration, correct?
`
`A Yes. I have had several revisions of it since
`
` then, but it was accurate as far as I know at
`
` that time.
`
`Q What were the nature of those revisions?
`
`A The nature of the revisions is this particular
`
` one represented a middle-of-third-quarter
`
` representation of 2021, and it had -- typically
`
` I keep in my CV a representation of the cases
`
` that go back five years, and this had actually
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`Page 19
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` more than five years in some instances. So I
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` was basically redacting those and just making it
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` up-to-date to -- you know, looking at the cases
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` for the last five years.
`
`Q Apart from an update to the list of legal
`
` matters in which you had been retained, were
`
` there any other revisions or amendments to your
`
` CV since you submitted it with your '982
`
` declaration?
`
`A Not as I recall. I mainly worked on just
`
` updating the cases that are identified in the
`
` CV.
`
`Q If you could turn to internal page 67 of your
`
` '982 declaration, please, and let me know when
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` you're there.
`
`A I am there.
`
`Q Do you see the bottom third of page 67 of your
`
` '982 declaration is a section entitled
`
` "Education Profile"?
`
`A Yes, I do.
`
`Q Does the material under the Education Profile
`
` section of your CV fairly and accurately reflect
`
` your formal education starting with your
`
` bachelor's degree and continuing to the present?
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`A Yes, it does.
`
`Q You note in your Education Profile that you
`
` received a Bachelor's of Science, I believe in
`
` electrical engineering from NC State University
`
` in 1969; is that correct?
`
`A Yes. That's correct.
`
`Q Am I right that the BSEE designation refers to a
`
` Bachelor of Science in Electrical Engineering?
`
`A Yes, that's correct.
`
`Q Did you have any specific sub-concentration
`
` within the field of electrical engineering when
`
` you took your degree from NC State?
`
`A Solid state.
`
`Q Could you explain in layman's terms what you
`
` mean by "solid state"?
`
`A There are two primary venues that one could take
`
` in terms of focused areas: Solid-state
`
` electronics, which is lower power, as compared
`
` to power electronics, which is like power
`
` services, you know, for powering homes and
`
` residences and that type of thing. So rather
`
` than the high power, mine was solid-state
`
` electronics.
`
`Q Did your studies for your BSEE degree involve
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`Page 21
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` any study of wireless communications?
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`A There was some wireless communication at that
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` time, yes, but that was a few years ago. But,
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` yes, there were some.
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`Q Safe to say that neither Bluetooth nor WiFi
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` existed at the time of your studies for your
`
` BSEE degree, correct?
`
`A As we know it today, no.
`
`Q Did your studies for your electrical engineering
`
` degree at NC State involve any study of
`
` headphones or audio products?
`
`A It had studies involving audio products at the
`
` system level in terms of speakers, transducers,
`
` that type of thing. Certainly the components
`
` that go into that kind of a system but not in
`
` terms of headphones per se.
`
`Q Did your studies for your electrical engineering
`
` degree involve the study of any digital or
`
` analog audio processing?
`
`A It was part of the curriculum in terms of just
`
` analog versus digital, and there was analog
`
` processing in speech or sound. It would be a
`
` part of that, yes, for analog-to-digital and
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` digital-to-analog conversion.
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`Page 22
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`Q Did your studies for your electrical engineering
`
` degree involve any study relating to batteries
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` or battery composition?
`
`A If you're talking about the chemistry of it, the
`
` answer is no. In terms of storage batteries,
`
` storage facilities, yes, you know, that was part
`
` of the curriculum. Storage techniques.
`
`Q In addition to your bachelor's degree from NC
`
` State, you also studied at the University of
`
` Texas as a graduate student, correct?
`
`A Yes, that's correct.
`
`Q Your studies at the University of Texas were in
`
` 1975 and '76, correct?
`
`A Yes, that is correct.
`
`Q While at the University of Texas, you were at
`
` the Graduate School of Biomedical Science,
`
` correct?
`
`A Yes, that's correct.
`
`Q Your studies at UT were focused in the area of
`
` neural science, correct?
`
`A Yes, specifically focused on neural physiology
`
` as applied to vision and audio or let's say --
`
` yeah, audio and/or vision.
`
`Q Did your studies or work at the University of
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` Texas involve any studies of headphones or audio
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`Page 23
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` products?
`
`A No, sir, did not.
`
`Q Did your studies at the University of Texas
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` involve any study of or work with speakers or
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` acoustic transducers?
`
`A No.
`
`Q Did your studies at the University of Texas
`
` involve the study of or work with digital or
`
` analog audio processing?
`
`A Yes.
`
`Q In what way?
`
`A In the research studies that I worked at as a
`
` part of the graduate program, we were measuring
`
` visual and auditory response characteristics,
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` and that's looking at the neural activity within
`
` animals doing neural probing, looking at their
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` visual and auditory response to various stimuli
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` and processing that using fairly sophisticated
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` analog techniques at that time.
`
`Q Did your study at the University of Texas
`
` involve any study of batteries or similar power
`
` sources?
`
`A No, sir, did not.
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`
`
`Q In addition to your graduate studies and your
`
` bachelor's degree, you've listed on your CV that
`
` from 1980 to 1985 you taught certain courses; is
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`Page 24
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` that correct?
