`
`
`DIGITAL EVIDENCE GROUP
`
`1726 M Street NW, Suite 1010
`
`Washington, DC
`
`20036
`
`
`
`(202) 232-0646
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015
`
`LG v. ATI; IPR2015-00325
`LG Ex. 1015, pg 1
`
`AMD1044_0012036
`
`ATI Ex. 2005
`IPR2023-00922
`Page 1 of 84
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`Page 1
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARI
`
`
`
`LG ELECTRONICS,
`
`INC.,
`
`Petitioner,
`
`< tA
`
`S$
`
`$
`
`$
`
`A
`
`wa
`
`Case IPR2015-00325
`
`Case IPR2Z015-00326
`
`§ Case IPR2015-00330
`
`$ $
`
`ATI TECHNOLOGIES ULC,
`
`Patent Owner.
`S$
`$
`
`**k* CONFIDENTIAL BUSINESS INFORMATION ***
`
`*** SUBJECT TO THE PROTECTIVE ORDER ***
`
`
`VIDEOTAPED DEPOSITION OF CALVIN H. WATSON
`
`Austin, Texas
`
`November 4, 2015
`
`8:58 a.m.
`
`Reported by: Micheal A. Johnson, RMR, CRR, CCR
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 1 of 84
`
`
`
`11/4/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Calvin H. Watson
`Confidential Business Information - Subject to Protective Order
`
`
`VIDEOTAPED ORAL DEPOSITION OF CALVIN H.
`
`WATSON, produced at the instance of the Petitioner,
`
`in the above-styled and numbered cause on the 4th
`
`Page 2
`
`day of November, 2015, at 8:58 a.m., before Micheal
`
`A. Johnson, RMR, CRR, Notary Public in and for the
`
`State of Texas,
`
`reported by realtime stenographic
`
`means, at the offices of Advanced Micro Devices,
`
`7171 Southwest Parkway, Building 100, Austin, Texas.
`
`i
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`2
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`20
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`21
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 2
`
`AMD1044_0012037
`
`ATI Ex. 2005
`IPR2023-00922
`Page 2 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 2 of 84
`
`
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`APPEARANCES
`
`ON BEHALF OF THE PETITIONER
`
`LG ELECTRONICS,
`
`INC.:
`
`Bryan Nese
`
`MAYER BROWN LUiP
`
`1999 K Street, N.W.
`Washington, D.C. 20006-1101
`(202) 263-3266
`bnesefmayerbrown.com
`
`
`Page 3
`
`i
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`2
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`Gl
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`4
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`Cn
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`6
`
`8
`ce]
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`ic
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`il
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`12
`
`is
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`i4
`
`is
`16
`
`17
`
`18
`
`is
`
`20
`21
`
`BS BS
`
`
`
`ON BEHALF OF THE PATENT OWNER
`
`ATI TECHNOLOGIES ULC:
`
`
`
`Jonathan Tuminaro, Ph.D.
`STERNE KESSLER GOLDSTEIN FOX
`
`7100 New York Avenue, NW
`Washington, D.c. 20005
`(202) 371-2600
`jtuminar@skgf.com
`
`Aaron R. Fahrenkrog
`ROBINS KAPLAN LLP
`
`800 LaSalle Avenue, Suite 2800
`Minneapolis, Minnesota 55402
`(612) 349-8500
`afahrenkrog@robinskaplan.com
`
`ON BEHALF OF THE WITNESS:
`
`Robert Rodriguez
`AMD AUSTIN
`
`7171 Southwest Parkway
`Austin, Texas 78735
`(512) 602-0413
`robert.rodriguez@amd.com
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 3
`
`AMD1044_0012038
`
`ATI Ex. 2005
`IPR2023-00922
`Page 3 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 3 of 84
`
`
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`i
`
`APPEARANCES (Cont. )
`
`
`Page 4
`
`VIDEOGRAPHER:
`
`Jason Lemley
`
`
`ALSO PRESENT:
`
`Pamela R. Horn, AMD Paraiegal
`
`2
`
`w
`
`cn
`
`
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 4
`
`AMD1044_0012039
`
`ATI Ex. 2005
`IPR2023-00922
`Page 4 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 4 of 84
`
`
`
`1
`
`2
`w
`
`on
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`oo
`
`16
`
`APPEARANCES
`
`
`PROCEEDINGS
`
`EXAMINATION OF CALVIN H. WATSON:
`
`BY MR. NESE
`
`REPORTER'S CERTIFICATION
`
