`
`Transcript of William Mangione-
`Smith, Ph.D.
`
`Date: May 10, 2024
`Case: Realtek Semiconductor Corp. -v- ATI Technologies ULC (PTAB)
`
`Planet Depos
`Phone: 888.433.3767
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`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`Realtek Ex. 1019, Page 1
`Realtek Semiconductor Corp. v. ATI Technologies ULC
`IPR2023-00922
`
`

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`Transcript of William Mangione-Smith, Ph.D.
`Conducted on May 10, 2024
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` EXAMINATION INDEX
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` EXAMINATION BY: PAGE NO.
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`MR. JOHNSON 4
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` EXHIBIT INDEX
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` EXHIBIT NO. DESCRIPTION PAGE NO.
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` (No exhibits marked for identification.)
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`REALTEK SEMICONDUCTOR CORP., )
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` )
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` Petitioner, )
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` vs. ) Case No. IPR2023-00922
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`ATI TECHNOLOGIES ULC, )
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`1 2 3 4 5 6 7 8 9 1
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` ) U.S. Patent No.
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` Patent Owner. ) 8,760,454
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` DEPOSITION OF WILLIAM MANGIONE-SMITH, PH.D.
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` May 10, 2024
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` Seattle, Washington
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` 9:09 a.m
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`Reporter: Teri Simons, CCR, RMR, CRR
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` APPEARANCES
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`For the Petitioner:
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` Jeffrey L. Johnson
` Baker Botts LLP
` 910 Louisiana Street
` Houston, TX 77002-4995
` 713.229.1222
` Jeffrey.johnson@bakerbotts.com
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`For the Patent Owner:
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` Reza Dokhanchy
` Mintz Levin Cohn Ferris Glovsky &
` Popeo
` 3580 Carmel Mountain Road
` Suite 300
` San Diego, CA 92130
` 858.314.1596
` Rdokhanchy@mintz.com
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` BE IT REMEMBERED that on Friday,
` May 10, 2024, at 9:09 a.m., before Terilynn Simons,
` Certified Court Reporter, CCR, RMR, CRR, CLR, appeared
` WILLIAM MANGIONE-SMITH, PH.D., the witness herein;
` WHEREUPON, the following proceedings
` were had, to wit:
` <<<<<< >>>>>>
` WILLIAM MANGIONE-SMITH, PH.D., having been first duly
` sworn by the Certified Court
` Reporter, testified as follows:
`0
` EXAMINATION
`11
` BY MR. JOHNSON:
`12
`Q Good morning, Dr. Smith, Dr. Mangione-Smith--
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`A "Mangione-Smith," please.
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`Q "Mangione-Smith," okay, I'll do my best.
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`A Thank you.
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`Q I don't think I have ever deposed you before, so it's
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` nice to meet you.
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` Are you ready to begin today?
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`A I am.
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` Nice to meet you as well, and I don't recall being
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` deposed by you as well.
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`Realtek Ex. 1019, Page 2
`Realtek Semiconductor Corp. v. ATI Technologies ULC
`IPR2023-00922
`
`

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`Transcript of William Mangione-Smith, Ph.D.
`Conducted on May 10, 2024
`5
`Q So since we haven't met before, I'll just go over a few
` basic things that I'm sure you're very well aware of
` because I know you've been deposed many times.
` Is there any reason you can't give me truthful
` answers today?
`A Not that I'm aware of.
`Q Are you on any kind of medication that will impair your
` ability to understand my questions or give answers today?
`A No.
`Q Okay. I see that you've brought some papers with you
` today.
` Can you tell me what those are?
`A Sure.
` Printouts of my report and some of the materials
` that are cited.
`Q Can you just go through them and identify each one for
` me?
`A Sure.
` The first one is ATI Exhibit No. 2071, and I know
` there is an issue with some of them having two exhibit
` numbers, so I'm going to do my best to get the right
` exhibit number.
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` were made to various circuitry. In this case I believe
` it's all focused on the SQ circuitry.
