·1· · · ·UNITED STATES PATENT AND TRADEMARK OFFICE
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`Page 1
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`·2· · · · · · · · · · ·_____________
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`·3· · · · BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`·4· · · · · · · · · · ·_____________
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`·5
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`·6· · · · · IPR2021-01549 (Patent 9,997,240 B2)
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`·7· · · · · IPR2021-01547 (Patent 8,891,298 B2)
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`·8· · · · · IPR2021-01548 (Patent 9,196,385 B2)1
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`·9
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`10
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`13· ·MICRON TECHNOLOGY, INC.,
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`14· · · · · · · · Petitioner
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`15· · · · v.
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`16· ·VERVAIN, LLC,
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`17· · · · · · · · Patent Owner
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`18· ·_____________
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`19
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`20
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`21· · · · · REMOTE DEPOSITION OF DR. DAVID LIU
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`22· · · · · · · · · · November 1, 2022
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`23· ·Job#: 219133
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`24· ·Reported by:
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`25· ·Bonnie Pruszynski, RMR
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`Vervain Ex. 2020, p.1
`Micron v. Vervain
`IPR2021-01549
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`Page 1
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`·2· · · · · · · · · · ·_____________
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`·3· · · · BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`·4· · · · · · · · · · ·_____________
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`·5
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`·6· · · · · IPR2021-01549 (Patent 9,997,240 B2)
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`·7· · · · · IPR2021-01547 (Patent 8,891,298 B2)
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`·8· · · · · IPR2021-01548 (Patent 9,196,385 B2)1
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`·9
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`10
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`11
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`12
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`13· ·MICRON TECHNOLOGY, INC.,
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`14· · · · · · · · Petitioner
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`15· · · · v.
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`16· ·VERVAIN, LLC,
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`17· · · · · · · · Patent Owner
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`18· ·_____________
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`19
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`20
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`21· · · · · REMOTE DEPOSITION OF DR. DAVID LIU
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`22· · · · · · · · · · November 1, 2022
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`23· ·Job#: 219133
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`24· ·Reported by:
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`25· ·Bonnie Pruszynski, RMR
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`Vervain Ex. 2020, p.1
`Micron v. Vervain
`IPR2021-01549
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`·1
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`·6· · · · · · · · · · · · · · · · · ·November 1, 2022
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`·7· · · · · · · · · · · · · · · · · ·8:00 a.m.
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`·8
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`·9
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`10· · · · · · · · · · · ·REMOTE DEPOSITION OF DR. DAVID
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`11· ·LIU, before Bonnie Pruszynski, CA Certified
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`12· ·Shorthand Reporter No. 13064, a Registered Merit
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`13· ·Reporter, Certified Livenote Reporter, and Notary
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`14· ·Public of the States of New York and Florida.
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`Vervain Ex. 2020, p.2
`Micron v. Vervain
`IPR2021-01549
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`Page 3
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`·1· ·APPEARANCES:
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`·2
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`·3· ·For the Patent Owner:
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`·4· ·MCKOOL SMITH
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`·5· ·1999 K Street, NW
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`·6· ·Washington, DC 20006
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`·7· ·BY:· ARVIND JAIRAM, ESQ.
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`·8
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`·9· ·For the Petitioner:
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`10· ·ORRICK, HERRINGTON & SUTCLIFFE LLP
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`11· ·222 Berkeley Street
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`12· ·Boston, MA 02116
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`13· ·BY:· PARTH SAGDEO,· ESQ.
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`Vervain Ex. 2020, p.3
`Micron v. Vervain
`IPR2021-01549
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`·1· · · · · · ·(Witness sworn.)
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`·2· ·DAVID LIU,
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`·3· · · · · ·called as a witness, having been first
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`·4· · · · · ·duly sworn, was examined and testified
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`Page 4
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`·5· · · · · ·as follows:
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`·6· ·EXAMINATION
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`·7· ·BY MR. JAIRAM:
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`·8· · · ·Q.· · Good morning, Dr. Liu.
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`·9· · · ·A.· · Good morning.
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`10· · · ·Q.· · I know you've been in depositions
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`11· ·before, including in the cases that we are
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`12· ·going to discuss today, but I am still going
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`13· ·to go over some basic housekeeping
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`14· ·information regarding depositions so that the
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`15· ·record is complete.· Okay?
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`16· · · ·A.· · Please.
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`17· · · ·Q.· · You understand you have been placed
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`18· ·under oath today just as though you were in
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`19· ·court?
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`20· · · ·A.· · Yes, I do.
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`21· · · ·Q.· · Do you understand that you are
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`22· ·bound to answer my questions truthfully
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`23· ·today?
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`24· · · ·A.· · Yes, I do.
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`25· · · ·Q.· · Are you aware of any reason that
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`Vervain Ex. 2020, p.4
`Micron v. Vervain
`IPR2021-01549
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`·1· ·you are unable to answer my questions
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`Page 5
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`·2· ·truthfully today?
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`·3· · · ·A.· · No, I don't.
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`·4· · · ·Q.· · And are you taking any medications
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`·5· ·that would prevent you from providing honest,
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`·6· ·accurate, and complete answers?
