UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` Samsung Electronics Co. Ltd.
`
`Case No. IPR2022-00996
`
`Petitioner,
`
`Patent No. 11,016,918
`
` vs.
`
` Netlist, Inc.,
`
`Case No. IPR2022-00999
`
`Patent Owner.
`
`Patent No. 11,232,054
`
` -------------------------------/
`
`VIDEOCONFERENCE DEPOSITION OF ANDREW WOLFE, Ph.D.
`
`Thursday, March 16, 2023
`
`Volume I (Pages 1 - 199)
`
` Reported Remotely and Stenographically by:
`
` JANIS JENNINGS, CSR No. 3942, CLR, CCRR
`
` Job No. 5807753
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 1
`
`1
`
`2
`
`3 4 5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` Samsung Electronics Co. Ltd.
`
`Case No. IPR2022-00996
`
`Petitioner,
`
`Patent No. 11,016,918
`
` vs.
`
` Netlist, Inc.,
`
`Case No. IPR2022-00999
`
`Patent Owner.
`
`Patent No. 11,232,054
`
` -------------------------------/
`
`VIDEOCONFERENCE DEPOSITION OF ANDREW WOLFE, Ph.D.
`
`Thursday, March 16, 2023
`
`Volume I (Pages 1 - 199)
`
` Reported Remotely and Stenographically by:
`
` JANIS JENNINGS, CSR No. 3942, CLR, CCRR
`
` Job No. 5807753
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 1
`
`1
`
`2
`
`3 4 5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
` DEPOSITION OF ANDREW WOLFE, Ph.D.,
`
` appearing remotely, located in Santa Clara,
`
` California, taken on behalf of the Petitioner,
`
` beginning at 9:06 a.m., on Thursday, March 16, 2023,
`
` sworn remotely by Janis Jennings, Certified Shorthand
`
` Reporter No. 3942, CCRR, located in the City of
`
` Walnut Creek, County of Contra Costa, State of
`
` California.
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 2
`
`1 2 3 4 5 6 7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
` REMOTE APPEARANCES:
`
` For the Patent Owner Netlist, Inc.:
`
` IRELL & MANELLA LLP
`
` BY: H. ANNITA ZHONG, ESQ.
`
` 1800 Avenue of the Stars
`
` Suite 900
`
` Los Angeles, California 90067
`
` 310.277.1010
`
` hzhong@irell.com
`
` For the Petitioner Samsung Electronics Co., Ltd.:
`
` BAKER BOTTS LLP
`
` BY: THEODORE W. CHANDLER, ESQ.
`
` FERENC PAZMANDI, Patent Agent
`
` 101 California Street
`
` Suite 3200
`
` San Francisco, California 94111
`
` 415.291.6200
`
` ted.chandler@bakerbotts.com
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 3
`
`1 2
`
`3 4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
` I N D E X
`
` WITNESS PAGE
`
` ANDREW WOLFE, Ph.D.
`
` VOLUME I (Pages 1 - 199)
`
` EXAMINATION BY MS. ZHONG 5
`
` E X H I B I T S
`
` EXHIBIT PAGE
`
` Exhibit 2101 Intel Developer Forum "Fully 41
`
` Buffered DIMM (FB-DIMM) Design
`
` Considerations" dated 2/18/04
`
`1
`
`2 3
`
`4
`
`5
`
`6 7
`
`8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 4
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
` THURSDAY, MARCH 16, 2023; 9:06 A.M.