`81
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`Page 5
`
`INDEX
`
`CALVIN H. WATSON
`
`November 4, 2015
`
`
`
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 5
`
`AMD1044_0012040
`
`ATI Ex. 2005
`IPR2023-00922
`Page 5 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 5 of 84
`
`
`
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`
`Calvin H. Watson
`
`Page 6
`
`DEPOSITION EXHIBITS
`
`CALVIN H. WATSON
`
`
`
`
`
`
`November 4, 2015
`
`NUMBER
`
`DESCRIPTION
`
`MARKED
`
`Exhibit
`
`1
`
`Case IPR2015-00325 Patent
`
`17
`
`7,742,053 Declaration of
`
`Calvin Watson
`
`Exhibit
`
`2
`
`Case IPR2015-00326 Patent
`
`6,897,871 Declaration of
`
`Calvin Watson
`
`Exhibit
`
`3
`
`Case TPR2015-00330 Patent
`
`7,327,369 Declaration of
`
`Calvin Watson
`
`Gl
`
`LO
`
`
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 6
`
`AMD1044_0012041
`
`ATI Ex. 2005
`IPR2023-00922
`Page6 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 6 of 84
`
`
`
`
`
`
`
`
`themselves for the record.
`
`
`
`
`
`MR. NESE: Good morning. This is
`
`Bryan Nese for petitioner LG Electronics,
`
`Inc.
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`PROCEEDINGS
`
`Page 7
`
`THE VIDEOGRAPHER: This is the video
`
`deposition of Calvin Watson taken by counsel for the
`
`plaintiff in the matter of LG Electronics,
`
`Inc.
`
`versus ATI Technologies. This is in the United
`
`States Patent and Trademark Office, Case Number
`
`TPR2005-00325,
`
`IPR2015 -- excuse me, 2015 on both of
`
`those -- IPR2015-00326 and IPR2015-00330.
`
`This deposition is being held at
`
`7171 Southwest Parkway, Austin, Texas, on
`
`November 4th, 2015.
`
`The time on the video is 8:58.
`
`1
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`2
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`4
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`6
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`7
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`8
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`ice]
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`10
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`ii
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`My name is Jason Lemley.
`
`I'm the
`
`
`legal videographer with Digital Evidence Group.
`
`The
`
`
`court reporter is Micheal
`
`Johnson in association
`
`with Digital Evidence Group.
`
`Would counsel please introduce
`
`12
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`is
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`Ze
`
`MR. TUMINARO:
`
`Jonathan Tuminaro
`
`
`from the law firm of Sterne Kessler Goldstein & Fox
`
`on behalf of the patent owner and the witness.
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 7
`
`AMD1044_0012042
`
`ATI Ex. 2005
`IPR2023-00922
`Page 7 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 7 of 84
`
`
`
`11/4/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Calvin H. Watson
`Confidential Business Information - Subject to Protective Order
`
`
`MR. FAHRENKROG: Aaron Fahrenxrog
`
`Page 8
`
`from the law firm Robins Kaplan LLP on behalf of ATI
`
`Technologies.
`
`THE VIDEOGRAPHER: Will the court
`
`reporter please swear in the witness.
`
`CALVIN H. WATSON
`
`having been first duly sworn,
`
`testified as follows:
`
`
`
`EXAMTNATTON
`
`BY MR. NESE:
`
`QO.
`
`A.
`
`Q.
`
`Good morning, sir.
`
`Hi.
`
`Would you please state your name and
`
`spell it for the record.
`
`A.
`
`is
`
`Calvin H. Watson, Calvin Hugh Watson,
`
`iG C-a-l-v-i-n H-u-g-h W-a-t-s-o-n.
`
`
`
`
`1
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`2
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`i?
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`i8
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`is
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`260
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`21
`
`Ze
`
`©.
`
`Okay. Mr. Watson, have you ever had
`
`
`your deposition taken before?
