UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________
`
`REALTEK SEMICONDUCTOR CORP.,
`Petitioner,
`v.
`ATI TECHNOLOGIES ULC
`Patent Owner.
`_________________________
`Case No. IPR2023-00922
`U.S. Patent No. 8,760,454
`_________________________
`
`DECLARATION OF CALVIN WATSON
`
`ATI Ex. 2122
`IPR2023-00922
`Page 1 of 56
`
`

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`TABLE OF CONTENTS
`
`Page
`BACKGROUND AND INTRODUCTION .................................................... 1
`I.
`PRIOR DECLARATIONS .............................................................................. 3
`II.
`III. PERFORCE ..................................................................................................... 5
`A. Documents Saved in Perforce ............................................................... 6
`1.
`PowerPoint Presentations (Program Reviews) ........................... 7
`2.
`Technical Specifications ............................................................. 8
`3.
`Other Documents ........................................................................ 9
`B. Metadata Saved in Perforce ................................................................... 9
`1.
`Document Logs .........................................................................10
`2.
`Folder Histories .........................................................................11
`IV. AUTHENTICATION OF EXHIBITS ..........................................................12
`1.
`Exhibit 2024 (Program Review) ...............................................12
`2.
`Exhibit 2025 (Technical Specification) ....................................12
`3.
`Exhibit 2026 (Technical Specification) ....................................13
`4.
`Exhibit 2027 (Technical Specification) ....................................13
`5.
`Exhibit 2028 (Technical Specification) ....................................14
`6.
`Exhibit 2032 (Program Review) ...............................................14
`7.
`Exhibit 2033 (Program Review) ...............................................14
`8.
`Exhibit 2038 (Technical Specification) ....................................15
`9.
`Exhibit 2040 (Program Review) ...............................................15
`10. Exhibit 2041 (Program Review) ...............................................15
`11. Exhibit 2071 (Regression Report) ............................................16
`12. Exhibit 2073 (Regression Reports) ...........................................16
`13. Exhibit 2079 (Technical Specification) ....................................18
`14. Exhibit 2088 (Program Review) ...............................................19
`15. Exhibit 2089 (Program Reviews) .............................................19
`16. Exhibit 2090 (Folder History) ...................................................26
`
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`17. Exhibit 2091 (Folder History) ...................................................26
`18. Exhibit 2092 (Folder History) ...................................................26
`19. Exhibit 2093 (Folder History) ...................................................27
`20. Exhibit 2094 (Folder History) ...................................................27
`21. Exhibit 2095 (Folder History) ...................................................27
`22. Exhibit 2096 (Folder History) ...................................................27
`23. Exhibit 2097 (Folder History) ...................................................28
`24. Exhibit 2098 (Document Logs) ................................................28
`25. Exhibit 2099 (Netlist Excel Files) ............................................34
`26. Exhibit 2112 (Document Logs and Folder Histories)...............35
`
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`IPR2023-00922
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`

`

`I, Calvin Watson, declare as follows:
`I.
`BACKGROUND AND INTRODUCTION
`1.
`I am a technical specialist and patent agent at Advanced Micro
`
`Devices, Inc. (“AMD”). My responsibilities include, among other things,
`
`supporting the AMD law department on various intellectual property matters.
`
`2.
`
`I understand that ATI merged with AMD in 2006. I understand that
`
`ATI’s documents are now managed on AMD’s database system, one of which is
`
`known as Perforce, which is the same system that ATI used before the merger with
`
`AMD. From my responsibilities at AMD, I am familiar with creating, editing,
`
`reviewing, maintaining, and retrieving files in Perforce.
`
`3.
`
`I understand the above captioned case filed by Petitioner Realtek
`
`Semiconductor Corp. involves U.S. Patent Number 8,760,454 (the “’454 patent”). I
`
`understand the ’454 patent is currently assigned to ATI Technologies ULC
`
`(“ATI”).
`
`4.