`
` ANDREW WOLFE, Ph.D.,
`
` the witness herein, was sworn and
`
` testified as follows:
`
` EXAMINATION 08:54
`
`BY MS. ZHONG: 08:54
`
` Q. Good morning, Dr. Wolfe. 08:54
`
` A. How are you? 09:07
`
` Q. Can you please -- good. 09:07
`
` Can you please state your full name for the 09:07
`
`record? 09:07
`
` A. Andrew Wolfe. 09:07
`
` Q. Okay. Dr. Wolfe, you're familiar with fully 09:07
`
`buffered dual in-line memory modules; correct? 09:07
`
` (Clarification requested by Reporter.) 09:07
`
`BY MS. ZHONG: 09:07
`
` Q. Dr. Wolfe, you are familiar with fully 09:07
`
`buffered dual in-line memory modules; correct? 09:07
`
` A. I'm familiar with that term as it is used in 09:07
`
`certain JEDEC standards. 09:07
`
` Q. And fully buffered dual in-line memory 09:07
`
`modules are abbreviated as FB-DIMM; correct? 09:08
`
` A. Sometimes they are. 09:08
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 5
`
`1
`
`2 3
`
`4
`
`5
`
`6 7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` Q. Okay. So if I use the abbreviation FB-DIMM, 09:08
`
`can we agree that I am referring to the fully 09:08
`
`buffered dual in-line memory modules? 09:08
`
` A. As specified in the JEDEC specifications? 09:08
`
` Q. Sure. 09:08
`
` A. Okay. 09:08
`
` Q. And FB-DIMM includes a buffer on a memory 09:08
`
`module; correct? 09:08
`
` A. Yes, as that's defined in the JEDEC 09:08
`
`specification, yes. 09:08
`
` Q. Okay. And that buffer is referred to as an 09:08
`
`advanced memory buffer or AMB; correct? 09:08
`
` A. In some cases it is. 09:08
`
` Q. The AMB receives information from a memory 09:08
`
`controller of a host system; is that correct? 09:08
`
` A. Under certain circumstances that can be 09:09
`
`true. 09:09
`
` Q. Under what circumstances it is not true? 09:09
`
` A. Well, if you buy an FB-DIMM and it's still 09:09
`
`in the box, it doesn't receive anything from any 09:09
`
`memory controller. You have to install it in a 09:09
`
`computer system and you have to configure the 09:09
`
`computer system properly and you have to operate the 09:09
`
`computer system. 09:09
`
` Q. Okay. So when the FB-DIMM is inserted into 09:09
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 6
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`a memory slot of a properly configured computer 09:09
`
`system, the AMB will receive information from the 09:09
`
`memory controller of the host system; is that 09:09
`
`correct? 09:09
`
` A. It needs a little bit more than that. It 09:09
`
`actually needs to be -- the computer system needs to 09:09
`
`be operating, and it needs to be programmed to 09:09
`
`interact with that particular memory module. 09:10
`
` Q. Okay. So assume that if the FB-DIMM is 09:10
`
`inserted into a memory slot, a properly configured 09:10
`
`computer system that is operating and that is 09:10
`
`programmed to interact with the particular memory 09:10
`
`module, the MB receives information from the memory 09:10
`
`controller of that host system; is that correct? 09:10
`
` A. That would normally be true. 09:10
`
` Q. Okay. And what information is received by 09:10
`
`the AMB from the memory controller in that 09:10
`
`situation? 09:10
`
` A. Let me look at the specification. 09:10
`
` Q. When you say "specification," which exhibit 09:10
`
`are you referring to? 09:10
`
` A. 1027. 09:10
`
` Q. 1027? 09:10
`
` A. Yes. 09:10
`
` Q. Okay. And that's JSD82-20; is that correct? 09:10
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 7
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` A. Yes. 09:11
`
` Q. Okay. 09:11
`
` A. The AMB receives clocks, it receives address 09:11
`
`command bits, and it receives data and data strobe 09:11
`
`signals. 09:11
`
` Q. Where are you looking at? 09:11
`
` A. I'm looking at Figure 1.1. 09:11
`
` Q. And which page? 09:11
`
` A. 3. 09:11
`
` Q. Page 3. 09:11
`
` And you are referring to the output on the 09:11
`
`DDR I/O side; is that correct? 09:11
`
` A. Correct. That's where it outputs the 09:11
`
`information that is received over what are called 09:12
`
`northbound/southbound links. 09:12
`
` Q. What information -- I'm asking what 09:12
`
`information it is received. 09:12
`
` A. Well, that's the information that's 09:12
`
`received. It's received over the northbound and 09:12
`
`southbound links in an encoded form. 09:12
`
` Q. Why don't you take a look at Exhibit 1028. 09:12
`
` A. Okay. 09:12
`
` Q. Can you take a look at pages 11 and 12 of 09:12
`
`Exhibit 1028. 09:12
`
` A. Yes. 09:13
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 8
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` Q. Where are the address pins? 09:13
`
` A. I didn't say there were address pins. The 09:13
`
`pins are the northbound and southbound lanes. The 09:13
`
`information that gets conveyed does include 09:13
`
`addresses. 09:13
`
` Q. So there are no address pins or control 09:13
`
`pins? 09:13
`
` MR. CHANDLER: Object to form. Object to 09:13
`
`form. 09:13
`
` THE WITNESS: There are no pins -- well -- 09:13
`
` DEPOSITION REPORTER: Excuse me, Mr. Wolfe. 09:14
`
`I'm sorry to interrupt. I'm getting an audio 09:14
`
`feedback from somebody. Can we go off the record 09:14
`
`real quick and let's see where it is coming from, 09:14