`
`A.
`
`QO.
`
`No.
`
`Okay.
`
`It's typically not on everyone's
`
`top five list of favorite things,
`
`
`so if it's okay
`
`with you, I'll go through just a little bit of what
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 8
`
`AMD1044_0012043
`
`ATI Ex. 2005
`IPR2023-00922
`Page8 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 8 of 84
`
`
`
`
`
`
`
`
`i?
`
`i8
`
`is
`
`260
`
`2i
`
`Oe
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`Page 9
`
`to expect,
`
`I'm sure your attorney had told you a
`
`little bit, but just so we're clear on what's going
`
`to happen today.
`
`Is that okay?
`
`A.
`
`QO.
`
`Please.
`
`Thank you.
`
`Okay.
`
`You got it.
`
`So I try to take
`
`breaks about every hour.
`
`If you need a break sooner
`
`than that,
`
`just let me know.
`
`Is that okay?
`
`A,
`
`Q.
`
`Yes.
`
`The only thing I would ask,
`
`though,
`
`if
`
`T've got a question pending,
`
`I would ask you to just
`
`finish your answer before we go on break.
`
`i
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`iG
`
`A.
`
`Q.
`
`A,
`
`Q.
`
`Yes.
`
`Okay?
`
`Okay.
`
`T'm going to be asking you questions,
`
`you're going to be answering them. Your
`
`lawyer may
`
`from time to time have objections. Okay. However,
`
`even if he objects, unless he specifically instructs
`
`you not
`
`to answer a question, you still need to
`
`answer the question.
`
`Is that okay?
`
`A.
`
`Q.
`
`Yes.
`
`Okay. We have a court reporter here,
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 9
`
`AMD1044_0012044
`
`ATI Ex. 2005
`IPR2023-00922
`Page 9 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 9 of 84
`
`
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`i Mr. Johnson, as you can see. He's going to be
`
`2 writing down everything I'm saying, everything
`
`Page 10
`
`3
`
`4
`
`S
`
`6
`
`7
`
`8
`
`you're saying.
`
`So to help make his Job easy,
`
`we
`
`need to have verbal responses to questions.
`
`Can you
`
`do that for me?
`
`A.
`
`QO.
`
`Yes.
`
`Great. And also going along with that,
`
`let's try not to talk over each other.
`
`It maxes
`
`S Mr. Johnson's job a bit more difficult.
`
`So let's do
`
`io
`
`il
`
`12
`
`is
`
`i4
`
`is
`
`
`
`
`
`
`him a favor there.
`
`Sound good?
`
`A,
`
`Q.
`
`Yes.
`
`Okay. Wonderful.
`
`The patent board has
`
`a rule that prohibits witnesses from conferring with
`
`their lawyers in the breaks while you're still on
`
`the record in this deposition. Will you abide by
`
`that rule today?
`
`A,
`
`QO.
`
`Yes.
`
`Okay.
`
`Thank you. Sir, what did you do
`
`to prepare for today's deposition?
`
`i6
`
`i?
`
`i8
`
`is
`
`260
`
`2i
`
`Ze
`
`A.
`
`Spoke with Jonathan and Aaron yesterday,
`
`and I reviewed my declaration which I previously
`
`Signed and I reviewed some of the exhibits.
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 10
`
`AMD1044_0012045
`
`ATI Ex. 2005
`IPR2023-00922
`Page 10 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 10 of 84
`
`
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`1
`
`2
`
`3
`
`4
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`S
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`6
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`7
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`3
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`Ls
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`i4
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`
`is
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`
`
`
`
`
`Q.
`
`Okay. Which exhibits did you review; do
`
`Page il
`
`you recall?
`
`A.
`
`Q.
`
`A.
`
`QO.
`
`A.
`
`No.
`
`Okay. Did you review all of them?
`
`No.
`
`Okay.
`
`I checked some of the metadata of the
`
`actual exhibits, Just spot-checking.
`
`Q.
`
`Okay. And about how long did you meet
`
`with your lawyers yesterday?
`
`A,
`
`Q.
`
`employed?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`About five hours.
`
`Okay. Mr. Watson, are you currently
`
`Yes.
`
`Whe is your current employer?