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`·7· · · ·A.· · No, I'm not.
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`·8· · · ·Q.· · Or any health conditions that would
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`·9· ·prevent you from providing honest, accurate,
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`10· ·and complete answers?
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`11· · · ·A.· · No, I don't believe I do.
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`12· · · ·Q.· · Do you understand that you have to
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`13· ·answer my questions even if your counsel
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`14· ·objects, unless he directly instructs you not
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`15· ·to answer?
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`16· · · ·A.· · Yes, I do.
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`17· · · ·Q.· · I would also like to caution you
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`18· ·not to discuss the substance of your
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`19· ·testimony during your breaks.· Okay?
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`20· · · ·A.· · Yes.
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`21· · · ·Q.· · Dr. Liu, is anyone in the room with
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`22· ·you today?
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`23· · · ·A.· · Only Parth, who is defending me in
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`24· ·this deposition.
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`25· · · ·Q.· · Do you have any documents with you
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`Vervain Ex. 2020, p.5
`Micron v. Vervain
`IPR2021-01549
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`·1· ·in the room today, either electronic or hard
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`Page 6
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`·2· ·copy?
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`·3· · · ·A.· · I don't have any documents with me,
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`·4· ·no electronic or hard copy, except the ones
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`·5· ·that you have uploaded via Zoom, and those
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`·6· ·will be standby for me to -- to go through if
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`·7· ·I need them.
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`·8· · · ·Q.· · Okay.· I will be asking you
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`·9· ·questions today about your declarations
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`10· ·submitted in support of Micron's replies in
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`11· ·IPR proceedings involving three patents, and
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`12· ·I will refer to those IPRs as the '298 IPR,
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`13· ·the '385 IPR, and the '240 IPR.· Okay?
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`14· · · ·A.· · Sounds fair.
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`15· · · ·Q.· · And for convenience, I will refer
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`16· ·to those reply declarations that you
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`17· ·submitted as the '298 reply declaration, '385
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`18· ·reply declaration, and '240 reply
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`19· ·declaration.· Okay?
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`20· · · ·A.· · I'm fine with that.
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`21· · · ·Q.· · And if I need to refer to the
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`22· ·declarations that you submitted in support of
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`23· ·Micron's petitions in those IPRs, I will
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`24· ·refer to them as the '298 original
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`25· ·declaration, '385 original declaration, and
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`Vervain Ex. 2020, p.6
`Micron v. Vervain
`IPR2021-01549
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`Page 7
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`·1· ·'240 original declaration, okay?
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`·2· · · ·A.· · I'm fine with that as well.
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`·3· · · ·Q.· · And I realize that that there are a
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`·4· ·lot of declarations and IPRs here, so, if you
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`·5· ·have a question at any point about which IPR
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`·6· ·or which declaration that we are talking
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`·7· ·about, please feel free to ask for
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`·8· ·clarification.· Okay?
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`·9· · · ·A.· · Yes, I will.
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`10· · · ·Q.· · Can you please turn to the '298
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`11· ·patent.· Actually, you don't have any patents
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`12· ·in front of you, correct, or --
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`13· · · ·A.· · I can open the files that you have
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`14· ·uploaded, if --
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`15· · · ·Q.· · Yeah, that will be okay.
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`16· · · · · · ·Can you please open the '298
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`17· ·patent, which is Exhibit 1001 in IPR
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`18· ·2021-01547.
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`19· · · ·A.· · So, I guess --
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`20· · · · · · ·MR. SAGDEO:· Sorry.· There's a
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`21· · · ·pop-up.· So I'm just going to instruct
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`22· · · ·Dr. Liu to hit cancel on that pop-up.
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`23· · · · · · ·THE WITNESS:· Okay.
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`24· · · ·A.· · Yeah.· I'm more of an Apple person,
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`25· ·so you have to bear with me.· I think --
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`Vervain Ex. 2020, p.7
`Micron v. Vervain
`IPR2021-01549
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`·1· · · ·Q.· · Just to clarify the record, Dr. Liu
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`Page 8
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`·2· ·is using an Orrick computer.
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`·3· · · ·A.· · Right, which I am not as familiar,
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`·4· ·obviously, in terms of navigation.· I'm a
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`·5· ·simple person, so I use Apple.
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`·6· · · · · · ·Okay.· So, I have it opened now
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`·7· ·Arvind.
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`·8· · · ·Q.· · You have Exhibit 1001 in the 01547
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`·9· ·proceeding?
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`10· · · ·A.· · Let me see what exhibit is.
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`11· · · · · · ·Yes.· 1001, yes, and it has a label
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`12· ·IPR2021-01547.
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`13· · · ·Q.· · We will talk about the '298 patent
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`14· ·and the '298 IPR for a little bit.· During
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`15· ·that time, for convenience, I may refer to
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`16· ·the '298 reply declaration that you submitted
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`17· ·as just "the reply declaration" for short.
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`18· ·Is that okay?
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`19· · · ·A.· · Sure.· Would you like me to open
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`20· ·that as well right now?
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`21· · · ·Q.· · No, no.· You can, if you would
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`22· ·like.· I was kind of just going over the
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`23· ·nomenclature that we can use to talk about it
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`24· ·to avoid confusing you or the record.