` Next is ATI Exhibit No. 2099. This is a document
` that has estimates for the area required for different
` circuit blocks in the R400.
` Next is ATI Exhibit 2111. It's titled, "ATI
` Technologies Incorporated R400 program."
` Then I have Realtek Exhibit 1001. This is the '454
` patent.
` Then Realtek Exhibit 1009. This is a reprint of
` the-- this is what I have referred to as the Selzer
` reference, S-E-L-Z-E-R, titled, "Dynamic load balancing
` within a high performance graphics system."
` Next is Realtek 1008. It's a magazine article
` titled, "Introducing the Intel I860 64-bit
` microprocessor."
` Next is Realtek Exhibit 1007. This is a reprint of
` the article, "A simple flexible parallel graphics
` architecture," where the lead author is John Amanatides,
` A-M-A-T-I-D-E-S.
` Next is Realtek Exhibit No. 1010 titled, "Thread
` prioritization, a thread scheduling mechanism for
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` multi-context parallel processors," and this is typically
` Do you want me to characterize it as well?
` referred to by me as the "Fiske reference," F-I-S-K-E.
`Q Can you just tell me briefly what it is?
` Then I have a printout of my declaration, which is
`A Sure.
` ATI Exhibit 2121.
` This is what's called a regression log of testing
` various circuits, and it looks like it's got a date of
`Q Thank you.
` being run on January of 2004.
` Are those clean copies or do you have any notes or
` marks in them?
`Q And do you know what it was testing?
`A I have not made any notes or marks on any of these.
`A In my notes I probably do.
` I didn't print them out, so I couldn't swear that
` There is a comment at the top that it's-- oh, it's a
` they were clean, but I know of no markings in them.
` regression report for the SQ on the R400 project.
`0
`Q So somebody else gave them to you?
`Q Okay. All right. And the next one?
`11
`A Yes.
`A The next one is titled, "R400 Top Level specification,
`12
` Version 0.2," and it's got an exhibit number of ATI
`Q I assume that was Counsel?
`13
`A Yes.
` Exhibit 2013.
`14
`Q Okay. So did you ask for printouts of those or they
`Q Okay.
`15
`A The next one is titled, "Shader processor, Version 0.1,"
` provided those at their own discretion?
`16
`A They were provided to me yesterday while we were doing
` and the exhibit number is ATI Exhibit 2012.
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` preparation for the deposition today.
` The next is "R400 sequencer specification," and then
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` below that it says, "SEQ, Version 0.4," Exhibit ATI 2010.
`Q Okay. And did you make that selection or did Counsel
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` make it, in terms of which documents to print?
`Q Okay.
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`A Well, I think-- it's hard to say.
`A Then there is ATI Exhibit 2095, which is what is often
`21
` Which ones to print, I certainly didn't direct any
` referred to as a change log. It's a log of changes that
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`Realtek Ex. 1019, Page 3
`Realtek Semiconductor Corp. v. ATI Technologies ULC
`IPR2023-00922
`
`

`

`Transcript of William Mangione-Smith, Ph.D.
`Conducted on May 10, 2024
`9
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`3 (9 to 12)
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`11
` had, you know, typed up different sections and said, you
` know, "What do you think of this," or I said, "We need to
` argue X, Y, and Z," and somebody said, "Well, then I'll
` take a crack at that," and then I reviewed it.
`Q Okay. So maybe, as we go through today, you can identify
` portions where you think you might have made the initial
` draft and others where they were provided to you, if
` possible.
` Would that be okay?
`A Sure.
`Q Okay. Once the declaration was finalized but before you
` signed it, did you review it?
`A Yes.
`Q And after you signed it and submitted it in this case,
` have you reviewed it again?
`A Yes.
`Q Have you found it to contain any errors or mistakes,
` anything you want to correct on the record before we get
` started?
`A Nothing that occurs to me as I sit here today.