`
`Advanced Micro Devices.
`
`And how long have you worked for
`
`Advanced Micro Devices?
`
`A.
`
`Started as a co-op in 1996 and as a
`
`full-time employee in 1997.
`
`Q.
`
`A,
`
`So co-op iS Similar to an intern?
`
`Correct, yes.
`
`1s
`
`26
`
`2i
`
`22
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 11
`
`AMD1044_0012046
`
`ATI Ex. 2005
`IPR2023-00922
`Page 11 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 11 of 84
`
`
`
`
`
`
`i6
`
`i?
`
`i8
`
`is
`
`26
`
`21
`
`Oe
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`i
`
`2
`
`3
`
`4
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`S
`
`6
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`7
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`is
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`i4
`
`is
`
`
`
`Q.
`
`Okay. And what's your current position
`
`Page 12
`
`at AMD?
`
`A.
`
`I'm a senior member of the technical
`
`staff.
`
`So it's a technical position, engineer in
`
`the law department.
`
`Q.
`
`Okay. And what are your current
`
`responsibilities as a senior member of the technical
`
`staff?
`
`A,
`
`My responsibilities today in the law
`
`department focus around patents.
`
`I'm also a patent
`
`agent,
`
`a registered US patent agent.
`
`So I do patent
`
`prosecution, mostly reviewing the work of outside
`
`counsel, draft applications and office actions.
`
`I
`
`also host patent committees. Right now just one of
`
`them, but from time to time T'll host multiple
`
`committees. We meet to review invention
`
`submissions, and we reject or allow or approve
`
`patent filings and I assign them to outside counsel.
`
`There's -- I'm not
`
`the only one who does that.
`
`I do some patent licensing work,
`
`
`both offensively and defensively.
`
`I support
`
`Litigation as needed on a technical basis.
`
`Amd I am
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 12
`
`AMD1044_0012047
`
`ATI Ex. 2005
`IPR2023-00922
`Page 12 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 12 of 84
`
`
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`Page 13
`
`quite involved in the patent portfolio of the
`
`database.
`
`I'm an administrator for the patent
`
`database.
`
`Those would be my current duties in
`
`the law department, which is since -- 2008 when I
`
`left design engineering to come to the law
`
`department.
`
`Q.
`
`And what percentage,
`
`roughly, would you
`
`
`
`
`i
`
`2
`
`3
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`4
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`S
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`
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`
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`
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`
`260
`
`21
`
`Oe
`
`say your work is on the patent prosecution side of
`
`things, we'll call it?
`
`
`
`A.
`
`30 percent.
`
`If you include patent
`
`committees, 35 percent.
`
`Q.
`
`Okay. And what percentage would you say
`
`roughly is involved with Litigation support?
`
`A.
`
`Q.
`
`10 percent.
`
`So let's see if my mental math works
`
`here. What would you characterize the other
`
`60 percent as?
`
`A,
`
`QO.
`
`A.
`
`Licensing.
`
`Okay.
`
`Let's say 50 percent licensing, another
`
`10 percent Just the portfolio.
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 13
`
`AMD1044_0012048
`
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`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
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`i
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`
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`Q.
`
`So you said you began working for AMD in
`
`Page i4
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`1996;
`
`is that right?
`
`A.
`
`Q.
`
`Correct.
`
`And then you came on full time in 1997.
`
`And you were a design engineer when you first came
`
`on to AMD.
`
`A.
`
`Correct. Yeah.
`
`I began as a -- an RTL
`
`designer, CGigital design. And I've done many types
`
`of Gesigns since then, ending up as an analog
`
`circuit designer.
`
`QO.
`
`A,
`
`Q.
`
`AMD?
`
`Okay.
`
`But always as a design engineer.
`
`Were you working anywhere else before
`
`A.
`
`Not -- not with -- after graduating from
`
`college, no -- yes, but otner jobs during and before
`
`college, yes.
`
`QO.
`
`I'm sorry,
`
`I should have been more
`
`clear. As an engineer, have you worked anywnere
`
`else other than AMD?
`
`A.
`
`Q.
`
`IT have not.