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`25· · · · · · ·So, you see that claim one of the
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`Vervain Ex. 2020, p.8
`Micron v. Vervain
`IPR2021-01549
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`·1· ·'298 patent includes a limitation that begins
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`Page 9
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`·2· ·with the words, quote, "allocate those
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`·3· ·blocks," end quote; correct?
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`·4· · · ·A.· · I'm -- I need -- I'm going to
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`·5· ·have -- I need my counsel for a moment.
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`·6· ·Could you please give me a minute?
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`·7· · · · · · ·MR. SAGDEO:· Sure.· Let's just go
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`·8· · · ·off the record for just a minute.
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`·9· · · · · · ·(Discussion held off the record.)
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`10· · · · · · ·MR. SAGDEO:· So, Arvind, basically,
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`11· · · ·Dr. Liu isn't so comfortable using this
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`12· · · ·Windows computer, and we'd like to switch
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`13· · · ·to the Mac.· Can we just go off the
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`14· · · ·record and take like just a five-minute
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`15· · · ·break to have him set up everything, and
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`16· · · ·we'll come back and get started?
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`17· · · · · · ·MR. JAIRAM:· Sure.
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`18· · · · · · ·THE WITNESS:· It's easier for me to
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`19· · · ·navigate.· Thank you for the
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`20· · · ·accommodation.
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`21· · · · · · ·MR. JAIRAM:· Of course.
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`22· · · · · · ·(Recess from 8:08 to 8:18 a.m.)
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`23· · · · · · ·MR. JAIRAM:· We can go on the
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`24· · · ·record.
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`25· · · ·Q.· · So, Dr. Liu, you have in front of
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`Vervain Ex. 2020, p.9
`Micron v. Vervain
`IPR2021-01549
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`·1· ·you the '298 patent in the IPR 2021-01547;
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`Page 10
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`·2· ·correct?
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`·3· · · ·A.· · That's correct.
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`·4· · · ·Q.· · Can you please turn to claim one of
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`·5· ·the '298 patent and let me know when you are
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`·6· ·there.
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`·7· · · ·A.· · I'm there.
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`·8· · · ·Q.· · Do you see towards the end of claim
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`·9· ·one, there is a limitation that begins with
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`10· ·the words, quote, "allocate those blocks,"
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`11· ·end quote?
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`12· · · ·A.· · Yes, I do.
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`13· · · ·Q.· · You addressed this allocating
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`14· ·limitation in your reply declaration at
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`15· ·paragraph 15; right?
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`16· · · ·A.· · What's that document number?· Can
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`17· ·you please let me know, and I can open it and
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`18· ·I can flip to that one.
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`19· · · ·Q.· · It's Exhibit 1057 in the '298 IPR.
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`20· · · ·A.· · Okay.
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`21· · · ·Q.· · In the 01547 proceeding.
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`22· · · ·A.· · Okay.
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`23· · · ·Q.· · So, in paragraph 15 of your '298
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`24· ·reply declaration, you address the allocating
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`25· ·limitation of claim one of the '298 patent;
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`Vervain Ex. 2020, p.10
`Micron v. Vervain
`IPR2021-01549
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`Page 11
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`·1· ·correct?
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`·2· · · ·A.· · That's correct.
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`·3· · · ·Q.· · Can you please read aloud the last
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`·4· ·sentence of paragraph 15 of your reply
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`·5· ·declaration?
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`·6· · · ·A.· · The '298.
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`·7· · · ·Q.· · Yes.· The '298 reply declaration,
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`·8· ·the same one that we just mentioned regarding
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`·9· ·paragraph 15.· Do you see that paragraph?
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`10· · · ·A.· · Yes, I do.
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`11· · · ·Q.· · Can you please read aloud the last
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`12· ·sentence of paragraph 15 of that declaration?
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`13· · · ·A.· · "Instead, allocating a block to SLC
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`14· ·refers to allocating the logical block to SLC
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`15· ·by reassigning the logical block address to a
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`16· ·physical SLC block."
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`17· · · ·Q.· · So, what you have written at
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`18· ·paragraph 15 is what your understanding of
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`19· ·allocating those blocks refers to; correct?
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`20· · · · · · ·MR. SAGDEO:· Object to form.
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`21· · · ·Q.· · So, what you have written at
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`22· ·paragraph 15 is your understanding of
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`23· ·allocating those blocks; correct?
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`24· · · · · · ·MR. SAGDEO:· Same objection.
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`25· · · ·A.· · I think what I am stating is, a
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`Vervain Ex. 2020, p.11
`Micron v. Vervain
`IPR2021-01549
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`Page 12
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`·1· ·POSA would read and find it obvious that
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`·2· ·allocating a block to SLC will refer -- will
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`·3· ·cover the scope of referring to allocating
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`·4· ·the logical block to SLC by assigning the
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`·5· ·logical block address to a physical SLC
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`·6· ·block.
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`·7· · · ·Q.· · I understand that's what the words
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`·8· ·of the sentence say, Dr. Liu.· I'm asking
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`·9· ·you, in writing that sentence, you were
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`10· ·expressing what you believe that allocating a
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`11· ·block means; correct?