`Q I'm sure there's typos in any document. I am not talking
` about those, just any other kind of mistakes that you
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` printing.
` Counsel came with a large box. He may have printed
` everything that was an exhibit. I just don't know.
`Q Okay. And so you met with Counsel yesterday to prepare
` for your deposition?
`A Yes.
`Q And did you do anything else to prepare for your
` deposition, other than meet with Counsel yesterday?
`A Certainly. I did some reviewing this morning and over
` the last couple of weeks.
`Q Okay. Did you have any other meetings with any other
` individuals?
`A No.
`Q Any phone calls, conversations with any other individuals
` to prepare for your deposition?
`A Not that I can recall, not specifically to prepare for my
` deposition.
`Q And Counsel was Reza or were there other attorneys
` present?
`A No, it was just he.
`Q Okay. So I was going to mark the patent and your
` declaration, but I'm not going to do that.
`
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` might have noticed.
` You already have a copy.
`A Nothing that occurs to me.
` (Discussion off the record.)
`Q Okay. Thank you.
`Q (By Mr. Johnson) With respect to your declaration, which
` In your declaration you refer to the transcripts of
` is Exhibit No. 2121, did you prepare that declaration on
` some other individuals, like Mr. Gruber and others,
` your own?
`A It contains-- the opinions expressed in there are my
` Dr. Watson-- I mean, Mr. Watson.
` opinions.
` Did you have any conversations with those
` I certainly had assistance in discussion with other
` individuals, where you cite to their transcripts, in
` individuals along the process of me developing the
` preparing for your declaration?
`A I don't believe so, not that I recall.
` declaration.
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`Q So to the extent that you cite to them or rely on them in
`Q That was a bad question.
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` your declaration, you are basing that solely on the
` Did you write the initial draft of the declaration?
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`A Even that's a little hard to answer because some of it,
` documents that you reviewed, correct?
`13
`A That's my recollection.
` for example, is my background and an explanation of my
`14
` It's my practice, if I'm relying on a personal
` understanding of the law, I believe. That's typically in
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` discussion, I will cite it that way, but I don't recall
` there.
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` any such conversations.
` Those sections have been developed over many years
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` with many different clients.
`Q And you can feel free to look at any of the documents
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` Furthermore, there have been two declarations in
` that you brought with you today as you need them. It
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` this matter, and I looked at the technology over the
` doesn't bother me at all, okay?
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` years, working previously in the context of an ITC
` If you need a break or anything, just let me know.
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` matter, so, sure, it's possible that different people
` I am very flexible.
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`Realtek Ex. 1019, Page 4
`Realtek Semiconductor Corp. v. ATI Technologies ULC
`IPR2023-00922
`
`

`

`Transcript of William Mangione-Smith, Ph.D.
`Conducted on May 10, 2024
`13
`
`4 (13 to 16)
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`15
`A So outside of the context of the '454, a vertex operation
` would be an operation that works on vertex data.
`Q Okay. And then a little later in Claim 1 it refers to
` "vertex calculation operation."
` Do you see that?
`A I don't doubt it's in there. I'm just not seeing it.
`Q Sorry, I think I said "Vertex."
` I meant "pixel," "pixel calculation operation."
` Do you see that?
`A I see "pixel calculation" but not "pixel operation
` calculation."
`Q Let me restart. Sorry.
` In the continuing clause of Claim 1, there's a
` reference to "pixel calculation operations."
` Do you see that?
`A Yes.
`Q Was that a term of art that you were aware of before
` encountering the '454 patent?
`A I would say the concept is.
` I don't recall with great confidence seeing exactly
` that sequence of words.
`Q Is there a difference between a vertex manipulation
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` I try to take breaks as quickly as I can when you
` ask for them. If I'm asking a question, and I want to
` finish one or two things, I will try to do that quickly,
` but feel free to ask, okay?
`A That sounds good.
` I prefer to take a break, a brief one, every hour,
` just to stretch my legs.
`Q I will do my best.
` I am sure your counsel will remind me often.