`
`Okay. And you mentioned college. Where
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 14
`
`AMD1044_0012049
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`ATI Ex. 2005
`IPR2023-00922
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`ATI Ex. 2005
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`IPR2023-00922
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`11/4/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Calvin H. Watson
`Confidential Business Information - Subject to Protective Order
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`did you attend college?
`
`Page i5
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`A.
`
`Q.
`
`there?
`
`A.
`
`QO.
`
`A.
`
`Q.
`
`A,
`
`The University of Texas at San Antonio.
`
`Okay. And what degree did you receive
`
`Electrical engineer.
`
`Was that a bachelor's?
`
`Correct.
`
`Do you hold any other degrees?
`
`An associate degree in electronics, but
`
`T don't put that on my resume.
`
`QO.
`
`A,
`
`Okay.
`
`<Any other degrees that you have?
`
`No. Patent agent would be my only other
`
`related certification.
`
`QO.
`
`Mr. Watson, when did you first hear
`
`about this proceeding?
`
`A.
`
`Q.
`
`Maybe three months ago. Maybe less.
`
`And without getting into the substance
`
`maybe of what was said to you, how did you first
`
`hear about this proceeding? Let's start with who
`
`told you?
`
`A,
`
`I
`
`--~ might have been Pam Horn or Chris
`
`Jacoos, maybe Robert.
`
`I'm not sure.
`
`Someone said
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 15
`
`AMD1044_0012050
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`ATI Ex. 2005
`IPR2023-00922
`Page 15 of 84
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`IPR2023-00922
`Page 15 of 84
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`
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`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`Page 16
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`that -- because of the --
`
`MR. TUMINARO: Don't disclose the
`
`substance of what was --
`
`THE WITNESS: Right. Yeah.
`
`BY MR. NESE:
`
`Q.
`
`So Pam Horn you think first told you
`
`about this case?
`
`A,
`
`Q.
`
`A.
`
`department.
`
`I believe it was Pam Horn, yeah.
`
`Okay. And what is Pam Horn's position?
`
`She's a paralegal
`
`in the AMD law
`
`Q.
`
`Sir, you submitted a few declarations in
`
`this case, correct?
`
`A,
`
`Q.
`
`A.
`
`Q.
`
`Yes.
`
`And three of them to be precise, right?
`
`Correct.
`
`Okay.
`
`I've premarked as Exhibits 1,
`
`2
`
`and 3 your three declarations that you've given in
`
`these proceedings and just so the record's straight,
`
`is
`
`iG
`
`17
`
`is
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`is
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`26
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`I believe for the 325 proceeding the exhibit is
`
`21 ATI's Exhibit 2105, and that's Exhibit
`
`1 to this
`
`Ze
`
`deposition.
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 16
`
`AMD1044_0012051
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`ATI Ex. 2005
`IPR2023-00922
`Page 16 of 84
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`ATI Ex. 2005
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`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`1
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`
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`(Deposition Exhibit
`1 marked.)
`
`Page 17
`
`BY MR. NESE:
`
`Q.
`
`And for the 326 proceeding, it's ATI
`
`Exhibit 2005, and that's going to be Exhibit
`
`2
`
`to
`
`this deposition.
`
`BY MR. NESE:
`
`
`(Deposition Exhibit 2 marked.)
`
`QO.
`
`And finally, for the 330 proceedina,
`
`it's ATT Exhibit 2005 and we'll mark that as
`
`Exhibit
`
`3 to this deposition.
`
`(Deposition Exhibit 3 marked.)
`
`MR. NESE: And, Counsel,
`
`IT have
`
`copies for at least a couple of you.
`
`BY MR. NESE:
`
`Q.
`
`Mr. Watson, can you look those over and
`
`confirm that those are indeed the declarations that
`
`you submitted in this -- in these proceedings.
`
`(Witness Reviews Document.)
`
`A,
`
`Yes,
`
`they are.
`
`is
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`20
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`BY MR. NESE:
`
`2i
`
`22
`
`Q.
`
`Okay. Did you write --
`
`MR. TUMINARO: Bryan, I'll just note
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 17
`
`AMD1044_0012052
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`ATI Ex. 2005
`IPR2023-00922
`Page 17 of 84
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`ATI Ex. 2005
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`IPR2023-00922
`Page 17 of 84
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`
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
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`for the record these copies are black and white anc
`
`Page 18
`
`they were produced in color.