`
`In this declaration, I provide an overview of Perforce and the types of
`
`files that ATI/AMD engineers saved in Perforce. I also intend to authenticate the
`
`following Exhibits which were submitted in the ’454 patent IPR. The Exhibits
`
`below are true and correct copies of documents, folder histories, document logs,
`
`and/or metadata retrieved from AMD’s document databases. Each of these files
`
`was kept in the ordinary course of AMD/ATI’s business, and the original
`
`1
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`Page 4 of 56
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`

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`documents, folder histories, document logs, and/or metadata remain in AMD’s
`
`possession, custody, and control today. I understand these files were produced as
`
`exhibits to the instant case with the following exhibit numbers:
`
`Exhibit No. Reference Name
`Ex. 2024
`R400 Executive Review (Sept. 16, 2002)
`Ex. 2025
`GFIXIP 9x SX Micro-Architecture Specification (Version 1.0)
`Ex. 2026
`WD/IA/VGT Micro-Architecture Specification (Version 1.0)
`Ex. 2027
`GX9 SPI Specification (Version 1.0)
`Ex. 2028
`R400 Top Level Specification (Version 0.2)
`Ex. 2032
`R400 Program Review (Feb. 12, 2003)
`Ex. 2033
`R400 Program Review (Jan. 15, 2003)
`Ex. 2038
`R400 Primitive Assembly (Version 0.1)
`Ex. 2040
`R400 Program Review (Aug. 29, 2002)
`Ex. 2041
`R400 Program Review
`Ex. 2071
`Sqsp Regression Report
`Ex. 2073
`R400 Regression Testing
`Ex. 2079
`SQ Thread Trace 2.3 User’s Guide
`Ex. 2088
`R400 Executive Review (Sept. 16, 2002)
`Ex. 2089
`R400 Program Reviews (Various Dates)
`Ex. 2090
`R400 PA Block Folder History
`Ex. 2091
`R400 RB Block Folder History
`Ex. 2092
`R400 SC Block Folder History
`Ex. 2093
`R400 SPI Block Folder History
`Ex. 2094
`R400 SP Block Folder History
`Ex. 2095
`R400 SQ Block Folder History
`Ex. 2096
`R400 SX Block Folder History
`Ex. 2097
`R400 VGT Block Folder History
`Ex. 2098
`R400 Source Code Document Logs 10/1/2002 – 4/17/2003
`Ex. 2099
`R400 Netlist Area Sheets
`Ex. 2112
`R400 Source Code Document Logs and Folder Histories
`
`2
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`II.
`
`PRIOR DECLARATIONS
`5.
`I previously submitted two similar declarations authenticating AMD
`
`documents, source code, folder histories, and document logs in two other inter
`
`partes reviews. The first declaration was submitted in IPR2015-00325, and the
`
`second declaration was submitted in IPR2015-00326. I understand those
`
`declarations were submitted for the instant case as Exs. 2003 and 2117. Ex. 2003 in
`
`the instant case is my declaration from IPR2015-00325, and Ex. 2117 is my
`
`declaration from IPR2015-00326.
`
`6.
`
`I understand that some of the exhibits I discussed in my authenticating
`
`declaration in both IPR2015-00325 and IPR2015-00326 were submitted as exhibits
`
`in this case, but were renumbered for this case. In order to address any confusion
`
`created by the two sets of exhibit numbers, below I have included a table for these
`
`documents with the new exhibit number in the instant case, the old exhibit number
`
`from my prior declarations in the prior cases, and a citation to the declaration
`
`where I previously explained why they are authentic AMD/ATI documents.
