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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ---------------------------------------------------x
` META PLATFORMS, INC.,
` Petitioner,
` vs.
` THALES VISIONIX, INC.,
` Patent Owner.
` ---------------------------------------------------x
` U.S. PATENT NO. 6,922,632
` IPR2022-01304
` ---------------------------------------------------x
` U.S. PATENT NO. 7,725,253
` IPR2022-01308
` ---------------------------------------------------x
` U.S. PATENT NO. 6,922,632
` IPR2022-01305
` ---------------------------------------------------x
`
` REMOTE VIDEOTAPED DEPOSITION BY VIRTUAL ZOOM OF
` ULRICH NEUMANN, Ph.D.
` Friday, October 20, 2023
`
` Stenographically Reported By: Lynne Ledanois
` License No. 6811
` Job No. 6153681
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
`
`IPR2022-01304
`Meta v. Thales
`Thales Exhibit 2025
`Page 1 of 22
`
`

`

`1 REMOTE APPEARANCES
`
`Page 4
`
`23
`
` Counsel for Real Party-In-Interest Gentex Corp.:
`4 WILLIAMS & CONNOLLY LLP
`5 BY: SHAYON GHOSH
`6 MELISSA COLLINS
`7 Attorneys at Law
`8 680 Maine Avenue SW
`9 Washington, DC 20024
`10 sghosh@wc.com
`11 mcollins@wc.com
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`Page 2
`1 UNITED STATES PATENT AND TRADEMARK OFFICE
`2 BEFORE THE PATENT TRIAL AND APPEAL BOARD
`3 ---------------------------------------------------x
`4 META PLATFORMS, INC.,
`5 Petitioner,
`6 vs.
`7 THALES VISIONIX, INC.,
`8 Patent Owner.
`9 ---------------------------------------------------x
` U.S. PATENT NO. 6,922,632
`10 IPR2022-01304
` ---------------------------------------------------x
`11 U.S. PATENT NO. 7,725,253
` IPR2022-01308
`12 ---------------------------------------------------x
` U.S. PATENT NO. 6,922,632
`13 IPR2022-01305
` ---------------------------------------------------x
`
`14
`15 Videotaped deposition of ULRICH NEUMANN,
`16 taken in Los Angeles, California, commencing at
`17 9:16 a.m., on Friday, October 20, 2023 before
`18 LYNNE M. LEDANOIS, Certified Shorthand Reporter
`19 No. 6811
`20
`21 * * *
`22
`23
`24
`25
`
`Page 3
`
`Page 5
`
`1 REMOTE APPEARANCES
`
`23
`
` Counsel for Petitioner Meta Platforms, Inc.:
`4 KIRKLAND & ELLIS LLP
`5 BY: JOSHUA GLUCOFT
`6 Attorney at Law
`7 555 Flower Street
`8 Suite 3700
`9 Los Angeles, California 90071
`10 jglucoft.deoras@kirkland.com
`11
`12 Counsel for Patent Owner Thales Visionix, Inc.:
`13 ADDYHART PC
`14 BY: BRANDON HELMS
`15 Attorney at Law
`16 401 N. Michigan Avenue
`17 Suite 1200-1
`18 Chicago, Illinois 60611
`19 bhelms@addyhart.com
`20
`21
`22
`23
`24
`25 ///
`
`1 I N D E X O F E X A M I N A T I O N
`
`23
`
` Examination by: Page
`4 Mr. Ghosh 6, 34
`5 Mr. Glucoft 31
`
`6789
`
` PREVIOUSLY MARKED EXHIBITS Page
`10 Exhibit 1003 7
`11 Exhibit 1038 7
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
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`Thales Exhibit 2025
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`Page 8
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`1 BY MR. GHOSH:
`2 Q Yes. You're familiar with this exhibit?
`3 A Yes.
`4 Q So and this is the -- if I refer to this
`5 as the '253 patent, do you understand what I mean?
`6 A Yes.
`7 Q Can you please scroll down to Column 16 of
`8 the patent. Please let me know when you're there.
`9 Column 16, Line 20.
`10 A Okay. I see it.
`11 Q Do you see the paragraph starting with,
`12 "The PSE drivers 120 provide interfaces to PSE
`13 devices 105"?