`
`MR. NESE: Okay.
`
`Thank you.
`
`BY MR. NESE:
`
`QO.
`
`Apart from that,
`
`these are accurate
`
`
`copies of your declarations, correct?
`
`A.
`
`QO.
`
`They appear to be, yes.
`
`Okay. Did you write each of these
`
`declarations?
`
`A.
`
`I did not.
`
`I reviewed them thoroughly.
`
`I did not author the words -- I made edits, but
`
`I
`
`didn't write them by myself.
`
`Q.
`
`So what sort of edits did you make to
`
`these declarations?
`
`MR. TUMINARO: Objection,
`
`form.
`
`A.
`
`I probably made some corrections --
`
`typographical corrections, corrections to dates.
`
`I
`
`added many screen shots.
`
`I perhaps corrected paths
`
`to files or file names.
`
`I made a lot of corrections
`
`is
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`21
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`Ze
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`and additions.
`
`
`BY MR. NESE:
`
`Q.
`
`Okay. But you didn't write a first
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 18
`
`AMD1044_0012053
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`ATI Ex. 2005
`IPR2023-00922
`Page 18 of 84
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`ATI Ex. 2005
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`IPR2023-00922
`Page 18 of 84
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`11/4/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Calvin H. Watson
`Confidential Business Information - Subject to Protective Order
`
`
`Page 19
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`draft of any of these,
`
`rignt?
`
`A,
`
`QO.
`
`That's correct.
`
`And let's look at Exhibit 1. And on
`
`pages 2
`
`through 6 of Exhibit 1,
`
`there are a whole
`
`bunch of exhibits that were submitted in these
`
`proceedings.
`
`Do you see that?
`
`MR. TUMINARO: Objection,
`
`form.
`
`A.
`
`What page?
`
`BY MR. NESE:
`
`Q.
`
`A,
`
`Q.
`
`Pages 2
`
`through ¢ of Exhibit 1.
`
`Yes.
`
`Okay.
`
`So apart from these exhibits on
`
`pages 2
`
`through 6, did you review any motes or other
`
`documents in the course of your -- editing your
`
`declarations?
`
`MR. TUMINARO: Objection to form.
`
`A.
`
`Can you repeat the question?
`
`
`
`
`BY MR. NESE:
`
`Q.
`
`Sure.
`
`
`
`
`
`
`16
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`i?
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`is
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`Ze
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`MR. NES#H: Mr. Johnson, would you
`
`read it back, please.
`
`(Question Read Back.)
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 19
`
`AMD1044_0012054
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`ATI Ex. 2005
`IPR2023-00922
`Page 19 of 84
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`ATI Ex. 2005
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`IPR2023-00922
`Page 19 of 84
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`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`i
`
`2
`
`Ww
`
`A.
`
`Did I review?
`
`I'm not sure. During the
`
`gathering of these documents,
`
`I likely -- I don't
`
`know, but
`
`I likely looked at other documents as
`
`Page 20
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`4 well.
`
`cn
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`6
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`7
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`8
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`S
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`10
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`11
`
`BY MR. NESE:
`
`Q.
`
`Okay. What sort of other documents did
`
`you likely look at?
`
`A.
`
`Well, Perforce is a database of many
`
`documents and I -- I don't recall.
`
`I'm just saying
`
`the answer is,
`
`I may have opened other documents.
`
`I
`
`don't recall.
`
`Q.
`
`T see. Mr. Watson, are there any errors
`
`in your declarations? Anything you'd like to
`
`correct?
`
`A.
`
`Q.
`
`Not that I know of.
`
`And, sir, other than the cover page ano
`
`some of the dates and a reference to the patents,
`
`are you aware of any substantive differences among
`
`your three declarations?
`
`
`
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`12
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`22
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`MR. TUMINARO: Objection,
`
`form.
`
`A.
`
`No,
`
`I think some of the exhibit numbers
`
`are different,
`
`some of the documents are different,
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 20
`
`AMD1044_0012055
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`ATI Ex. 2005
`IPR2023-00922
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`11/4/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Calvin H. Watson
`Confidential Business Information - Subject to Protective Order
`
`
`Page 21
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`
`
`but they're very similar.