`
`Exhibit
`Number in
`Instant Case
`Ex. 2009
`
`Ex. 2010
`
`Description
`
`R400 Testing Folder
`History
`R400 Sequencer
`Specification
`(Version 0.4)
`
`Prior IPR and
`Exhibit
`Number(s)
`IPR2015-00325,
`Ex. 2050
`IPR2015-00325,
`Ex. 2010
`
`Authentication
`Discussion
`Ex. 2003, ¶145
`
`Ex. 2003, ¶¶ 33-
`
`35
`
`3
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`Exhibit
`Number in
`Instant Case
`Ex. 2011
`
`Description
`
`R400 Sequencer
`Specification
`(Version 2.0)
`
`Prior IPR and
`Exhibit
`Number(s)
`IPR2015-00325,
`Ex. 2028
`
`Authentication
`Discussion
`Ex. 2003, ¶¶ 85-
`
`87
`
`Ex. 2012
`
`Ex. 2013
`
`Ex. 2104
`
`Ex. 2105
`
`Ex. 2106
`
`Ex. 2107
`
`Ex. 2108
`
`Ex. 2109
`
`R400 Shader
`Processor (Version
`0.1)
`
`IPR2015-00325,
`Ex. 2042
`
`Ex. 2003, ¶¶ 127-
`
`129
`
`R400 Top Level
`Specification
`(Version 0.2)
`
`R400 Sequencer
`Specification
`(Version 0.1)
`
`R400 Sequencer
`Specification
`(Version 0.3)
`
`R400 Sequencer
`Specification
`(Version 1.2)
`
`R400 Sequencer
`Specification
`(Version 1.8)
`
`R400 Sequencer
`Specification
`(Version 2.01)
`
`R400 Sequencer
`Specification
`(Version 2.07)
`
`IPR2015-00325,
`Ex. 2041
`
`IPR2015-00325,
`Ex. 2007
`
`IPR2015-00325,
`Ex. 2009
`
`IPR2015-00325,
`Ex. 2018
`
`IPR2015-00325,
`Ex. 2024
`
`IPR2015-00325,
`Ex. 2029
`
`Ex. 2003, ¶¶ 124-
`
`126
`
`Ex. 2003, ¶¶ 26-
`
`28
`
`Ex. 2003, ¶¶ 30-
`
`32
`
`Ex. 2003, ¶¶ 57-
`
`59
`
`Ex. 2003, ¶¶ 73-
`
`75
`
`Ex. 2003, ¶¶ 88-
`
`90
`
`IPR2015-00325,
`Ex. 2035
`
`Ex. 2003, ¶¶ 106-
`
`108
`
`4
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`Exhibit
`Number in
`Instant Case
`Ex. 2110
`
`Description
`
`Document Logs and
`File Histories
`
`Ex. 2111
`
`Ex. 2119
`
`Ex. 2120
`
`PowerPoint
`Presentations
`
`Technical
`Specifications,
`Document Logs, and
`File Histories
`Source Code
`
`Prior IPR and
`Exhibit
`Number(s)
`IPR2015-00325,
`Ex. 2043 - Ex.
`2052
`
`IPR2015-00325,
`Ex. 2057 - Ex.
`2071
`
`IPR2015-00326,
`Ex. 2007 - Ex.
`2072
`
`IPR2015-00326,
`Ex. 2073 - Ex.
`2118
`
`Authentication
`Discussion
`Ex. 2003, ¶¶ 136-
`
`147
`
`Ex. 2003, ¶¶ 133-
`
`135
`
`Ex. 2117, ¶¶ 23-
`129, 133-148
`
`Ex. 2117, ¶¶ 130-
`132
`(authenticating
`IPR2015-00326,
`Exs. 2093-2119)
`
`III. PERFORCE
`7.
`AMD and former ATI engineers used shared-file repositories for
`
`documents, source code, and other files. The system that manages the repositories
`
`is called Perforce. As part of my responsibilities, I understand how Perforce works
`
`and the types of documents that have been saved in Perforce with respect to this
`
`case.
`
`8.
`
`Perforce allows many users to connect to shared-file repositories.
`
`Each shared-file repository is called a depot. Files are organized in a depot using a
`
`file tree hierarchy. Any user with a permission to access the files can do so.
`
`5
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`9.
`
`Perforce maintains time stamped logs, user permissions, and whether
`
`files are checked out. This information is stored in a separate database. The
`
`information stored in this database is referred to as metadata.
`
`10. Users do not work directly on depot files. When a user checks out
`
`files, the files are saved to the user’s individual workspace according to the same
`
`file hierarchy in the depot. The user works on the files on his or her workspace.
`
`When the user is finished editing the files, the user checks in the files. Perforce
`
`then accesses the files on the user’s workspace and syncs the depot according to
`
`the user's changes.
`
`11.
`
`Perforce is a revision-control repository. This means that the system
`
`saves every revision of every file under Perforce control. When a user uploads an
`
`edited file, Perforce saves the file as a new version under the folder tree hierarchy.
`
`This type of system is particularly useful during development. For example, a
`
`version-control system allows a user to revert to a previous version of code. A user
`
`can therefore freely edit code while ensuring that the previous version is
`
`maintained.
`
`A.
`12.
`
`Documents Saved in Perforce
`Some of the Exhibits, which I am intending to authenticate below, are
`
`documents such as PowerPoint presentations, technical specifications, Excel
`
`6
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`spreadsheets, and source code. These documents are maintained in Perforce’s
`
`depot files and are kept in the regular course of business.
`
`PowerPoint Presentations (Program Reviews)
`1.
`The program reviews are PowerPoint presentations which are
`
`13.