`14 A I do see that.
`15 Q Can you please read that paragraph to
`16 yourself and let me know when you're done.
`17 A Okay.
`18 Q This paragraph is describing an embodiment
`19 of the invention of the '253 patent; correct?
`20 A I assume that's correct, yes.
`21 Q And PSE in this paragraph refers to pose
`22 sensing elements; is that right?
`23 A I'll take your word for that. I haven't
`24 gone back to the definition, but I think that's right.
`25 Q We can go back to the definition quickly.
`Page 9
`
`Page 6
`
`1 Friday, October 20, 2023
`2 9:16 a.m.
`3 ----------------------------------------------------
`4 EXAMINATION
`5 BY MR. GHOSH:
`6 Q Good morning, Dr. Neumann.
`7 A Good morning.
`8 Q I understand that you've been deposed
`9 several times before?
`10 A Yes.
`11 Q I won't go through the basic deposition
`12 ground rules again, but have you ever been deposed
`13 virtually before?
`14 A This is the first time where everyone has
`15 been virtual.
`16 Q So just given the vagaries of the Zoom
`17 format, please just be careful to wait until I've
`18 finished asking a question before starting your
`19 answer.
`20 Does that make sense?
`21 A Yes, it does.
`22 Q And if you ever have any trouble, given
`23 the format, hearing any of my questions, please feel
`24 free to ask me to repeat.
`25 Does that make sense?
`
`Page 7
`
`1 A Absolutely.
`2 Q If you do give an answer, I will assume
`3 that you've heard and understood my question.
`4 Is that fair?
`5 A I missed the last phrase, could you say it
`6 again?
`7 Q That was a test. I'm saying that if you
`8 do give an answer, I'll assume that you have heard
`9 and understood my question.
`10 Is that fair?
`11 A Yes, that's fair.
`12 Q Is there any reason you cannot give
`13 truthful or accurate testimony today?
`14 A No.
`15 Q I'm adding to the Exhibit Share what has
`16 been previously marked as Exhibit 1003, 1003.
`17 Please let me know when you see that.
`18 A I have not logged into the Exhibit Share
`19 yet. So let me just do that.
`20 Q Okay.
`21 A This I have not used before.
`22 MR. GHOSH: If you want, we can go off the
`23 record while you get that set up. Is that okay?
`24 THE WITNESS: I'm doing it as we speak.
`25 Okay. So I see Exhibit 1003. Is that the one?
`
`1 It's in Column 12, Line 50.
`2 A Okay. I'll take your word for it.
`3 Q PSE in the specification of the '253
`4 patent also includes sensors; is that right?
`5 A PSE includes sensors; is that the question?
`6 Q Yes.
`7 MR. GLUCOFT: Objection, scope.
`8 THE WITNESS: I recall that sensors are
`9 the topic of this patent and the discussions. I
`10 haven't reviewed this patent for this particular
`11 session. So I'm trying to do this from memory.
`12 BY MR. GHOSH:
`13 Q I assume you reviewed this patent when
`14 putting together your supplemental declaration,
`15 Exhibit 1038?
`16 A When I put the declaration together, I was
`17 addressing specific questions that were put to me.
`18 And so I was making opinions about those.
`19 Q Okay. In the process of putting together
`20 those opinions, did you refer to the patent at all?
`21 A I don't recall referring specifically to the
`22 text of the patent, no.
`23 Q So you did not need to consider the patent
`24 in putting together the opinions?
`25 A I had the specific questions as outlined in
`3 (Pages 6 - 9)
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`Page 10
`1 my declaration and those questions were posed to me.
`2 And I used the references that I cited in
`3 the declaration. I did not -- excuse me. I didn't
`4 review the patents themselves.
`5 Q And I assume you didn't review the patents
`6 in putting together your supplemental declaration
`7 because you didn't think it was necessary?
`8 A I recall the information sufficiently to
`9 form my opinions. I did not need to go back to the
`10 patent to read them in detail.
`11 Q So going back to the patent then, I
`12 recognize that it may have been awhile, but if you
`13 look at -- go back to Column 16, Line 20.
`14 A Mm-hmm.