`
`BY MR. NESE:
`
`Q.
`
`Okay. Let's talk about your time at
`
`AMD. When you first joined as an engineer, and
`
`let's go to 1997, what were your responsibilities
`
`when you first started at AMD?
`
`A.
`
`I was in the embedded processor group,
`
`which is like a system on a chip. And my block was
`
`called the SSI block, and I wrote the RTL for it and
`
`verified it, synthesized it and owned it all the way
`
`to tape-out. That's the first project I worked on.
`
`Q.
`
`And you said that you joined the law
`
`department,
`
`I think you called it,
`
`in 2008.
`
`A,
`
`Q.
`
`Correct.
`
`And what was the nature of your work up
`
`until 2008 for AMD?
`
`A,
`
`I -- the last project
`
`I worked on was
`
`a -- an APU, which combines a CPU and a GPU, and I
`
`owned the voltage regulator and band gap blocks ana
`
`I designed those at a transistor level.
`
`So that was
`
`clrcuit design. And IT can tell you what
`
`I did in
`
`between if you'd like.
`
`is
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`26
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`Ze
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`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 21
`
`AMD1044_0012056
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`ATI Ex. 2005
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`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
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`Page 22
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`Q.
`
`A.
`
`Just briefly would be great.
`
`Thank you.
`
`Okay. Well, starting as a digital
`
`designer writing Verilog,
`
`I think it's relevant to
`
`note that part of that process is checking files in
`
`and out of a revision control tool similar to
`
`Perforce.
`
`So T'ive learned and had experience with
`
`revision control tools almost on a daily basis
`
`from -- since the beginning of my career as an
`
`engineer. And from RTL design went to
`
`implementation, which is synthesizing RTL code into
`
`gates, and then place and route, where you place the
`
`gates.
`
`Then I focused more on circuit design at the
`
`
`transistor level,
`I/O pads and then analog design.
`
`QO.
`
`And you mentioned a revision control
`
`tool.
`
`A.
`
`Q.
`
`Right.
`
`What was AMD's revision control tool
`
`when you Joined in 1997?
`
`A.
`
`Q.
`
`tool today?
`
`I believe it was called RCS.
`
`Is that still their revision control
`
`A.
`
`I don't think so.
`
`T'm not sure.
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 22
`
`AMD1044_0012057
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`IPR2023-00922
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`ATI Ex. 2005
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`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
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`MR. TUMINARO: Bryan,
`
`I just -- at
`
`
`this time I would like to designate this transcript
`
`Page 23
`
`under the protective order.
`
`MR. NESE:
`
`Sure.
`
`BY MR. NESE:
`
`Q.
`
`So, Mr. Watson, what is your
`
`understanding of the relationship between AMD and
`
`ATI Technologies?
`
`A.
`
`We --
`
`MR. TUMINARO: Objection, outside
`
`the scope.
`
`BY MR. NESE:
`
`Q.
`
`A.
`
`You can answer.
`
`We merged -- tne two companies merged in
`
`2006.
`
`AMD -- the relationship today or pricr to
`
`2006?
`
`‘or
`
`I think that's fine.
`
`Thank you. And
`
`were you -~ you were working at AMD when it merged
`
`with ATI, correct?
`
`17
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`is
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`18
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`26
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`21
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`22
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`A.
`
`Q.
`
`A.
`
`Yes.
`
`You said that was 2006, correct?
`
`I believe that's when the merger, around
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 23
`
`AMD1044_0012058
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`ATI Ex. 2005
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`
`
`
`
`
`Q.
`
`Okay. And how do you know about ATI's
`
`policies for maintaining documents?
`
`A.
`
`The specific policies like, you know,
`
`retention policy, if that's what you're referring
`
`to,
`
`I'm not familiar with those policies.
`
`But
`
`I do
`
`know that I have personally reviewed and seen -- or
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`Page 24
`
`that time, happened.
`
`QO.
`
`SO prior to the merger in 2006, you've
`
`never worked for ATI, have you?
`
`A.
`
`I've not worked for the company ATI.