`
`generally stored in Perforce and summarize R400 progress. These documents are
`
`kept in the regular course of business.
`
`14. As customary with AMD’s regular course of business, the program
`
`reviews include a date on the title slide which corresponds to the day the
`
`presentation was given.
`
`E.g., Ex. 2024 at p. 1.
`
`7
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`Technical Specifications
`2.
`The technical specifications are documents stored in Perforce which
`
`15.
`
`give a high level overview of the technical details of the R400 project. These
`
`documents are kept in the regular course of business.
`
`16.
`
`The author of the document manually enters the specification’s title,
`
`version number, author, and overview. Each field appears on the cover page.
`
`E.g., Ex. 2028 at p. 1.
`
`17.
`
`The cover page header includes the ORIGINATE DATE and the
`
`EDIT DATE. The ORIGINATE DATE is intended to be the date the original
`
`document (e.g., the first version within the depot folder) was created. The EDIT
`
`DATE is intended to be the date the document was last edited. The EDIT DATE is
`
`auto populated using a macro, and this macro cannot be disabled. So, every time
`
`8
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`the document is opened, the EDIT DATE changes. This macro is a revision-control
`
`feature of Perforce. Further, both the EDIT DATE and the ORIGINATE DATE
`
`can be manually changed.
`
`18.
`
`It is the regular and customary practice of AMD (and predecessor
`
`ATI) to record the date that a technical specification or testing record was edited.
`
`The record is kept on the document itself, as shown in a sample below.
`
`E.g., Ex. 2028 at p. 5.
`
`Other Documents
`3.
`19. Other documents stored in Perforce include Excel spreadsheets and
`
`Regression reports. As explained in further detail below, Perforce also includes
`
`data regarding revision history of the documents. Where any documents, such as
`
`some Excel spreadsheets, do not have a date visible on the face of the document, I
`
`have included the last edit date from the metadata in Perforce.
`
`B. Metadata Saved in Perforce
`20.
`Some of the Exhibits, which I authenticate below, are document logs
`
`and folder histories. Document logs and folder histories are metadata files. These
`
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`metadata files contain information relating to revision history of the depot files
`
`(e.g., technical specifications) maintained in Perforce. Through document logs and
`
`folder histories, Perforce allows administrators to track edits, track who made the
`
`edits, and track when the edits were made. Metadata files are kept in the regular
`
`course of business.
`
`21.
`
`In Perforce, there are two types of metadata files: (1) document logs;
`
`and (2) folder histories.
`
`Document Logs
`1.
`22. Document logs track each revision to the depot files in Perforce. Each
`
`depot file has a corresponding document log. So, each document log tells the
`
`revision history of its corresponding file.
`
`23.
`
`Perforce maintains certain information in document logs. For
`
`example, Perforce automatically saves the date a document was changed and the
`
`workspace that made the change. Further, for any edited file a user uploads to the
`
`system, the user is prompted to enter a description of the file or a brief description
`
`of the changes made to the file.
`
`24. An excerpt of sample document log is shown below for the source
`
`code file pa.v. In this excerpt, four revisions were uploaded. Various users
`
`uploaded the revisions on various dates.
`
`10
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`E.g., Ex. 2098 at p. 1.
`
`Folder Histories
`2.
`Folder histories list the same information as the document logs. The
`
`25.
`
`difference is that a folder history compiles all the document log files saved within
`
`the folder and its subfolders. The information in the folder history file is organized
`
`by date. An excerpt of a sample folder history file is shown below.
`
`E.g., Ex. 2090 at p. 1.
`
`11
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`IV. AUTHENTICATION OF EXHIBITS
`26. As part of my responsibilities, I verified the Exhibits listed in Section
`
`IV of this Declaration with documents and metadata stored in Perforce and on
`
`internal AMD databases. My responsibilities include, among other things,
`
`supporting the AMD law department on various intellectual property matters. I am
`
`authenticating these Exhibits. The Exhibits include: (1) technical specifications; (2)
`
`PowerPoint presentations such as program reviews; (3) Excel spreadsheets; (4)
`
`regression testing; and (5) metadata, which include file histories and document
`
`logs.
`
`Exhibit 2024 (Program Review)
`1.
`Exhibit 2024 is a true and accurate copy of a PowerPoint presentation
`
`27.
`
`from a program review meeting that is indicated on the face of the document to
`
`have occurred during development of the R400. The title page is dated September
`
`16, 2002. Ex. 2024 at p. 1. The file name is Review020916.ppt.