` Do you recall that there's a term in the '454 patent
` claims that says, "Vertex manipulation operation"?
` Have you heard of that term before?
`A It seems familiar.
` Can you point me to the section where that appears?
`Q Sure.
` You can just look at Claim 1 in Exhibit No. 1001.
` Claim 1 appears in Column 6.
`A Yes, I see that.
`Q Is "vertex manipulation operation" a term of art?
`A I don't recall hearing exactly that sequence of words
` previously, but certainly the-- I think that there's a
` clear understanding to a person of ordinary skill in the
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` art.
`Q So we'll get to that.
` I just want to know, in your experience as a person
` of ordinary skill in the art and an expert in the field,
` whether or not you had heard the term "vertex
` manipulation operation" before.
`A It's possible.
` The concept I certainly had heard of, but I don't
` recall exactly hearing that sequence of words previously.
`Q Is-- and then a little later in Claim 1 it refers to a
` "vertex operation."
` Is that a term of art?
`A I think that's a little bit closer to a term of art, so I
` would say yes.
`Q Okay. And so you have encountered that term in your past
` experiences prior to the '454 patent?
`A I believe so, but I am not suggesting that I have a
` reference to point to.
`Q That's fine. I just want to know what your general
` understanding was outside of the context of the '454
` patent as to what a vertex operation would have been.
` Can you give me that understanding?
`
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` operation, a vertex operation, and a vertex calculation
` operation?
`A Sure.
`Q Okay. Can you explain to me the difference between those
` three terms?
`A Well, there are a number of different types of
` operations.
` I think "operation" was in all three of those terms.
` "Vertex manipulation operation" would be an
` operation that manipulates, I would say, the vertices,
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` and the third one was a vertex, I think, calculation--
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` just "vertex operations"--
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`Q Yes.
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`A No--
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`Q Okay. Let me ask the question just to make sure you're
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` not floundering around.
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` So you've already identified what you believe is a
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` vertex manipulation operation. I appreciate that.
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` What I would like to know is, how is that different
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` from just a general vertex operation?
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` Let's start there.
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`A It is an instance of a vertex operation.
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`Realtek Ex. 1019, Page 5
`Realtek Semiconductor Corp. v. ATI Technologies ULC
`IPR2023-00922
`
`

`

`Transcript of William Mangione-Smith, Ph.D.
`Conducted on May 10, 2024
`17
`
`5 (17 to 20)
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`A Yes, I do.
`Q Are these the legal principles that you used to conduct
` any claim construction that you felt needed to be done in
` forming your opinions for your declaration?
`A These are the legal principles that have been explained
` to me, as I understand them, regarding claim
` construction, yes.
`Q Were you provided any other legal principles that you
` relied on in conducting any claim construction that you
` felt needed to be done?
`A I guess the answer would be no, I don't recall conducting
` any claim construction in this matter, but it's a long
` report. Maybe it's in there.
`Q Okay. In Paragraph No. 53 and 54, I am just going to
` summarize, but I think you identify that there are two
` possibilities for claim construction.
` One is that a term could be given its ordinary and
` customary meaning, and the other is that it could be
` given a special definition in the patent, which would
` supersede any plain and ordinary meaning; is that
` correct?
`A That is generally my understanding.
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`Q But I take it that vertex operations are broader, they
` may include more things?
`A I believe so, yes.
`Q Okay. And then I'm asking you if you have ever heard of
` the term "vertex calculation operation."
`A Yeah, I believe that was in here, right?
`Q Well, they have a "pixel calculation operation," but I'm
` just asking in the terms of vertex.
`A Oh, okay. That explains why I couldn't find it.
` "Vertex calculation operation," sure, that would,
` again, be an example of a vertex operation.
`Q But it would be different than a vertex manipulation
` operation?
`A It could also be an instance of a vertex manipulation
` operation.
`Q So how would you define the "vertex calculation
` operation"?