`15 Q That paragraph there that we were looking
`16 at before. The second line in that paragraph,
`17 Line 21, says that PSE drivers in this embodiment
`18 are software modules; correct?
`19 A Mm-hmm.
`20 Q And then in Line 28, there is a long
`21 sentence starting on Line 26 and it says that PSE
`22 drivers include, among other things, "data and code
`23 needed for computation of the linearized observation
`24 matrices, observation noise covariance matrices, and
`25 expected sensor measurements and/or innovations as
`
`Page 12
`
`1 A I would have to assume that that's a
`2 possibility, yes.
`3 Q Can you think of any other possibility for
`4 how they would be written?
`5 A Software can come in a variety of forms.
`6 Manufacturers write software for their devices that
`7 are embedded in the devices, sometimes they are not
`8 embedded in the devices.
`9 I'm just hedging here because this doesn't
`10 really tell me much about at what level and it
`11 doesn't exclude any particular level, so I'm
`12 hesitant to suggest there is only one possible
`13 interpretation of this.
`14 Q I appreciate you're being careful. Okay.
`15 Yes, I think that's fair then.
`16 If you go down a couple more pages to
`17 Column 21, the paragraph starting at Line 7, could
`18 you please read that paragraph and let me know when
`19 you're done.
`20 MR. GLUCOFT: You said Column 21 Line 7,
`21 Shayon?
`22 MR. GHOSH: Yes.
`23 THE WITNESS: Okay. Yes.
`24 BY MR. GHOSH:
`25 Q I know there is a lot of math --
`
`Page 11
`
`1 described above."
`2 Do you see that?
`3 A I see that, yes.
`4 Q "Code" here refers to software; correct?
`5 A Yes, in this context, that's what it would
`6 refer to.
`7 Q And so the computations here that are
`8 described in this paragraph are implemented in
`9 software; is that correct?
`10 (Reporter clarification.)
`11 THE WITNESS: I think in the context this
`12 is written in, that's the assumption, yes.
`13 BY MR. GHOSH:
`14 Q And similarly, if you go back up to
`15 Line 21 and 22, it says that "PSE drivers are
`16 software modules," and I'm reading again, "which may
`17 be written by manufacturers of PSE devices." I'll
`18 stop there.
`19 Do you see that?
`20 A Yes.
`21 Q And where the patent says "written by
`22 manufacturers of PSE devices," the patent is
`23 referring to writing these drivers or these software
`24 modules in a computer programming language; is that
`25 right?
`
`Page 13
`1 A There is a lot in there to digest on the fly
`2 but okay. Go ahead.
`3 Q So the PSE driver that's referred to here
`4 is the same one we were discussing earlier; right?
`5 A I would have to assume so. If they are
`6 using the same term, I would have to assume that's
`7 what they were referring to.
`8 Q And they are using the same term as well
`9 as Number 120 in both instances; right?
`10 A Yes, so that narrows it down even more.
`11 Okay.
`12 Q And at Line 16, there is a sentence that
`13 starts -- let me just read it, actually.
`14 "The PSE driver 120 estimates the
`15 predicted measurement z-hat sub st" -- let me stop
`16 there.
`17 Do you see that?
`18 A Yes.
`19 Q And the z-hat represents the predicted
`20 measurement; right?
`21 A Well, that's what it says, yes.
`22 Q And if you go back to Column 16 where we
`23 were, that paragraph at Line 31 refers to expected
`24 sensor measurements.
`25 Do you see that?
`
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`Page 14
`1 A Column 16. Which line are you referring to?
`2 Q Line 30 and 31.
`3 A Okay.
`4 Q And again, so the question is that so the
`5 z-hat expected measurement that we were discussing
`6 earlier is the same as the -- sorry, the z-hat
`7 predicted measurement that we were discussing
`8 earlier is the same as the expected sensor
`9 measurement described here; is that right?
`10 MR. GLUCOFT: Objection, scope.
`11 THE WITNESS: You know, I've not reviewed
`12 this. This is dense material. I have not reviewed
`13 it, as I said, in detail.
`14 I hesitate to make absolute statements
`15 about something I'm not really prepared to do that
`16 for. Sorry, but I would need to read this in more
`17 detail to give you a more definitive answer.