`
`28.
`
`Exhibit 2024 is stored in Perforce at
`
`//depot/r400/web/project/Program Reviews/Executive
`
`Reviews/Review020916.ppt#1.
`
`Exhibit 2025 (Technical Specification)
`2.
`Exhibit 2025 is a true and accurate copy of a technical specification.
`
`29.
`
`The file name is GFXIP_9x_SX_MAS.docx. It was last edited by Dong Yiao on
`
`February 12, 2014. See Ex. 2025 at p. 2.
`
`12
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`30.
`
`Exhibit 2025 is stored in Perforce at
`
`//depot/macosx/extras/docs/HW_Docs/GFX9/Block
`
`Specs/sx/GFXIP_9x_SX_MAS.docx#1.
`
`Exhibit 2026 (Technical Specification)
`3.
`Exhibit 2026 is a true and accurate copy of a technical specification.
`
`31.
`
`The file name is IA_VGT_Spec.docx. As provided by Perforce, the last change
`
`made to this file was on August 12, 2015, by Glenn Ortner. Glenn Ortner is a
`
`Fellow Software Development Engineer at AMD and is currently still employed at
`
`AMD.
`
`32.
`
`Exhibit 2026 is stored in Perforce at
`
`//depot/macosx/extras/docs/HW_Docs/GFX9/Block
`
`Specs/vgt/IA_VGT_Spec.docx#1.
`
`Exhibit 2027 (Technical Specification)
`4.
`Exhibit 2027 is a true and accurate copy of a technical specification.
`
`33.
`
`The file name is gfx9_SPI_Specification#1.docx. It was last edited November 3,
`
`2016. See Ex. 2027 at p. 1.
`
`34.
`
`Exhibit 2027 is stored in Perforce at
`
`//depot/macosx/extras/docs/HW_Docs/GFX9/Block
`
`Specs/spi/gfx9_SPI_Specification.docx#1.
`
`13
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`Exhibit 2028 (Technical Specification)
`5.
`Exhibit 2028 is a true and accurate copy of a technical specification
`
`35.
`
`describing the development of the R400. The file name is R400 Top Level
`
`Spec.DOC. Steve Morein created this document on March 11, 2001. See Ex. 2028
`
`at p. 1, 5. Steven Morein also revised the document on March 14, 2001, and April
`
`21, 2001. See id. at p. 5.
`
`36.
`
`Exhibit 2028 is stored in Perforce at //depot/r400/arch/doc/chip/R400
`
`Top Level Spec.DOC#7.
`
`Exhibit 2032 (Program Review)
`6.
`Exhibit 2032 is a true and accurate copy of a PowerPoint presentation
`
`37.
`
`from a program review meeting that is indicated on the face of the document to
`
`have occurred during development of the R400. The title page is dated February
`
`12, 2003. Ex. 2032 at p. 1. The file name is Lili S. - R400 reviewfeb03.ppt.
`
`38.
`
`Exhibit 2032 is stored in Perforce at
`
`//depot/r400/web/project/Program Reviews/Feb2003_Review/Lili S. - R400
`
`reviewfeb03.ppt#1.
`
`Exhibit 2033 (Program Review)
`7.
`Exhibit 2033 is a true and accurate copy of a PowerPoint presentation
`
`39.
`
`from a program review meeting that is indicated on the face of the document to
`
`have occurred during development of the R400. The title page is dated January 15,
`
`2003. Ex. 2033 at p. 1. The file name is Lili S. - R400 reviewjan03.ppt.
`
`14
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`40.
`
`Exhibit 2033 is stored in Perforce at
`
`//depot/r400/web/project/Program Reviews/Jan2003_Review/Lili S. - R400
`
`reviewjan03.ppt#1.
`
`Exhibit 2038 (Technical Specification)
`8.
`Exhibit 2038 is a true and accurate copy of a technical specification
`
`41.
`
`describing the development of the R400. The file name is R400_CP_PA_Top.doc.
`
`Clay Taylor created this document on October 29, 2001. See Ex. 2028 at pp. 1, 3.
`
`42.
`
`Exhibit 2038 is stored in Perforce at
`
`//depot/r400/doc_lib/design/blocks/pa/R400_CP_PA_Top.doc#1.
`
`Exhibit 2040 (Program Review)
`9.
`Exhibit 2040 is a true and accurate copy of a PowerPoint presentation
`
`43.