`A I would understand that a vertex calculation operation is
` an operation that does a calculation based on vertex
` data.
`Q Do you believe those three terms have a plain and
` ordinary meaning outside of the context of the '454
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` patent?
`A I haven't really considered it.
`Q Do they have a plain and ordinary meaning inside the
` context of the '454 patent?
`A I think a person of ordinary skill in the art certainly
` understands those terms without requiring a construction,
` so I think that means "yes," but I'll stick with that
` answer.
`Q Did you formulate an opinion as to what those terms meant
` when forming your opinions in your declaration?
`A Yes, I would say so, although not explicitly, as far as I
` recall.
`Q Okay. And you can turn, if you want to, to Page 22 of
` your declaration, which is Exhibit No. 2121.
`A Okay. I am there.
`Q On Page 22 of your declaration you have a subheading
` entitled, "Claim construction."
` Do you see that?
`A Yes, I do.
`Q And underneath "Claim construction" are two paragraphs
` numbered 53 and 54 that spill over to Page 23.
` Do you see that?
`
`Q Okay. If a term that's recited in a patent claim doesn't
` have a plain and ordinary meaning, and it was given no
` special definition in the patent, how would you go about
` construing that term?
`A Well, it's my understanding that a term in a patent
` claim-- the claim should be presumed to be valid, and the
` meaning of any term should be interpreted as it would be
` understood by a person of ordinary skill in the art at
` the time of invention, in the context-- in the whole
` intrinsic-- in the context of the entire intrinsic
`0
` evidence.
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`Q Okay. So if I had a term in a patent, let's say,
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` "widget," that has no plain and ordinary meaning in the
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` art, and it turns out that the patent didn't give a
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` special definition for "widget"-- do you understand that
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` assumption?
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`A I do.
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`Q Is it your opinion then that you would then just construe
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` the term "widget" in the context of the intrinsic record?
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`A That's my understanding, it should determine whether
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` there is-- given the entire context, whether there is a
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` reasonable understanding of what a widget would be.
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`Realtek Ex. 1019, Page 6
`Realtek Semiconductor Corp. v. ATI Technologies ULC
`IPR2023-00922
`
`

`

`Transcript of William Mangione-Smith, Ph.D.
`Conducted on May 10, 2024
`21
`
`6 (21 to 24)
`
`23
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` your declaration?
`A So my recollection is that likely in my first declaration
` the construction had not come out.
` I have voiced opinions regarding some of the art not
` being unified shaders.
` I don't recall for sure if those are all missing
` from 2121, but I understand that for purposes of the
` proceedings, that is the construction that now needs to
` be applied.
`Q Okay. So it sounds like at some point you did review the
` institution decision that was issued by the board; is
` that correct?
`A Yes, that's correct.
`Q Okay. So I want to turn to Page 28 of your declaration,
` Exhibit No. 2121.
`A Okay. I am there.
`Q On Page 28 there is a Section 8 with the title,
` "Conception."
` Do you see that?
`A Yes, I do.
`Q Just by way of paraphrasing, I think in this section you
` address what you are asserting as evidence of conception
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`Q And in that circumstance would that be considered the
` plain and ordinary meaning of that term?
` MR. DOKHANCHY: Objection; calls for a
` legal conclusion.
` THE WITNESS: Yeah, I don't really
` know.
`Q (By Mr. Johnson) Okay. Now, I noticed in your
` declaration, which is Exhibit No. 2121, that other than
` these two paragraphs, 53 and 54, there is no other
` specific claim construction section in your declaration.
` Is that correct?
`A I don't recall for sure, but it would not surprise me if
` that was the case.
`Q And so I take that to mean that you did not feel the need
` to specifically construe any particular term recited in
` any of the '454 patent claims, correct?
`A I think that's generally correct.
` In the past there have been instances where I've
` been asked to provide a construction where I didn't feel
` it was necessary, so it's not-- so I would say it's
` likely two-pronged: I wasn't asked, and I didn't, on my
` own, feel the need to provide a construction.