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`12· · · · · · ·MR. SAGDEO:· Object to form.
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`13· · · ·A.· · I think perhaps a better way to say
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`14· ·it, to answer your question, would be, a POSA
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`15· ·will understand that this sentence will be
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`16· ·covered under the scope of the claim
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`17· ·limitation.
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`18· · · ·Q.· · The claim limitation, which is
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`19· ·labeled as D in claim one, goes on to explain
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`20· ·how the allocating is performed; correct?
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`21· · · ·A.· · In the sentence, there is a verb,
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`22· ·an action, and there is object that received
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`23· ·the action, so, a POSA would read it as
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`24· ·allocating the block.· Okay?· And then, of
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`25· ·course, there may be a modifier to the block.
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`Vervain Ex. 2020, p.12
`Micron v. Vervain
`IPR2021-01549
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`·1· ·It's allocating those blocks to at least one
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`Page 13
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`·2· ·SLC non-volatile memory module.
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`·3· · · · · · ·So, there is an allocate, what we
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`·4· ·allocate.· We are allocating those blocks.
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`·5· ·Allocating to where?· To the at least one SLC
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`·6· ·non-volatile memory module.
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`·7· · · · · · ·So, you parse the sentence with the
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`·8· ·most important thing, the verb, the object,
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`·9· ·and what the verb is doing.
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`10· · · ·Q.· · The claim limitation that starts
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`11· ·with "allocate those blocks" specifically
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`12· ·recites that the allocation is by
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`13· ·transferring "the respective contents of
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`14· ·those blocks to the at least one SLC
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`15· ·non-volatile memory module."· Correct?
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`16· · · ·A.· · As I mentioned, that modifies
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`17· ·the -- those blocks.· Okay.· And the
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`18· ·"allocate" is simply the -- the verb.
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`19· ·Allocate is simply to allocate the blocks to
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`20· ·the SLC non-volatile memory module.
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`21· · · ·Q.· · The last limitation of claim one
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`22· ·recites allocating by transferring; correct?
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`23· · · ·A.· · I am parsing the sentence.· The
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`24· ·transferring or the modifying, receiving --
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`25· ·those are modifying, but the keyword is, we
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`Vervain Ex. 2020, p.13
`Micron v. Vervain
`IPR2021-01549
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`Page 14
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`·1· ·are allocating the blocks, and who are we
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`·2· ·allocating a block to?· We are allocating to
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`·3· ·the SLC non-volatile memory module.
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`·4· · · ·Q.· · Limitation B -- strike that.
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`·5· · · · · · ·The last limitation of claim one
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`·6· ·specifies how the allocating is performed;
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`·7· ·correct?
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`·8· · · ·A.· · Can you repeat the question?· I'm
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`·9· ·not sure -- I'm not sure if my answer is
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`10· ·somehow not meeting -- yeah.· Can you repeat
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`11· ·the question, please?
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`12· · · ·Q.· · The last limitation of claim one
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`13· ·specifies how the allocating is performed;
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`14· ·correct?
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`15· · · ·A.· · I will categorize as in the
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`16· ·process, allocating those blocks, which could
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`17· ·be logical block or physical block, to the
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`18· ·SLC non-volatile memory module, in the course
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`19· ·of performing the allocating the block, which
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`20· ·under the scope could be both logical or
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`21· ·physical, and you -- there is a modifier, by
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`22· ·transferring the respective content of those
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`23· ·blocks.· So, you could be transferring the
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`24· ·content of a logical block into -- to at
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`25· ·least one SLC non-volatile memory module.
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`Vervain Ex. 2020, p.14
`Micron v. Vervain
`IPR2021-01549
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`·1· · · · · · ·But the keyword is "allocate," and
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`·2· ·I am opining "allocate" is to have this block
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`Page 15
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`·3· ·and then to allocate it to an SLC
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`·4· ·non-volatile memory module.
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`·5· · · ·Q.· · I am not focusing right here about
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`·6· ·whether something is logical or physical. I
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`·7· ·am just simply asking if you understand that
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`·8· ·the allocating in the last limitation of
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`·9· ·claim one is explicitly specified as by
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`10· ·transferring the respective contents of those
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`11· ·blocks.· Do you see that in the last
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`12· ·limitation?
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`13· · · ·A.· · Yes, I do, and the reason I brought
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`14· ·that in is because I'm trying to provide a
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`15· ·context.· The -- you can see from my
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`16· ·paragraph 15, the word "allocate" would have
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`17· ·better meaning under certain definition
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`18· ·rather compared to the other definition, the
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`19· ·other context, and it is my opinion, which is
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`20· ·clearly stated in paragraph 15.
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`21· · · · · · ·So, that's why I mentioned the
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`22· ·nature of the block, to provide context.· And
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`23· ·that's being consistent with my reply
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`24· ·declaration paragraph 15.
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`25· · · ·Q.· · Claim one doesn't recite logical
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`Vervain Ex. 2020, p.15
`Micron v. Vervain
`IPR2021-01549
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`Page 16
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`·1· ·blocks; correct?