`
`from a program review meeting that is indicated on the face of the document to
`
`have occurred during development of the R400. The title page is dated August 29,
`
`2002. Ex. 2040 at p. 1. The file name is Bob P. - R400_PD.ppt.
`
`44.
`
`Exhibit 2040 is stored in Perforce at
`
`//depot/r400/web/project/Program Reviews/AugustReview/Bob P. -
`
`R400_PD.ppt#1.
`
`10. Exhibit 2041 (Program Review)
`Exhibit 2041 is a true and accurate copy of a PowerPoint presentation
`
`45.
`
`from a program review meeting that is indicated on the face of the document to
`
`have occurred during development of the R400. The file name is Frank H. -R400 -
`
`15
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`Program Review - August 2002.ppt. As provided by Perforce, the last change made
`
`to this file was on September 11, 2002 by Joseph Cox. Joseph Cox was the CVP of
`
`Silicon Design Engineering at AMD, and he left AMD on December 31, 2020.
`
`46.
`
`Exhibit 2041 is stored in Perforce at
`
`//depot/r400/web/project/Program Reviews/AugustReview/Frank H. -R400 -
`
`Program Review - August 2002.ppt#1.
`
`11. Exhibit 2071 (Regression Report)
`Exhibit 2071 is a true and accurate copy of a regression report of the
`
`47.
`
`SQ block of the R400 dated January 22, 2004. The file name is
`
`sqsp_regress_report012204.txt.
`
`48.
`
`Exhibit 2071 is stored in Perforce at
`
`//depot/r400/web/project/Validation/Reports/regress/tb_sqsp/sqsp_regress_report0
`
`12204.txt.
`
`49.
`
`50.
`
`12. Exhibit 2073 (Regression Reports)
`Exhibit 2073 is a compilation of several different documents.
`
`Page 1 to 135 is a true and accurate copy of an emulation regression
`
`test history of the R400 dated April 16, 2003. The file name is
`
`r400_emu_test_regress_history_041603.txt. The file is stored in Perforce at
`
`//depot/r400/web/project/Validation/Reports/Emulation/r400_emu_test_regress_hi
`
`story_041603.txt.
`
`16
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`51.
`
`Pages 136 to 160 is a true and accurate copy of an emulation
`
`regression test history of the R400 dated August 5, 2002. The file name is
`
`r400_emu_test_regress_history_080502.txt. The file is stored in Perforce at
`
`//depot/r400/web/project/Validation/Reports/Emulation/r400_emu_test_regress_hi
`
`story_080502.txt.
`
`52.
`
`Pages 161 to 185 is a true and accurate copy of an emulation
`
`regression test history of the R400 dated August 6, 2002. The file name is
`
`r400_emu_test_regress_history_080602.txt. The file is stored in Perforce at
`
`//depot/r400/web/project/Validation/Reports/Emulation/r400_emu_test_regress_hi
`
`story_080602.txt.
`
`53.
`
`Pages 186 to 273 is a true and accurate copy of an emulation
`
`regression test history of the R400 dated December 3, 2002. The file name is
`
`r400_emu_test_regress_history_120302.txt. The file is stored in Perforce at
`
`//depot/r400/web/project/Validation/Reports/Emulation/r400_emu_test_regress_hi
`
`story_120302.txt.
`
`54.
`
`Pages 274 to 367 is a true and accurate copy of an emulation
`
`regression test summary of the R400 dated December 31, 2002. The file name is
`
`r400_emu_test_regress_history_123102.txt. The file is stored in Perforce at
`
`//depot/r400/web/project/Validation/Reports/Emulation/r400_emu_test_regress_hi
`
`story_123102.txt.
`
`17
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`

`55.
`
`Page 368 is a true and accurate copy of an emulation regression test
`
`summary of the R400 dated April 16, 2003. The file name is
`
`r400_emu_test_regress_statistics_041603.log. The file is stored in Perforce at
`
`.//depot/r400/web/project/Validation/Reports/Emulation/r400_emu_test_regress_st
`
`atistics_041603.log.
`
`56.
`
`Page 369 is a true and accurate copy of an emulation regression test
`
`summary of the R400 dated December 3, 2002. The file name is
`
`r400_emu_test_regress_statistics_120302.log. The file is stored in Perforce at
`
`//depot/r400/web/project/Validation/Reports/Emulation/r400_emu_test_regress_sta
`
`tistics_120302.log.