`
`please. 09:14
`
` MS. ZHONG: Sure. 09:14
`
` (Off the record.) 09:14
`
`BY MS. ZHONG: 09:15
`
` Q. So there are no address pins or control 09:15
`
`pins; is that correct, Dr. Wolfe? 09:15
`
` MR. CHANDLER: Object to form. 09:15
`
` THE WITNESS: No. I think that that would 09:15
`
`be misleading. There are no pins that have those 09:15
`
`specific names and there are no -- when you talk 09:15
`
`about -- pins on the DIMM? Is that the question? 09:15
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 9
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`BY MS. ZHONG: 09:15
`
` Q. Correct. 09:15
`
` A. Yeah. There are no DIMM pins that have 09:15
`
`those specific names, but there are pins, the 09:15
`
`northbound and southbound lanes, that carry that 09:15
`
`information so they perform that function. 09:15
`
` Q. And the address and the control information 09:15
`
`are sent as serialized packets; is that correct? 09:15
`
` A. Serialized packets? They -- yes. They 09:16
`
`are -- the information is sent to the advanced 09:16
`
`memory buffer in the form of serialized packets. 09:16
`
` Q. Okay. So unlike the most common DIMMs with 09:16
`
`the dedicated second address and the control pins, 09:16
`
`the FB-DIMM does not have dedicated address and 09:16
`
`control pins; is that correct? 09:16
`
` MR. CHANDLER: Object to form. 09:16
`
` THE WITNESS: I want to be clear. When we 09:16
`
`talk about the most common DIMMs, I assume we are 09:16
`
`talking about unbuffered DIMMs of some type and, of 09:16
`
`course, there are a number of different types that 09:16
`
`were known at the time of the filing of these 09:16
`
`patents. There are more types known today. 09:16
`
` Those generally have pins that are used for 09:17
`
`address and control, but there are often pins that 09:17
`
`are shared between address functions and control 09:17
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 10
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`functions. So to that extent, they are not 09:17
`
`dedicated to one or the other. 09:17
`
` But as I explained before, the northbound 09:17
`
`and southbound lanes on the fully buffered DIMM are 09:17
`
`used for address and control communications, but 09:17
`
`they are also used for data communications. 09:17
`
`BY MS. ZHONG: 09:17
`
` Q. Okay. So in the most common DIMMs, such as 09:17
`
`RDIMMs, or registered DIMMs, SODIMMs, small outlined 09:17
`
`DIMMS and the output DIMM connection -- 09:18
`
` (Clarification requested by Reporter.) 09:18
`
`BY MS. ZHONG: 09:18
`
` Q. -- SODIMMs, or small outlined DIMMs, and 09:18
`
`unbuffered DIMMs. Small outlined DIMMs, yeah, 09:18
`
`SODIMMs, and unbuffered DIMMs or UDIMMs. 09:18
`
` So in those DIMMs, data is not sent on the 09:18
`
`same pins as for address signals; is that correct? 09:18
`
` MR. CHANDLER: Objection to form. 09:18
`
` THE WITNESS: Of course, there are many 09:18
`
`different generations of those DIMM types at 09:18
`
`different times and each one has its own 09:18
`
`specification, so I would need to review them all to 09:18
`
`give you an absolute answer. 09:18
`
` But my recollection is that, generally, 09:19
`
`there are separate pins that are used for data 09:19
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 11
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`communication as opposed to the pins that are used 09:19
`
`for address and commands. 09:19
`
`BY MS. ZHONG: 09:19
`
` Q. Okay. But in FB-DIMMs, they are sent on the 09:19
`
`same pins as for command and address; is that 09:19
`
`correct? 09:19
`
` MR. CHANDLER: Objection. Form. 09:19
`
` THE WITNESS: Between the host computer and 09:19
`
`the FB-DIMM, that is the case. 09:19
`
`BY MS. ZHONG: 09:19
`
` Q. Okay. What's an FB-DIMM? That's only for 09:19
`
`the DDR2; correct? There are no DDR3 FB-DIMMs as 09:19
`
`far as you know? 09:19
`
` A. I don't recall one way or the other. There 09:19
`
`certainly is a DDR2 FB-DIMM. 09:19
`
` Q. Does your declaration rely on DDR3 FB-DIMMs? 09:19
`
` A. Not that I can recall. 09:20
`
` Q. And there are no DDR4 FB-DIMMs; correct? 09:20
`
` A. I don't recall referring to any in my 09:20
`
`declaration. 09:20
`
` Q. Okay. So your declaration only referred to 09:20
`
`a DDR2 FB-DIMM? 09:20
`
` A. As far as I can recall right now. 09:20
`
` Q. Okay. What is a termination voltage? 09:20
`
` A. In general? 09:20
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 12
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` Q. For use with -- let me withdraw and ask. 09:20
`
` Is a termination voltage used in connection 09:20
`
`with a DDR2 FB-DIMM? 09:20
`
` A. I believe it is, yes. 09:20
`
` Q. Okay. What is it used for? 09:20
`
` MR. CHANDLER: Objection. Form. 09:21
`
` THE WITNESS: It's used to provide power to 09:21
`
`signal termination networks. 09:21
`
`BY MS. ZHONG: 09:21
`
` Q. What does "signal termination" mean? 09:21
`
` A. What does -- as I used it in that previous 09:21
`
`phrase? 09:21
`
` Q. Correct. 09:21
`
` A. When a high-speed signal passes over a wire 09:21
`
`that has what we call transmission line properties, 09:21
`
`there is potential for that signal to reflect back 09:21
`
`from the end of the wire. 09:21
`
` Q. Uh-huh.