`18 BY MR. GHOSH:
`19 Q That's fair. I think I can hopefully
`20 point you to the relevant portions and we can get
`21 there and --
`22 A The document is -- sorry, but the document
`23 is large and there is information spread through it.
`24 I don't think I can cherry pick components of it and
`25 decide on some interpretation without reading the
`Page 15
`
`1 whole thing.
`2 Q Let's try and then --
`3 A Okay.
`4 Q If you go up to Column 15, this is on the
`5 same page as Column 16.
`6 A Fifteen, yes. Okay.
`7 Q And starting at Line 18, there is a
`8 paragraph starting, "In operation, it is useful to
`9 liearize the observation model."
`10 Do you see that?
`11 A I do.
`12 Q Let me direct your attention to the
`13 next-to-last sentence in that paragraph starting at
`14 Line 22.
`15 It says, "It is also useful to compute the
`16 difference."
`17 Do you see that?
`18 A Yes, I see that.
`19 Q In that sentence it refers to the expected
`20 measurement based on the estimated pose as z-hat
`21 sub IJ.
`22 Do you see that?
`23 A I do.
`24 Q And z-hat is the same variable that was
`25 used in Column 21 and referred to as a predicted
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`1 measurement; correct?
`2 MR. GLUCOFT: Objection, scope.
`3 THE WITNESS: You know, it appears to be
`4 the same variable, but again, without reading the
`5 document, I hesitate to make definitive statements
`6 about this.
`7 BY MR. GHOSH:
`8 Q When was the last time you read the
`9 specification of the '632 and '253 patents?
`10 A Probably around the time where I made my
`11 first declaration and depositions about it. I haven't
`12 looked at it since.
`13 Q That's fair.
`14 A Or at least not in detail.
`15 (Discussion off the record.)
`16 BY MR. GHOSH:
`17 Q Let me turn to your declaration. This is
`18 Exhibit 1038.
`19 I understand you have a copy in front of
`20 you, but for completeness, I'll add it to the
`21 Exhibit Share as well.
`22 A Okay.
`23 Q To be clear, this is the supplemental
`24 declaration?
`25 A The supplemental declaration, yes, I have
`Page 17
`
`1 that in front of me.
`2 Q Could you please turn to Paragraph 21
`3 starting on Page 9.
`4 A Yes.
`5 Q In the last sentence on the bottom of
`6 Page 9, you've written, quote, "This selection
`7 process is a sequence whose timing needs to be
`8 synchronized to the A/D converter."
`9 Do you see that?
`10 A Yes.
`11 Q When you say the timing needs to be
`12 synchronized, could a clock signal be used for that
`13 synchronization?
`14 A I'm sorry, could you repeat that? Could a
`15 what signal?
`16 Q A clock signal.
`17 A A "clock signal" is a very generic term.
`18 I'm not sure what -- by itself, a clock signal is just
`19 a waveform. It doesn't select anything.
`20 Q Right. I'm asking if a clock signal could
`21 be used specifically for synchronizing the timing
`22 between the multiplexor and the A/D converter?
`23 A As part of a larger -- or as part of a
`24 system that does this sequencing and synchronization,
`25 yes, a clock signal could be used as part of it. By
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`Page 18
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`1 itself, it's not enough.
`2 Q So a circuit designer could use a clock
`3 signal as a tool to perform the synchronization
`4 between the multiplexor and the A/D converter; is
`5 that fair?
`6 A That's a fair statement. I think I would
`7 say it's a time base, that's generally what a clock is
`8 used for. It's a time base. It repeats at a certain
`9 interval and those intervals are the basis for then
`10 creating the synchronization signals and performing
`11 the operation that's needed, yes.
`12 Q And then when the circuit designer is
`13 determining how to perform the synchronization, the
`14 circuit designer would, for example, select a
`15 frequency for -- select a clock signal or clock
`16 signal generator with a particular frequency?
`17 A Well, yes. I mean, generally you either
`18 create a clock or you use a clock -- if there's
`19 already a clock in the system, you could use that one
`20 or you could create another one and you would choose
`21 an appropriate frequency if that was left to your
`22 decision, yes.
`23 Q And when you say "your decision," you're
`24 referring to the decisions of the person who's
`25 designing this analog circuit; right?