`
`57.
`
`Page 370 is a true and accurate copy of an emulation regression test
`
`summary of the R400 dated December 31, 2002. The file name is
`
`r400_emu_test_regress_statistics_123102.log. The file is stored in Perforce at
`
`//depot/r400/web/project/Validation/Reports/Emulation/r400_emu_test_regress_sta
`
`tistics_123102.log.
`
`13. Exhibit 2079 (Technical Specification)
`Exhibit 2079 is a true and accurate copy of a technical specification.
`
`58.
`
`The file name is GFX9_sq_thread_trace_users_guide.docx. It was authored by
`
`Brian Emberling, Jeremy Furtek, Andrew Pomianowski, Guennadi Riguer, and
`
`Andrew Brown. See Ex. 2079, at p. 1. As provided by Perforce, the last change
`
`18
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`

`made to this file was on March 11, 2016 by Edward Mandac. Edward Mandac is a
`
`Sr. Manager in Software Development at AMD and is currently still employed at
`
`AMD.
`
`59.
`
`Exhibit 2079 is stored in Perforce at
`
`//depot/macosx/extras/docs/HW_Docs/GFX9/Block
`
`Specs/sq/GFX9_sq_thread_trace_users_guide.docx#1.
`
`14. Exhibit 2088 (Program Review)
`Exhibit 2088 is a true and accurate copy of a PowerPoint presentation
`
`60.
`
`from a program review meeting that is indicated on the face of the document to
`
`have occurred during development of the R400. The title page is dated September
`
`16, 2002. Ex. 2008 at p. 1. The file name is R400_September16.ppt.
`
`61.
`
`Exhibit 2088 is a duplicate copy of a file stored in Perforce under a
`
`different file name at //depot/r400/web/project/Program Reviews/Executive
`
`Reviews/Review020916.ppt#1.
`
`15. Exhibit 2089 (Program Reviews)
`Exhibit 2089 is a compilation of several different documents.
`
`Page 1 is a true and accurate copy of the original Excel Spreadsheet
`
`62.
`
`63.
`
`incorporated into another exhibit, Exhibit 2088, at page 9.
`
`64.
`
`Page 2 is a true and accurate copy of the original Excel Spreadsheet
`
`incorporated into another exhibit, Exhibit 2088, at page 2.
`
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`65.
`
`Pages 3 through 14 is a true and accurate copy of a PowerPoint
`
`presentation from a program review meeting that is indicated on the face of the
`
`document to have occurred during development of the R400. The title page is
`
`dated September 30, 2002. Ex. 2089 at p. 3. The file name is
`
`R400_September30.ppt. This file is a duplicate copy of a file stored in Perforce
`
`under a different file name at //depot/r400/web/project/Program
`
`Reviews/Executive Reviews/Review020930-BW.ppt#1.
`
`66.
`
`Pages 15 through 28 is a true and accurate copy of a PowerPoint
`
`presentation from a program review meeting that is indicated on the face of the
`
`document to have occurred during development of the R400. The title page is
`
`dated October 28, 2002. Ex. 2089 at p. 15. The file name is R400_October28.ppt.
`
`This file is a duplicate copy of a file stored in Perforce under a different file name
`
`at //depot/r400/web/project/Program Reviews/Executive Reviews/Review021028-
`
`BW.ppt#1.
`
`67.
`
`68.
`
`Page 29 is intentionally omitted.
`
`Pages 30 through 45 is a true and accurate copy of a PowerPoint
`
`presentation from a program review meeting that is indicated on the face of the
`
`document to have occurred during development of the R400. The title page is
`
`dated October 15, 2002. Ex. 2089 at p. 30. The file name is R400_October15.ppt.
`
`This file is a duplicate copy of a file stored in Perforce under a different file name
`
`20
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`at //depot/r400/web/project/Program Reviews/Executive Reviews/Review021015-
`
`BW.ppt#1.
`
`69.
`
`70.
`
`Page 46 is intentionally omitted.
`
`Pages 47 through 57 is a true and accurate copy of a PowerPoint
`
`presentation from a program review meeting that is indicated on the face of the
`
`document to have occurred during development of the R400. The title page is
`
`dated November 11, 2002. Ex. 2089 at p. 47. The file name is
`
`R400_November11.ppt. This file is stored in an internal AMD database at
`
`\\cviis01\wwwroot\ProgramManagement\Documents\Exec_Reviews\11
`
`November02\R400_November11.ppt.