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`·2· · · · · · ·MR. SAGDEO:· Object to form.
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`·3· · · ·A.· · Claim one, the word "logical" is in
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`·4· ·claim one, and there's a lot of indication,
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`·5· ·for example, logical address range, and we
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`·6· ·know claim two obviously qualifies that to be
`
`·7· ·a block.· So, logical address range, address
`
`·8· ·range is a block, so logical block is implied
`
`·9· ·there.
`
`10· · · · · · ·But if you ask the term "logical
`
`11· ·block," no, it may not explicitly be there.
`
`12· ·I would have to go through it.· But the -- as
`
`13· ·I opine, clearly, claim one does not limit
`
`14· ·the scope, covered logical block as well as
`
`15· ·physical block.· In fact, as a POSA will read
`
`16· ·it, and an expert sitting here, I would think
`
`17· ·that logical block in many ways would map to
`
`18· ·claim one, would satisfy claim one limitation
`
`19· ·much better.
`
`20· · · ·Q.· · Is it your contention, Dr. Liu,
`
`21· ·that the claimed logical address ranges
`
`22· ·recited in claim one are the logical blocks
`
`23· ·that you just now spoke of?
`
`24· · · · · · ·MR. SAGDEO:· Object to form.
`
`25· · · ·A.· · I think you are taking my testimony
`
`Vervain Ex. 2020, p.16
`Micron v. Vervain
`IPR2021-01549
`
`
`
`·1· ·out of context, and perhaps I should be more
`
`Page 17
`
`·2· ·specific.· I'm not strictly pointing to
`
`·3· ·logical address range as a block, but it is
`
`·4· ·very clear that these logical address are
`
`·5· ·defined by a minimum quanta, so, you cannot
`
`·6· ·just have an address, you know, without --
`
`·7· ·for example, my physical address of my home,
`
`·8· ·it's a house.· You cannot divide into half a
`
`·9· ·house.
`
`10· · · · · · ·So, there is a minimum quanta here,
`
`11· ·and clearly claim two refer that in the
`
`12· ·logical address where you go by minimum
`
`13· ·quanta, one feature of that minimum quanta is
`
`14· ·you go to one block.· So, my testimony, just
`
`15· ·to be clear on the record, is that in the
`
`16· ·logical address range, which is defined by,
`
`17· ·or demarcated, I should say, by this minimum
`
`18· ·quanta, and that minimum quanta in claim two
`
`19· ·says clearly it's one block.· It is not --
`
`20· ·it's one block.· Therefore, you can certainly
`
`21· ·read the logical address range that consists
`
`22· ·of a minimum quanta, having a minimum quanta
`
`23· ·of addresses to be a block, and therefore,
`
`24· ·it's just as a logical address, it's a
`
`25· ·logical block.
`
`Vervain Ex. 2020, p.17
`Micron v. Vervain
`IPR2021-01549
`
`
`
`·1· · · · · · ·I think we have been -- I mean, I
`
`Page 18
`
`·2· ·think I have been very consistent in my
`
`·3· ·declaration regarding this matter.
`
`·4· · · ·Q.· · You spoke of logical address
`
`·5· ·ranges.· In what context are the logical
`
`·6· ·address ranges recited in claim one?
`
`·7· · · · · · ·MR. SAGDEO:· Object to form.
`
`·8· · · ·A.· · I think you would have to bracket
`
`·9· ·your question a little better, because it's
`
`10· ·a -- it's a -- I think it's a very broad
`
`11· ·question.
`
`12· · · ·Q.· · In claim one, the phrase "logical
`
`13· ·address ranges" is recited in the context of
`
`14· ·an address map comprising a list of logical
`
`15· ·address ranges; correct?
`
`16· · · ·A.· · Specifically, the address map
`
`17· ·comprising the list of logical address range,
`
`18· ·it's -- that map, it indicates there is a
`
`19· ·mapping or correlation of mapping between a
`
`20· ·logical block and a physical block.· And
`
`21· ·that's what controller or FTL does.
`
`22· · · ·Q.· · The controller maps physical blocks
`
`23· ·to logical blocks, you are saying?
`
`24· · · ·A.· · That's one function controller
`
`25· ·would do.· Controller would maintain -- let
`
`Vervain Ex. 2020, p.18
`Micron v. Vervain
`IPR2021-01549
`
`
`
`Page 19
`
`·1· ·me just read out the claim -- "maintain the
`
`·2· ·address map."· So, what does the "map" mean?
`
`·3· ·Maps going from point A to point B., so, of
`
`·4· ·at least the module MLC or SLC non-volatile
`
`·5· ·memory module, and then the address will
`
`·6· ·comprise certain things, a list of logical
`
`·7· ·address range, which the host or computer
`
`·8· ·sees, and the list of logical address range
`
`·9· ·and the minimum quanta of address, which we
`
`10· ·know would include a block.
`
`11· · · ·Q.· · I'm just trying to understand what
`
`12· ·you meant when you said that's what
`
`13· ·controller or FTL does.· I believe your
`
`14· ·specific testimony a minute or two ago was:
`
`15· ·That map, it indicates there is a mapping or
`
`16· ·correlation of mapping between a logical
`
`17· ·block and a physical block, and that's what
`
`18· ·controller or FTL does.· There might be one
`
`19· ·or two words incorrect, because I am looking
`
`20· ·at the feed that I am seeing here.