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` of the unified shader that's disclosed in the '454
`Q Do you recall whether or not you came to the conclusion
` patent, correct?
` that any recited term in any of the claims of the '454
`A Yes, throughout the remainder of this section of my
` patent had a special definition, as that term is
` report.
` understood by you in Paragraph No. 54 of your
`Q And your opinion, with respect to conception, is based on
` declaration?
` the documentation that you cite throughout this section,
`A So my recollection is that my opinion was and is that the
` related to something called the R400 project; is that
` term "unified shader" has a particular meaning to a
` correct?
` person of ordinary skill in the art.
`A I think that's broadly correct.
` However, my recollection is that the PTAB, I
` The documentation is certainly some of the
` believe, had offered up a construction, and so moving
`0
` engineering technical specifications, as well as some of
` forward I have endeavored to apply that construction.
`11
` the related but different types of documents,
`Q Okay. I am happy to give you a copy of the PTAB's
`12
` particularly that I mentioned I brought in today.
` decision, but I'm just going to read it and see if you--
`13
`Q So just to set the stage, I just want to-- I want you to
` if this sounds familiar to you.
`14
` tell me what is the R400 project.
` On Page 17 of the institution decision, the PTAB
`15
`A So my understanding was that the R400 was a development
` writes, "We construe the claimed unified 'shader' to mean
`16
` project at ATI to build a new graphics processor or
` a shader that is configured to perform both vertex and
`17
` "GPU," it's sometimes referred to for "graphics
` pixel operations."
`18
` processing unit," and they developed the design.
` Do you recall that?
`19
` I think I would assume that initially it was
`A Yes, I do.
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` anticipated to be sold fairly broadly.
`Q And is that the construction that you applied when
`21
` My understanding is that it was used in the
` reviewing the prior art and formulating your opinions in
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`Transcript of William Mangione-Smith, Ph.D.
`Conducted on May 10, 2024
`25
` Microsoft Xbox, but I don't know of use other than that.
`Q All right. And this GPU that you referred to included a
` unified shader, correct?
`A Yes, that's correct.
`Q As well as some other components to make out the overall
` GPU architecture, correct?
`A I would say that's correct.
` It's a little bit tricky in that as VLSI Technology
` has gotten denser and denser, other stuff on the system
` has gotten put on the chip, so whether-- I think the R400
` was considered the entire chip, but ATI might have
` considered that just the main part of the chip with other
` peripherals around the edge.
` So exactly what they would consider the boundary of
` the GPU, it certainly is the R400. It may have been
` other components as well.
`Q Okay. The '454 patent claims are directed to a unified
` shader, correct?
`A Yes, that's correct.
`Q So my only desire in my question was to just make sure
` that the GPU included a unified shader.
` That's all I was trying to get at.
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` You are basing your opinions on this AMD
` documentation in the 2001 timeframe, correct?
`A Yes, I think that's correct, although I don't recall if
` in some of the-- I'm basing it on the AMD documentation.
` I did my best to only consider documentation with
` regards to diligence.
` I don't-- let me take a step back and try to be a
` little clearer.
` I am not sure if it was restricted-- if my analysis
` was restricted to documentation in the 2001 timeframe.
` I think that certainly was the starting point.
`Q Let me refresh your recollection just a little bit and
` see if we can clear it up.
` I think you addressed two things in your report, and
` feel free to correct me. One is conception and the other
` is diligence.
` Do you recall that?
`A Yes.
`Q And I believe your opinions related to conception are
` that it was conceived of in the 2001 timeframe, but then
` there was diligence that lead up to the reduction in
` practice in the 2003 timeframe, correct?
`
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`A That is my recollection, yes.
`Q So it would not surprise me that you did look at some
` documents after 2001, at least with respect to diligence,
` but my question is:
` For conception, since you are asserting it in 2001,
` did you rely on documents in the 2001 timeframe?
`A Yes.
`Q Okay. Do you believe that documents beyond 2001 would
` show conception in 2001?