`
`71.
`
`Pages 58 through 68 is a true and accurate copy of a PowerPoint
`
`presentation from a program review meeting that is indicated on the face of the
`
`document to have occurred during development of the R400. The title page is
`
`dated November 25, 2002. Ex. 2089 at p. 58. The file name is
`
`R400_November25.ppt. This file is stored in an internal AMD database at
`
`\\cviis01\wwwroot\ProgramManagement\Documents\Exec_Reviews\11
`
`November02\R400_November25.ppt.
`
`72.
`
`Pages 69 through 79 is a true and accurate copy of a PowerPoint
`
`presentation from a program review meeting that is indicated on the face of the
`
`document to have occurred during development of the R400. The title page is
`
`21
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`dated December 9, 2002. Ex. 2089 at p. 69. The file name is
`
`R400_December09.ppt. This file is stored in an internal AMD database at
`
`\\cviis01\wwwroot\ProgramManagement\Documents\Exec_Reviews\12
`
`December02\R400_December09.ppt.
`
`73.
`
`Pages 80 through 90 is a true and accurate copy of a PowerPoint
`
`presentation from a program review meeting that is indicated on the face of the
`
`document to have occurred during development of the R400. The title page is
`
`dated December 16, 2002. Ex. 2089 at p. 80. The file name is
`
`R400_December16.ppt. This file is stored in an internal AMD database at
`
`\\cviis01\wwwroot\ProgramManagement\Documents\Exec_Reviews\12
`
`December02\R400_December16.ppt.
`
`74.
`
`Pages 91 through 99 is a true and accurate copy of a PowerPoint
`
`presentation from a program review meeting that is indicated on the face of the
`
`document to have occurred during development of the R400. The title page is
`
`dated December 23, 2002. Ex. 2089 at p. 91. The file name is
`
`R400_December23.ppt. This file is stored in an internal AMD database at
`
`\\cviis01\wwwroot\ProgramManagement\Documents\Exec_Reviews\12
`
`December02\R400_December23.ppt.
`
`75.
`
`Pages 100 through 109 is a true and accurate copy of a PowerPoint
`
`presentation from a program review meeting that is indicated on the face of the
`
`22
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`

`document to have occurred during development of the R400. The title page is
`
`dated January 6, 2003. Ex. 2089 at p. 100. The file name is R400_Jan6.ppt. This
`
`file is stored in an internal AMD database at
`
`\\cviis01\wwwroot\ProgramManagement\Documents\Exec_Reviews\January\R400
`
`_Jan6.ppt.
`
`76.
`
`Pages 110 through 118 is a true and accurate copy of a PowerPoint
`
`presentation from a program review meeting that is indicated on the face of the
`
`document to have occurred during development of the R400. The title page is
`
`dated January 13, 2003. Ex. 2089 at p. 110. The file name is R400_Jan13.ppt. This
`
`file is stored in an internal AMD database at
`
`\\cviis01\wwwroot\ProgramManagement\Documents\Exec_Reviews\January\R400
`
`_Jan13.ppt.
`
`77.
`
`Pages 119 through 134 is a true and accurate copy of a PowerPoint
`
`presentation from a program review meeting that is indicated on the face of the
`
`document to have occurred during development of the R400. The title page is
`
`dated January 20, 2003. Ex. 2089 at p. 119. The file name is R400_Jan20.ppt. This
`
`file is stored in an internal AMD database at
`
`\\cviis01\wwwroot\ProgramManagement\Documents\Exec_Reviews\January\
`
`R400_Jan20.ppt.
`
`23
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`

`78.
`
`Pages 135 through 149 is a true and accurate copy of a PowerPoint
`
`presentation from a program review meeting that is indicated on the face of the
`
`document to have occurred during development of the R400. The title page is
`
`dated January 27, 2003. Ex. 2089 at p. 135. The file name is R400_Jan27.ppt. This
`
`file is stored in an internal AMD database at
`
`\\cviis01\wwwroot\ProgramManagement\Documents\Exec_Reviews\January\R400
`
`_Jan27.ppt.
`
`79.
`
`Pages 150 through 162 is a true and accurate copy of a PowerPoint
`
`presentation from a program review meeting that is indicated on the face of the
`
`document to have occurred during development of the R400. The title page is
`
`dated February 10, 2003. Ex. 2089 at p. 150. The file name is R400_Feb10