`
` A. We can reduce those reflections using what's 09:21
`
`called a termination network, and in many cases, 09:22
`
`that termination network is powered. 09:22
`
` Q. So termination -- signal termination is not 09:22
`
`required if you have a low-speed signal; is that 09:22
`
`correct? 09:22
`
` MR. CHANDLER: Objection. Form. 09:22
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 13
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` THE WITNESS: It depends on the 09:22
`
`characteristics of the -- of the wiring and the 09:22
`
`voltages that are used and the wiring properties and 09:22
`
`what your definition of low speed is. 09:22
`
` The speed of the signal with respect to 09:22
`
`termination requirements has to do with the spectral 09:22
`
`distribution of the energy, and that is primarily 09:22
`
`reflected by the signal transition speed, not the 09:22
`
`total amount of data that's being communicated. 09:23
`
`BY MS. ZHONG: 09:23
`
` Q. So in DDR2 FB-DIMM, what signals are the 09:23
`
`termination voltage used to terminate? 09:23
`
` A. The VTT voltage is used to terminate the 09:23
`
`signals going to the DRAM chips. I would have to go 09:23
`
`through the spec very carefully to figure out if 09:23
`
`there were other places where it's used. 09:23
`
` Q. Why don't you take a look at Exhibit 1028, 09:23
`
`page 11, and the pin name for VTT as well as the 09:23
`
`corresponding description. 09:24
`
` A. I see that. 09:24
`
` Q. So which signals are used to terminate with 09:24
`
`VTT? 09:24
`
` A. Well, as I said, I -- the ones that I recall 09:24
`
`are address command and clock signals to the DRAMs, 09:24
`
`but I would have to look very carefully at the 09:24
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 14
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`specification to see if there were any others. 09:24
`
`That's the one that's documented on, for example, 09:24
`
`page 15 or page 14. 09:24
`
` Q. So if -- in FB-DIMM, if address command 09:24
`
`signal information is transmitted on the same -- 09:24
`
`through the same pin as for data, how can VTT be 09:24
`
`selectively terminating the address command and 09:25
`
`clock signals but not the data? 09:25
`
` MR. CHANDLER: Objection. Form. 09:25
`
` THE WITNESS: Are you referring to something 09:25
`
`in my declaration? 09:25
`
`BY MS. ZHONG: 09:25
`
` Q. I'm just asking you. 09:25
`
` A. So you're asking me about an unmodified 09:25
`
`FB-DIMM? 09:25
`
` Q. Correct. 09:25
`
` A. I'm sorry. Can I hear the question one more 09:27
`
`time? 09:27
`
` Q. In FB-DIMM, you said that the address and 09:27
`
`command information is transmitted on the same pins 09:27
`
`as for data; correct? 09:27
`
` MR. CHANDLER: Object to form. 09:27
`
` THE WITNESS: From the host, that is true. 09:27
`
`Not to the DRAMs. 09:27
`
`/ / / 09:27
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 15
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`BY MS. ZHONG: 09:27
`
` Q. Okay. So how can the FTT be used 09:27
`
`to selectively terminate the address and command 09:27
`
`information signals but not the data signals? 09:27
`
` MR. CHANDLER: Objection. Form. And I 09:27
`
`think you said "FTT." 09:27
`
` (Clarification requested by Reporter.) 09:28
`
` MS. ZHONG: FTT -- VTT. 09:28
`
` MR. CHANDLER: Even with that correction, 09:28
`
`objection to form. 09:28
`
` THE WITNESS: So VTT can be used to 09:28
`
`selectively enable termination between the AMB and 09:28
`
`the DRAMs on the address and command signals without 09:28
`
`impacting the termination of the data signals. 09:28
`
`BY MS. ZHONG: 09:28
`
` Q. So where on the termination resistors placed 09:28
`