`
`Page 19
`
`1 A I'm talking designing the system that
`2 performs whatever task it is that's to be performed,
`3 you would consider what granularity, for example, of
`4 time is required. Do you need to specify things to a
`5 microsecond or to a millisecond or to a fraction or a
`6 nanosecond?
`7 So whatever that granularity is, that's
`8 generally a strong determinant for what the clock
`9 signal frequency should be.
`10 Q And these are all factors that, again, the
`11 system designer is considering?
`12 A Yes.
`13 Q Later on in this paragraph, the
`14 next-to-last sentence you say refer to "functions to
`15 advance the selection process."
`16 Do you see that?
`17 A I'm sorry, Paragraph 21?
`18 Q Yes. The next-to-last sentence, I can
`19 read it in its entirety.
`20 It says, "Thus, this selection and timing
`21 process is part of a computation that computes time
`22 intervals and performs functions to advance the
`23 selection process."
`24 Do you see that?
`25 A Yes. I'm sorry, yes, I do see that.
`
`Page 20
`1 Q The function performed by the multiplexor
`2 in the system is selecting one of multiple input
`3 signals; correct?
`4 A Correct. That's what a multiplexor does.
`5 Q What other functions, quote, advance the
`6 selection process?
`7 A Well, the context of what I wrote is
`8 Figure 1 above, right. And in that context, the
`9 multiplexor is selecting to output one of the low pass
`10 filter outputs and it's passing it to the A to D
`11 converter.
`12 So a selection involves changing the
`13 multiplexor selection signals, allowing the low pass
`14 filter signal to propagate through the multiplexor
`15 and go to the A to D converter.
`16 The A to D converter may require
`17 synchronization signals as well to tell it that a
`18 signal for its conversion is present and so another
`19 signal may need to be sent to the A/D converter to
`20 begin its process of converting that signal to a
`21 digital value.
`22 But this is -- I use the word "may"
`23 because there are many different types of these
`24 things and I'm just imagining and using as an
`25 example what I would consider a typical case.
`Page 21
`
`1 Q The role of the multiplexor in this
`2 system, as I understood from your testimony just
`3 now, is selecting one of the six inputs that are
`4 coming from the low pass filters based on the
`5 selection signal that is input to the multiplexor;
`6 correct?
`7 A Right. That's what the multiplexor does, it
`8 selects one input to pass to its output.
`9 Q So in the next paragraph, Paragraph 22 of
`10 Exhibit 1038, you're describing the A/D converter;
`11 correct?
`12 A Yes.
`13 Q And in the last sentence of this paragraph
`14 you say, quote, "Various computational algorithm may
`15 be used to find the digital value quickly, and that
`16 algorithm is embedded in the A/D converter and
`17 controls its operation."
`18 Do you see that?
`19 A Correct.
`20 Q The choice of computational algorithm
`21 that's used to find the digital value quickly is
`22 made by the circuit designer; is that fair?
`23 A Which circuit are we talking about? Because
`24 the A to D system is a circuit and the overall
`25 Figure 1 is a circuit.
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`Page 22
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`1 Which circuit?
`2 Q Right. The person who designed the A/D
`3 converter is the person who chose the computational
`4 algorithm that the A/D converter uses to find the
`5 digital value quickly.
`6 Is that fair to say?
`7 A Generally that's the case, yes.
`8 Q And the designer then implements these
`9 algorithms into the A/D converter?
`10 A I'm sorry, what was the question?
`11 Q The designer of the A/D converter
`12 implements the chosen algorithm to find the digital
`13 value quickly into the A/D converter; correct?
`14 A Yes, that's correct.
`15 Q And once the A/D converter is fabricated,
`16 it will then use that computational algorithm to
`17 find the digital value quickly; correct?
`18 A I would say in most cases that would
`19 probably be the case. Designers are very clever and
`20 devices are made to be flexible.
`21 So there is even a possibility of devices
`22 where the user of the device would have some ability
`23 to tailor the process.
`24 So I guess what I'm saying is the
`25 algorithm need not be one algorithm. It could be a
`Page 23
`
`1 choice of several or variations on different
`2 algorithms.
`3 And the user of the device would control
`4 to some extent which one is being used.