`
`21· · · · · · ·When you say that's what the
`
`22· ·controller does, what is "that"?
`
`23· · · · · · ·MR. SAGDEO:· Object to form.
`
`24· · · ·A.· · I am simply reading out the claim
`
`25· ·limitation.· It says:· "Wherein" -- this is
`
`Vervain Ex. 2020, p.19
`Micron v. Vervain
`IPR2021-01549
`
`
`
`Page 20
`
`·1· ·of course referring to the controller, that
`
`·2· ·maintains an address map, and it says,
`
`·3· ·"wherein each entry in the list of logical
`
`·4· ·address ranges maps to a similar range of
`
`·5· ·physical addresses."
`
`·6· · · · · · ·So -- and taking into the context a
`
`·7· ·logical address consists of quanta, and the
`
`·8· ·quanta can be block, I'm simply paraphrasing
`
`·9· ·the statement of the claim.· Now, I did
`
`10· ·not -- I am not saying that's all the
`
`11· ·controller does.· I'm just simply reading the
`
`12· ·claim limitation in one, in claim one, and
`
`13· ·when it refers to the controller and the
`
`14· ·function, at least part of the function of
`
`15· ·the controller, I'm simply, for lack of a
`
`16· ·better word, I'm simply paraphrasing it and
`
`17· ·trying to put a context into that claim
`
`18· ·limitation.
`
`19· · · ·Q.· · So, is it your understanding that
`
`20· ·one of the functions of the controller is to
`
`21· ·map physical blocks to logical blocks?
`
`22· · · ·A.· · It says right here to map, and if
`
`23· ·you read into it, one of the functions, yes,
`
`24· ·is mapping the logical address range to a
`
`25· ·physical address range, and that range would
`
`Vervain Ex. 2020, p.20
`Micron v. Vervain
`IPR2021-01549
`
`
`
`·1· ·include a quanta of that -- minimum quanta of
`
`Page 21
`
`·2· ·the address range would include blocks.
`
`·3· ·Therefore, I'm just saying that I'm looking
`
`·4· ·at this.· It would -- it would map.· It would
`
`·5· ·do that mapping.
`
`·6· · · ·Q.· · The controller would do that
`
`·7· ·mapping?
`
`·8· · · ·A.· · Controller at least would maintain
`
`·9· ·a map.
`
`10· · · ·Q.· · The controller would maintain a map
`
`11· ·of physical blocks to logical blocks?
`
`12· · · · · · ·MR. SAGDEO:· Object to form.
`
`13· · · ·A.· · Should I just read the claim
`
`14· ·limitation, so that this is how -- how I
`
`15· ·understand it?
`
`16· · · · · · ·You will maintain an address map,
`
`17· ·okay, and, and the -- modifying that is "each
`
`18· ·entry in the list of logical address ranges
`
`19· ·maps to a similar range of physical
`
`20· ·addresses."· That's -- that's -- that's what
`
`21· ·this limitation says, and that's what the
`
`22· ·controller in the context of claim one is
`
`23· ·doing.
`
`24· · · ·Q.· · I am trying to understand the
`
`25· ·relationship between what you just now said
`
`Vervain Ex. 2020, p.21
`Micron v. Vervain
`IPR2021-01549
`
`
`
`Page 22
`
`·1· ·and your earlier testimony about a mapping
`
`·2· ·between a logical block and a physical block.
`
`·3· ·Are you saying your earlier testimony that
`
`·4· ·the controller performs a mapping between a
`
`·5· ·logical block and a physical block is
`
`·6· ·correct, or are you saying that earlier
`
`·7· ·testimony was incorrect?
`
`·8· · · · · · ·MR. SAGDEO:· Object to form.
`
`·9· · · ·A.· · I am not saying my earlier
`
`10· ·testimony is incorrect.· I am just saying
`
`11· ·that I am paraphrasing what claim one
`
`12· ·limitation is doing, and to the extent that
`
`13· ·the word I used may be different to the claim
`
`14· ·limitation, but I think -- I think I am not
`
`15· ·here to wordsmithing or to parse everything,
`
`16· ·but I am actually here to simply opine that
`
`17· ·if a -- a POSA reading this, they will know
`
`18· ·that at least there is a map that is
`
`19· ·maintained by the controller, and one of the
`
`20· ·functions that map does is mapping the
`
`21· ·logical block to a physical block, or mapping
`
`22· ·logical address range to a physical address
`
`23· ·range.