`between the FTT pins and the address command clock 09:28
`
`signals to the DRAM, or they are terminated on the 09:29
`
`motherboard? 09:29
`
` MR. CHANDLER: Objection. Form. 09:29
`
` THE WITNESS: Usually there is a termination 09:29
`
`on each end, but there would be termination near the 09:29
`
`DRAMs for the address control signals. There are 09:29
`
`numerous other places where there's termination, but 09:29
`
`I believe on FB-DIMM, the other terminations would 09:29
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 16
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`primarily be on-chip terminations. 09:29
`
`BY MS. ZHONG: 09:29
`
` Q. The on-chip terminations is not part of the 09:29
`
`F -- VTT; correct? 09:29
`
` MR. CHANDLER: Objection. Form. 09:29
`
` THE WITNESS: On an unmodified FB-DIMM, I 09:29
`
`believe that's correct. 09:30
`
`BY MS. ZHONG: 09:30
`
` Q. And in the modified Harris FB-DIMM, how 09:30
`
`would that differ? 09:30
`
` Let me withdraw and ask it this way. In 09:30
`
`your declaration, you didn't say that the FTT -- let 09:30
`
`me withdraw and ask. 09:30
`
` In your declaration, you do not say that the 09:30
`
`VTT would operate any differently in the Harris 09:30
`
`FB-DIMM and the JEDEC-compliant FB-DIMM; correct? 09:30
`
` A. Well, no. I think that there are certain 09:31
`
`teachings from the FB-DIMM that are taken into 09:31
`
`account into Harris, but I explained what the 09:31
`
`combination would be and how Harris would be 09:31
`
`modified in the declaration for the [simultaneous 09:31
`
`speakers] --
`
` Q. Did you contend -- did you contend that VTT 09:31
`
`would be used for online -- on-die termination? 09:31
`
` A. I don't recall everything that's in the 09:31
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 17
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`declaration. It's quite large, but the focus 09:31
`
`appears to be for DRAM termination for VTT in the 09:32
`
`embodiment that I'm looking at right now for grounds 09:32
`
`2D and 3D. 09:32
`
` Q. When you say for "DRAM termination," is it 09:32
`
`for the on-die termination? 09:32
`
` A. I don't believe so. There is a resistor 09:32
`
`shown in the drawings. 09:32
`
` Q. Okay. So for the modified Harris, the VTT 09:32
`
`is used in the same manner as in the -- for the 09:32
`
`JEDEC-compliant FB-DIMM -- 09:32
`
` A. No, actually I --
`
` Q. -- [Simultaneous speakers] command a clock's
`
`signal to the DRAM -- 09:32
`
` (Clarification requested by Reporter.) 09:32
`
`BY MS. ZHONG: 09:32
`
` Q. So in your declaration, the VTT is used in 09:33
`
`the same set manner for the modified Harris FB-DIMM 09:33
`
`as for the JEDEC-compliant FB-DIMM, which is for the 09:33
`
`termination of the address command and clock signals 09:33
`
`to the DDR2 devices; is that correct? 09:33
`
` A. No, I think that's an overgeneralization. 09:33
`
`Again, there are many different grounds that are 09:33
`
`presented in the declaration. We'd have to go 09:33
`
`through them all carefully. 09:33
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 18
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` But, for example, I do see that certainly 09:33
`
`some of the grounds refer to DDR3 and some of the 09:33
`
`grounds refer to a VTT voltage of 0.9 volts, which I 09:33
`
`recall is the on-ground -- or the on-die termination 09:34
`
`voltage. 09:34
`
` Q. For Harris, you used a DDR3 combination? 09:34
`
` A. Let me look. 09:34
`
` Q. Are you confusing that with Spiers? 09:34
`
` A. Let me look at the various combinations 09:34
`
`here. Oh, I'm sorry. I may have these backwards. 09:34
`
` For Harris, I have DDR2 combinations that do 09:34
`
`show a variety of different VTTs, so those would be 09:35