`A I guess it's possible if they included references or data
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` or cited data that was from 2001, but I'm not sure.
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`Q And the documents that you refer to in this sentence in
`12
` Paragraph No. 76, they all relate to the R400 project,
`13
` correct?
`14
`A I believe so.
`15
` I don't know why I would have cited anything not
`16
` related to the R400.
`17
`Q And do you recall whether or not there was a product in
`18
` the 2001 timeframe that was reflected in the R400
`19
` documentation?
`20
`A I don't recall for sure.
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` Some of the documentation referred to a product or
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`A Got it.
` The GPU in the R400 project included a unified
` shader.
`Q Okay. And it included some other things as well, but it
` absolutely included a unified shader, correct?
`A Yes, sir.
`Q Okay. And then starting on Page 30 of your report, there
` is a subsection entitled, "'454 patent," and for the next
` many pages you walk through each claim on an
` element-by-element basis and identify where you believe
` those elements are present or disclosed within the
` documentation you reviewed, correct?
`A Yes, I think that's a generally accurate assessment.
`Q And if we look at Paragraph No. 76 on Page 31 of Exhibit
` No. 2121, there is a statement in the second sentence
` that says, "The AMD documentation in the 2001 timeframe
` describes a unified shader performing the same steps as
` the unified shader of the '454 patent."
` Do you see that?
`A Yes, I do.
`Q So you repeat this sentence throughout your analysis in
` this conception section, and my question is:
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`Realtek Semiconductor Corp. v. ATI Technologies ULC
`IPR2023-00922
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`

`

`Transcript of William Mangione-Smith, Ph.D.
`Conducted on May 10, 2024
`29
` referred to a previous design, which I believe was turned
` into a product, but I don't recall for sure as I sit
` here.
` For example, my recollection is that there was an
` R300, an earlier design, and elements of the R400 early
` documentation talked about changes or advancements
` compared to earlier products and designs.
`Q It is not your opinion that the R300 is evidence of
` conception of the invention described in the '454 patent,
` correct?
`A I don't recall relying upon that.
` I am not sure that it could not have served such a
` purpose, but I don't think I used it for that purpose.
`Q Did you inspect any of the products that might have been
` available in the 2001 timeframe that were related to the
` documentation you reviewed?
`A Not that I recall in the process of my work for this
` matter.
`Q Have you ever seen any of the products from the 2001
` timeframe related to the R400 project?
`A Likely.
` I'm a computer nerd. I see lots of different kinds
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`A It depends.
` I do quite a bit, but different companies oftentimes
` have their own proprietary language for source code that
` is not available outside of the company.
`Q And have you heard the term "RTL code"?
`A Yes, I have.
`Q Can you tell me what that is?
`A "RTL" stands for "registered transfer language."
`Q And do you recall there was a reference to "RTL code"
` related to the R400 project?
`A I recall there being quite a bit of discussion of RTL.
` I recall reviewing RTL, as well as discussions of
` net list files, which are closely related.
`Q And was that RTL code, code that existed in the 2001
` timeframe that you reviewed?
`A I believe so, but I'm not sure.
`Q Do you recall whether or not there's, for lack of a
` better term, a schematic diagram of the overall layout or
` circuitry architecture for the GPU related to the R400?
`A I certainly recall a number of high-level schematics,
` block diagrams at different levels of abstraction.
`Q So, for example, on Page 31 there is a block diagram,
`
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` of products.
` I've had lots of different kinds of processors and
` GPUs from-- some of them from AMD, some of them from ATI,
` but I don't recall any particular one at this moment.
`Q So you have no specific memory of ever inspecting a
` product related to the R400 project that was available in
` the 2001 timeframe, correct?
`A Not that I recall as I sit here.
`Q Within the AMD documentation that you reference in your
` declaration, did that include any source code?
`A My recollection is that it did, but I'm not 100 percent
` certain where.
` My recollection could be wrong.
` It's a