`
`24· · · · · · ·Now, to the extent it may be more
`
`25· ·than one block or smaller than one block, it
`
`Vervain Ex. 2020, p.22
`Micron v. Vervain
`IPR2021-01549
`
`
`
`Page 23
`
`·1· ·depends on the feature, so I -- I -- I
`
`·2· ·don't -- I don't think I'm saying anything
`
`·3· ·that is different from claim one limitation,
`
`·4· ·and to the extent every word, every sentence,
`
`·5· ·every communication has a context, the
`
`·6· ·context is in claim one of '298, where it
`
`·7· ·says "disclosed," and POSA would know
`
`·8· ·disclosed controller maintaining a map, and
`
`·9· ·the map has point A, at least includes
`
`10· ·point A to point B, and that point A to
`
`11· ·point B could be a logical address range
`
`12· ·mapping to a physical address range, and
`
`13· ·within that address range, certainly there is
`
`14· ·a mapping of -- that would include a scope
`
`15· ·of -- the scope would include mapping of
`
`16· ·logical block to a physical block.
`
`17· · · ·Q.· · How does the controller map in your
`
`18· ·view a -- strike that.
`
`19· · · · · · ·Is the mapping from a logical block
`
`20· ·to a physical block the same as a mapping
`
`21· ·from a physical block to a logical block?
`
`22· · · · · · ·MR. SAGDEO:· Object to form.
`
`23· · · ·A.· · What do you mean by that?· I don't
`
`24· ·understand your question.
`
`25· · · ·Q.· · I am asking because you have
`
`Vervain Ex. 2020, p.23
`Micron v. Vervain
`IPR2021-01549
`
`
`
`Page 24
`
`·1· ·referred variously to a mapping from a
`
`·2· ·logical block to a physical block, and a
`
`·3· ·mapping from a physical block to a logical
`
`·4· ·block.· I am trying to understand if you mean
`
`·5· ·the same mapping, or if you mean some
`
`·6· ·different kind of mapping, depending on the
`
`·7· ·direction.
`
`·8· · · · · · ·MR. SAGDEO:· Object to form.
`
`·9· · · ·A.· · I don't believe I ever said
`
`10· ·anything about mapping from physical block to
`
`11· ·logical block.
`
`12· · · ·Q.· · So, is it your contention that
`
`13· ·there are no mappings from physical blocks to
`
`14· ·logical blocks in the scope of the '298
`
`15· ·patent?
`
`16· · · · · · ·MR. SAGDEO:· Object to form.
`
`17· · · ·A.· · I don't know -- I actually don't
`
`18· ·know -- what do you mean by that?
`
`19· · · ·Q.· · Well, what do you mean by a mapping
`
`20· ·from a logical block to a physical block?
`
`21· · · ·A.· · The way this memory system works
`
`22· ·is, the host is the one that needs or that
`
`23· ·utilize the memory, the physical memory, but
`
`24· ·the host deals with logical block.· And
`
`25· ·this --
`
`Vervain Ex. 2020, p.24
`Micron v. Vervain
`IPR2021-01549
`
`
`
`Page 25
`
`·1· · · ·Q.· · What is the host -- I'm sorry. I
`
`·2· ·thought you were done with your response.
`
`·3· ·Please continue your response, if you were
`
`·4· ·not done.
`
`·5· · · ·A.· · We can take a break in my -- I can
`
`·6· ·take a break in my -- in my testimony to
`
`·7· ·answer your question.
`
`·8· · · ·Q.· · I'm not -- are you asking for a
`
`·9· ·break right now?
`
`10· · · ·A.· · No, I'm not asking for a break
`
`11· ·necessarily.· I'm asking, you can go ahead
`
`12· ·and parse my testimony for now, and ask your
`
`13· ·question.
`
`14· · · ·Q.· · Okay.· You mentioned that the host
`
`15· ·utilizes memory.· What is the host?
`
`16· · · ·A.· · Let me put it this way, so that --
`
`17· ·so that we don't extend beyond the scope of
`
`18· ·this, and as person who works in the industry
`
`19· ·for many, many years, obviously you always
`
`20· ·fall into misnomer.
`
`21· · · · · · ·Let's just put it this way.· The
`
`22· ·flash memory that you have with the
`
`23· ·physical -- let's call it a physical block, I
`
`24· ·don't think -- for my USB, for example, I
`
`25· ·don't think I need to go into each of the
`
`Vervain Ex. 2020, p.25
`Micron v. Vervain
`IPR2021-01549
`
`
`
`Page 26
`
`·1· ·412K bytes or something and dictate which one
`
`·2· ·to write it.· There is an interface.· You can
`
`·3· ·call that interface "host" or you can call
`
`·4· ·that interface "host with controller,"
`
`·5· ·whatever.· It's just a system that utilize
`
`·6· ·the memory.· It could be my PC that utilize
`
`·7· ·USB.
`
`·8· · · · · · ·Everything is -- should be
`
`·9· ·functioning as a memory system and be
`
`10· ·transparent to the user.· So, the host is
`
`11· ·trying to do this mapping, and the host
`
`12· ·communicates in the logical address form.
`
`13· ·That's why -- and it use that, use this
`
`14· ·mapping to dictate what should be done unto
`
`15· ·the memory modules.· Okay.· And that's the
`
`16· ·extent and the over- -- and entire view of
`
`17· ·this.