`5 Q Dr. Neumann, are you aware of A/D
`6 convertors that allow the user to choose between
`7 multiple algorithms to use to find the digital value
`8 quickly that existed in the 1990s at the time that
`9 Horton was published?
`10 A Not off the top of my head, no.
`11 Q Does anything in the Horton reference
`12 disclose that the A/D converter could have been
`13 configured by the user to choose between multiple
`14 algorithms to find the digital value quickly?
`15 A No. No, I wasn't suggesting that. I was --
`16 when you say this was an algorithm embedded in a
`17 device, I was simply pointing out it could be a
`18 complex system that allows people to interact with it.
`19 I wasn't suggesting that was the case
`20 here.
`21 Q In the context of Horton, the A/D
`22 converter likely implemented one particular
`23 algorithm to find the digital value quickly?
`24 A There is no suggestion that it would be
`25 otherwise.
`
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`1 Q Earlier, the first sentence of that
`2 paragraph, you say that "A person of ordinary skill
`3 would also have recognized that the A/D converter is
`4 itself a small computing system because A/D
`5 conversion requires a sequence of computing steps."
`6 Do you see that?
`7 A Yes.
`8 Q As we were discussing, the designer of the
`9 A/D converter is the person who has implemented
`10 these computing steps; is that right?
`11 A Yes. Yes, it would be embedded in the A to
`12 D device, that's right.
`13 Q And at least in the context of the A/D
`14 convertors in Horton, once an A/D converter is
`15 fabricated, it typically would perform the same
`16 computing steps?
`17 A It would typically have a controller or a
`18 sequencer or a program, whatever you want to call it,
`19 that is fixed. But in terms of would it repeat the
`20 same steps, it would depend on the input, right?
`21 The input would determine which steps and
`22 how many of them are needed to find the digital
`23 value.
`24 Q But the steps it would perform would be
`25 fixed in the design of the A/D converter?
`
`Page 25
`1 A The program or the logic of the decision and
`2 the process, the conversion process, would be fixed.
`3 Q Let me direct you to Paragraph 24 on the
`4 following page of Exhibit 1038.
`5 A Okay.
`6 Q Can you actually read this paragraph to
`7 yourself and let me know when you're done.
`8 A Okay.
`9 MR. GLUCOFT: I apologize, I did not hear
`10 the paragraph number.
`11 MR. GHOSH: Twenty-four.
`12 Q So in the second sentence in this
`13 paragraph, the end of that sentence says, quote,
`14 "the designer of these devices would program the
`15 sequence of steps into some computing engine such as
`16 a sequential state machine or a small dedicated
`17 computing element."
`18 Do you see that?
`19 A Yes, I do.
`20 Q Is the sequential state machine or small
`21 dedicated computing element used by the designer?
`22 A The designer of the A to D device would use
`23 some logic or some sequencing machinery to embed this
`24 small program we've been discussing or small
`25 conversion process into a form that could be executed
`7 (Pages 22 - 25)
`IPR2022-01304
`Meta v. Thales
`Thales Exhibit 2025
`Page 7 of 22
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`

`

`Page 26
`1 in the A to D converter, that's what I'm basically
`2 saying, yes.
`3 Q Does the A/D converter described in Horton
`4 contain a small dedicated computing element?
`5 A It very likely does, yes. He doesn't
`6 specify a particular A to D converter, but as I point
`7 out, A to D convertors go through a process to make
`8 their conversion, make their calculation.
`9 And that process involves a series of
`10 steps and the series of steps has to be implemented
`11 in some fashion inside that chip just like it is in
`12 a microprocessor.
`13 And so the designer would implement that
`14 presumably the simplest, most cost-effective way
`15 possible, but it is some sequence of steps, it's an
`16 algorithm to compute the digital value.
`17 Q And that algorithm again is typically, at
`18 least at the time of Horton, reflected in the design
`19 of the A/D converter?
`20 A Yeah, that is the algorithm embedded in
`21 essence in the A to D converter. It's an embedded
`22 logical code or sequence, whatever you want to call
`23 it, it's an embedded process.
`24 That's what makes the A to D converter do
`25 what it does.