`
`used for a variety of different purposes. 09:35
`
` Q. When you say "a variety of VTTs," which 09:35
`
`paragraph are you referring to? 09:35
`
` A. So in paragraph 247, I talk about a VTT of 09:36
`
`1.2 volts and also of .9 volts. I'm sorry, 1.25 09:36
`
`volts and .9 volts. 09:36
`
` Q. Paragraph 247? 09:36
`
` A. Yes. 09:36
`
` Q. VTT is half of VDDQ; correct? 09:36
`
` A. In some instances, it is. 09:36
`
` Q. In which instance is -- it is not? 09:36
`
` A. I believe in the instance of DDR2 SDRAM, it 09:36
`
`can just be .9 volts independently of VDDQ. 09:37
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 19
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` Q. What is VDDQ in DDR2? 09:37
`
` A. I'm sorry. I didn't get -- 09:37
`
` Q. Let me withdraw and ask. 09:37
`
` What is VDDQ for DDR2? 09:37
`
` A. It's one of the power supply voltages. 09:37
`
` Q. What's the value? 09:37
`
` MR. CHANDLER: Objection to form. 09:37
`
` THE WITNESS: It's 1.8 volts plus or minus 09:38
`
`0.1 volts. 09:38
`
`BY MS. ZHONG: 09:38
`
` Q. And half of that is 0.9; correct? 09:38
`
` A. It is. 09:38
`
` Q. Okay. So the 0.9 volt VTT is half of the 09:38
`
`DDR2 SDRAM, as you stated in paragraph 247; correct?
`
` A. That nominal -- 09:38
`
` (Clarification requested by Reporter.) 09:38
`
`BY MS. ZHONG:
`
` Q. Is half of the VDDQ for DDR2. 09:38
`
` MR. CHANDLER: Objection. Form. 09:38
`
` THE WITNESS: At the nominal value, that's 09:38
`
`true. 09:38
`
` MS. ZHONG: VDDQ is one word, VDDQ, as 09:38
`
`letter Q. 09:38
`
` MR. CHANDLER: And sometimes it's shown as 09:38
`
`subscript. It doesn't have to be, but -- so the V 09:39
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 20
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`is always capitalized and then the letters after it, 09:39
`
`like "TT" and "DD" or "DDQ" are sometimes shown as 09:39
`
`subscript. 09:39
`
` MS. ZHONG: Yeah, it's probably easier for 09:39
`
`you just to type them all as like capitalized 09:39
`
`letters. 09:39
`
` DEPOSITION REPORTER: Thank you. I 09:39
`
`appreciate that. 09:39
`
`BY MS. ZHONG: 09:39
`
` Q. And which SDRAMs have a VDD or VDDQ of 09:39
`
`2.5 volts? 09:39
`
` A. I don't recall them all off the top of my 09:39
`
`head. 09:39
`
` Q. That's DDR; correct? Why don't you take a 09:39
`
`look at your paragraph 246. 09:40
`
` A. For certain DDR devices. 09:40
`
` Q. So do you remember -- do you see like your 09:40
`
`quote for different generations, there's 3.3 volt, 09:40
`
`2.5 volt, 1.8 volt and a 1.5 volts? 09:40
`
` A. I do. 09:40
`
` Q. So the -- so the 3.3 is for SDR SDRAM, 2.5 09:40
`
`is for DDR1, 1.8V is for DDR2, and 1.5V is for DDR3; 09:40
`
`correct? 09:40
`
` A. For at least some examples of these, that's 09:40
`
`true. 09:40
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 21
`
`Netlist Ex 2030
`Samsung v Netlist
`IPR2022-00996
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
` Q. Okay. You're not aware of any DDR1 FB-DIMM, 09:40
`
`are you? 09:41
`
` A. Not off the top of my head, no. 09:41
`
` Q. Okay. And you certainly didn't cite any 09:41
`
`JEDEC standards for DDR1 FB-DIMM; correct? 09:41
`
` A. I did not. 09:41
`
` Q. And you're not aware of any DDR1 FB-DIMM; 09:41
`
`correct? 09:41
`
` A. I don't recall one right now. 09:41
`
` Q. And as far as you know, is FB-DIMM first 09:41
`
`developed for DDR2? 09:41
`
` MR. CHANDLER: Objection. Form. 09:41
`
` THE WITNESS: That particular specification, 09:41
`
`JESD82-20, was first developed for DDR2, as far as I 09:41
`
`know. 09:41
`
`BY MS. ZHONG: 09:42
`
` Q. Now, for the memory controller to send data,
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