`
`18· · · · · · ·And to the extent, you know, we
`
`19· ·want to go down exactly what constitutes a
`
`20· ·host, I think this is beyond the scope, and I
`
`21· ·did not opine on that.· I'm simply saying
`
`22· ·that from the user point of view, that could
`
`23· ·be a host interfaced by the user.· They
`
`24· ·communicate in logical address, and it's up
`
`25· ·to the controller, with all the teaching, and
`
`Vervain Ex. 2020, p.26
`Micron v. Vervain
`IPR2021-01549
`
`
`
`Page 27
`
`·1· ·which these alleged inventions are trying to
`
`·2· ·do, with all the teachings, they're trying to
`
`·3· ·make it as transparent as possible and as
`
`·4· ·much as hard disk drive compatible as
`
`·5· ·possible.
`
`·6· · · · · · ·So, there is all this garbage
`
`·7· ·collection, wear leveling, and everything
`
`·8· ·that's involved.· That requires this mapping
`
`·9· ·make an address map of logical block, logical
`
`10· ·address range into physical block or physical
`
`11· ·address range.
`
`12· · · · · · ·And that's my testimony.· I never
`
`13· ·said anything about -- I have not said
`
`14· ·anything about going from physical block to
`
`15· ·logical block.
`
`16· · · ·Q.· · Is a mapping an association between
`
`17· ·two things?· What is a mapping?
`
`18· · · · · · ·MR. SAGDEO:· Object to form.
`
`19· · · ·A.· · You can call it association.· You
`
`20· ·can call it respective.· It's a respective.
`
`21· ·So, once this block, logical block is mapped
`
`22· ·to a physical block, then these two,
`
`23· ·essentially to the host -- essentially the
`
`24· ·host -- there is a connection between them,
`
`25· ·so, the host could write to the logical
`
`Vervain Ex. 2020, p.27
`Micron v. Vervain
`IPR2021-01549
`
`
`
`Page 28
`
`·1· ·block, and if the mapping is intact, then I
`
`·2· ·am writing to the physical block.· If the
`
`·3· ·host is erasing this logical block, which we
`
`·4· ·know logical block could be erased, then it's
`
`·5· ·also erasing -- depending on the time,
`
`·6· ·whether it's doing in background or whatever,
`
`·7· ·it's also erasing this physical block.
`
`·8· · · · · · ·So, there is a mapping.· There is a
`
`·9· ·respective.· There is a projection.· There is
`
`10· ·a mapping that you can call it a correlation,
`
`11· ·but we all -- I think we know what exactly
`
`12· ·it's doing.· It's similar, akin to
`
`13· ·Dr. Khatri's testimony using analogy of a
`
`14· ·class in a classroom.· That class is
`
`15· ·associated with a classroom.· Therefore, the
`
`16· ·student in the class, in this class,
`
`17· ·hopefully, if they're good student, will also
`
`18· ·attend -- will be present in the classroom
`
`19· ·when the class teaching is being conducted.
`
`20· ·Of course, you may have bad student, and
`
`21· ·that's why you need perhaps a daily integrity
`
`22· ·check.· But anyway, that's a different
`
`23· ·analogy.
`
`24· · · · · · ·So, what you mean by correlation,
`
`25· ·so, when I say I'm taking this class, it's
`
`Vervain Ex. 2020, p.28
`Micron v. Vervain
`IPR2021-01549
`
`
`
`·1· ·identical to I will be attending and I would
`
`Page 29
`
`·2· ·attend the lectures, under normal
`
`·3· ·circumstances, similar, again -- let me just
`
`·4· ·say that once the logical block is mapped
`
`·5· ·with a physical block, I can read that
`
`·6· ·logical block, which means I'm taking the
`
`·7· ·data of the physical block.· I can write to
`
`·8· ·the logical block, which means I'm putting
`
`·9· ·data into the physical block.· Of course
`
`10· ·writing has its own process.
`
`11· · · · · · ·I also could erase that logical
`
`12· ·block, which means that I will erase this
`
`13· ·physical block, and in my earlier testimony
`
`14· ·regarding the erase operation, I am not
`
`15· ·limiting the erase operation just to the --
`
`16· ·quote/quote, erase, to the physical block.
`
`17· ·Of course when I erase a logical block, I
`
`18· ·need to physically go in according to the
`
`19· ·mapping and set the data to be logical one,
`
`20· ·so that host, the logical block -- host will
`
`21· ·see the logical block is erased and when the
`
`22· ·physical block is erased, but the erase, of
`
`23· ·course there is a timing to it.
`
`24· · · · · · ·Similar, the classroom analogy, the
`
`25· ·student in the class, if he drops the class,
`
`Vervain Ex. 2020, p.29
`Micron v. Vervain
`IPR2021-01549
`
`
`
`Page 30
`
`·1· ·drops this class, he will no longer
`
`·2· ·physically need to be present in the
`
`·3· ·classroom.
`
`·4· · · · · · ·So, I think this mapping, this
`
`·5· ·analogy, and everything, I think the context
`
`·6· ·and everything is very clear.
`
`·7· · · ·Q.· · If there is a mapping between a
`
`·8· ·logical block and a physical block, is there
`
`·9· ·also a mapping between the physical block and
`
`10· ·the logical block?
`
`11· · · · · · ·MR. SAGDEO:· Object to form.
`
`12· · · ·A.· · Again, I think, I believe I gave
`
`13·
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