`
`Page 28
`
`1 Q Previously in that sentence you say in
`2 your opinion, quote, "that orchestration is a form
`3 of programming that involves performing
`4 computations."
`5 Do you see that?
`6 A Yes.
`7 Q And here you're referring to orchestration
`8 that is performed by the circuit designer?
`9 A Let's go back to this. There are two
`10 different designers we're talking about here. One is
`11 of the A to D converter, one is of the Figure 1
`12 system.
`13 In both cases the designer would have to
`14 orchestrate a sequence through some logic, through
`15 some program, through some hardware means, right, a
`16 computation that is being produced by the hardware
`17 elements.
`18 Q Right. And the designer of the A/D
`19 converter component is orchestrating the various
`20 steps involved in the A/D conversion and making that
`21 into the design of the A/D converter; is that right?
`22 A Yes, so the A to D converter designer, his
`23 concern or her concern or their concern is to produce
`24 a device which will do the conversion.
`25 So that's their concern.
`
`Page 27
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`Page 29
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`1 Q In the last sentence of Paragraph 24, you
`2 say, "As a person of ordinary skill would have
`3 recognized, the sequence of steps and their timing
`4 are usually expressed as a program that is stored in
`5 a read-only memory, as many other computer programs
`6 are."
`7 Do you see that?
`8 A Yes.
`9 Q Does the A/D converter as described in
`10 Horton contain read-only memory?
`11 A Well, Horton describes an A/D converter.
`12 I'm stating that an A to D converter usually -- I'm
`13 just making my sort of view and understanding of A to
`14 D convertors as part of this declaration.
`15 They contain a sequence of steps and that
`16 sequence of steps is often embedded in some sort of
`17 permanent memory so that the device works at power
`18 up and doesn't need to be booted, for example.
`19 So that requires a read-only memory to the
`20 sequence of instructions or logic that's going to be
`21 executed by the A to D converter.
`22 Q And I'm just asking a question whether
`23 that read-only memory would be physically located
`24 within the A/D converter?
`25 A Oh. Yes. Yes, it would be.
`
`1 Q And then the designer of the larger system
`2 in Horton is also orchestrating the interaction of
`3 all the various components and baking that into the
`4 larger circuit design; is that right?
`5 A That's basically correct, yes.
`6 Q Are you familiar with operational
`7 amplifiers?
`8 A Reasonably. I have not studied them for
`9 this discussion, but yes, I know something about them.
`10 Q If I refer to them as op amps, you'll
`11 understand what I mean?
`12 A Yes, I will.
`13 Q And leaving aside the power supply, an op
`14 amp typically has two inputs; is that right?
`15 A It has two polarity or negative and positive
`16 inputs, yes.
`17 Q And the op amps compute the difference in
`18 voltage or determine the difference in voltage
`19 between the two inputs?
`20 A Op amps take the difference of the two
`21 inputs and produce an output based on that, yes.
`22 Q And the output is the difference of
`23 voltage between the two inputs multiplied by an
`24 amplification factor?
`25 A Once you put an op amp in a circuit, you can
`8 (Pages 26 - 29)
`IPR2022-01304
`Meta v. Thales
`Thales Exhibit 2025
`Page 8 of 22
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
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`Page 30
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`1 make it do what you just described, yes. That's a
`2 typical case of what you would do with an op amp.
`3 Q Does an op amp perform a sequence of
`4 computing steps?
`5 A Does an op amp compute? An op amp generally
`6 is an intrinsically analog device. So there are such
`7 things as analog computers.
`8 Op amps can be used in integrator
`9 circuits, for example, where time is integrated and
`10 therefore you are computing time.
`11 Op amps can be used in a variety of ways,
`12 but an analog circuit by itself where it's simply
`13 producing a voltage gain, I guess that's a form of
`14 computation but it's not often referred to that way.
`15 MR. GHOSH: Let me take a break here.
`16 Maybe a five-minute break, if that's okay with you,
`17 Lynne.
`18 THE WITNESS: That's fine.
`19 THE REPORTER: Sure.
`20 (Recess taken.)
`21 MR. GHOSH: Now that I found my
`22 headphones, I have no further questions.
`23 MR. GLUCOFT: Can we take five minutes,
`24 please, maybe ten minut