`
`A Yes, that's correct.
`
`Q At what institution did you teach those courses?
`
`A The course -- the course instruction was done to
`
` the professional engineering staff at Texas
`
` Instruments during that period of time. I
`
` taught the courses both in U.S. as well as in
`
` Singapore.
`
`Q On your CV, I see that there are two different
`
` entries for the courses that you taught under
`
` the time period 1980 to 1985.
`
` Do you see that?
`
` MR. KNEDEISEN: Objection.
`
` THE DEPONENT: Yes. I see three, but go
`
` ahead.
`
`BY MR. PIEJA:
`
`Q So the first paragraph that I see -- withdrawn.
`
` The first paragraph that I see next to the
`
` numbers 1980 to 1985 in your CV states, Taught
`
` solid state device physics, semiconductor
`
` processing, circuit design techniques, and
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`Page 25
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` statistical quality control measures.
`
` Do you see that?
`
`A Yes, I do.
`
`Q Is that a description of some of the courses
`
` that you taught to the professional staff at
`
` Texas Instruments?
`
`A That's an overview of some of the courses, yes.
`
`Q Below that I see an entry that states,
`
` Effectiveness training and Japanese
`
` manufacturing techniques, Participative problem
`
` solving courses.
`
` Do you see that?
`
`A Yes. Yes, I do.
`
`Q Is that also a description of the courses that
`
` you taught to the professional staff at Texas
`
` Instruments?
`
`A Yes.
`
`Q Did any of the courses that you taught to the
`
` professional staff at Texas Instruments relate
`
` to headphones or audio products?
`
`A The solid-state device physics and semiconductor
`
` processing related to the actual design and
`
` fabrication and assembly and test of electronic
`
` components that would go into multiple different
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`
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`Page 26
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` kinds of systems, some of which would be
`
` auditory.
`
`Q Were any of the courses that you taught to the
`
` professional staff at Texas Instruments
`
` specifically directed to headphones or audio
`
` products?
`
`A Not specifically directed. It was directed to
`
` the design and integration of the types of
`
` products that would go into different kinds of
`
` systems, including audio.
`
`Q Did any of the courses that you taught to the
`
` professional staff at Texas Instruments relate
`
` to acoustics?
`
`A There would be a relationship in terms of some
`
` of the device physics to acoustics, not
`
` directed -- not as a course taught specifically
`
` focused on acoustics, but certainly strong
`
` relationship with some of the fundamental
`
` physics and electrical aspects of those courses
`
` that would relate to acoustics.
`
`Q Did any of the courses that you taught to the
`
` professional staff at Texas Instruments relate
`
` to digital or analog audio processing?
`
`A Yes. Quite a bit of the design and the
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`Page 27
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` analytical aspects would relate to both analog
`
` and digital processing.
`
`Q I would like to talk a little bit about your
`
` work experience, if I could.
`
`A Certainly.
`
`Q From 1972 to 1986, you were employed by Texas
`
` Instruments; is that correct?
`
`A That's correct.
`
`Q What was the general nature of your work for
`
` Texas Instruments during that time?
`
` MR. KNEDEISEN: Objection. Form.
`
` THE DEPONENT: And this, again, was '72 to
`
` '86, just to verify?
`
`BY MR. PIEJA:
`
`Q Yes.
`
`A Okay. I started in 1972 after my military
`
` service with Texas Instruments, and that was
`
` specifically integrated circuit design as a
`
` design engineer focusing on various types of
`
` memory storage devices and products that would
`
` relate to that.
`
` So the career was basically focused on
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` design, modeling, implementation of circuit
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` designs and following those designs through the
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`
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`Page 28
`
` wafer fabrication process all the way to the
`
` assembly and to the testing, evaluation,
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` reliability studies, and then customer
`
` interface. So that's where I started in 1972.
`
` I continued as a designer for a number of
`
` years, including taking management slots as a
`
` design section manager sometime around 19--
`
` excuse me -- around '74. So it is 19. I had to
`
` make sure I got the right decade here. In 1974.
`
` By 1976, I had moved into a product slot
`
` where I was still -- still had engineering
`
` design management under me but also worked
`
` directly with the customer interface for
`
` instantiation of the design products in customer
`
` houses like IBM, Burroughs, UNIVAC, and many
`
` other system houses.
`
` I then in 19 -- around 1976, I took over
`
` the entire product cost center for all of the
`
` integrated circuit development, which included
`
` the design, the assembly, the test, the
`
` reliability studies, the marketing, and all the
`
` financial aspects with regard to those products.
`
` Then around 1981 to -- I listed this as '81
`
` and '82. That time frame, I continued to take
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`
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`Page 29
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` over much of the operation of those products,
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` including the interface to the overseas
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` accounts.
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` And then in 1982 to '84 for three years, I
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` moved to Singapore and taught all of the
`
` engineering staff there on device physics and
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` wafer processing for the preparation of TI's
`
` installation subsequent to that of an actual
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` wafer fabrication facility in Singapore. So I
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` was preparing the students for that, or the
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` engineers for it.
`
` I also ran the entire quality an
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