`
`Although the companies have ~- do very similar work
`
`with processors.
`
`QO.
`
`Do you know what ATI's policies were for
`
`i
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`2
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`3
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`4
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`5
`
`6
`
`7
`
`8 maintaining documents?
`
`8
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`io
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`il
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`A.
`
`IT think I do. Their -- well,
`
`their
`
`database was a tool called Perforce,
`
`their revision
`
`control tool.
`
`It's a brand for a type of tool
`
`that's very common in the industry.
`
`I would say
`
`required.
`
`12
`
`is
`
`i4
`
`is
`
`iG
`
`i?
`
`is
`
`is
`
`26
`
`21
`
`Ze
`
`viewed and checked out files from at least as far
`
`back as 2001. And I'm -- they still use -- AMD uses
`
`the Perforce tool today.
`
`So in that respect
`
`I
`
`think
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 24
`
`AMD1044_0012059
`
`ATI Ex. 2005
`IPR2023-00922
`Page 24 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 24 of 84
`
`
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`T'm familiar with that policy.
`
`Q.
`
`Okay. And how did you come to be
`
`familiar with that policy?
`
`Page 25
`
`
`
`A,
`
`I -- part of my job in the law
`
`department is supporting Litigation. And so it's
`
`not uncommon for me to -- since 2008,
`
`to use
`
`Perforce to provide files to the litigation team.
`
`And there may be other situations when I used
`
`Perforce.
`
`I don't recall.
`
`Q.
`
`Do you know whether AMD was using
`
`Perforce prior to its merger with ATI
`
`in 2006?
`
`A.
`
`T don't know.
`
`I do know that AMD and
`
`1
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`2
`
`3
`
`4
`
`S
`
`6
`
`7
`
`8
`
`3
`
`io
`
`il
`
`12
`
`
`
`
`
`
`is myself, we have always used a revision control tool.
`
`14
`
`is
`
`16
`
`17
`
`i8
`
`is
`
`
`They all work very similarly. There's -- required
`
`for the -- for the same reasons.
`
`The brand name of
`
`the revision control tool, whether it was Perforce
`
`I don't know.
`
`
`
`But you haven't always used Perforce,
`
`oer not,
`
`Q.
`
`right?
`
`20
`
`2i
`
`Oe
`
`MR. TUMINARO: Objection,
`
`form.
`
`A.
`
`IT have used other revision control tools
`
`prior to using Perforce, yes.
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 25
`
`AMD1044_0012060
`
`ATI Ex. 2005
`IPR2023-00922
`Page 25 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 25 of 84
`
`
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`Page 26
`
`1
`
`2
`
`3
`
`4
`
`S
`
`BY MR. NESE:
`
`Q.
`
`And AMD hasn't always used Perforce,
`
`cight?
`
`A.
`
`I don't know whether other people in AMD
`
`used Perforce prior to 2006.
`
`I've used other tools
`
`6 myself before that.
`
`7
`
`8
`
`3
`
`io
`
`11
`
`QO.
`
`So in your time at AMD between 1997 and
`
`2006, did you ever use Perforce?
`
`A.
`
`IT believe the answer's no.
`
`I may have,
`
`but
`
`I -- I
`
`think the answer's no.
`
`QO.
`
`Mr. Watson, do you know about any of
`
`12
`
`is
`
`i4
`
`is
`
`
`
`
`
`
`ATI's business practices?
`
`MR. TUMINARO: Objection,
`
`form,
`
`outside the scope.
`
`A.
`
`Yes. My declaration says that I do,
`
`yes.
`
`BY MR. NESE:
`
`Q.
`
`Okay.
`
`How do you know about ATI's
`
`business practices?
`
`i6
`
`17
`
`is
`
`is
`
`260
`
`21
`
`Ze
`
`A.
`
`I have worked -- the two companies are
`
`very Similar.
`
`One designs one type of processor.
`
`
`ATI did prior to 2006.
`
`AMD designed a processor
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 26
`
`AMD1044_0012061
`
`ATI Ex. 2005
`IPR2023-00922
`Page 26 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 26 of 84
`
`
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`prior to 2006. And beginning in 2006 I -- you know,
`
`Page 27
`
`
`
`
`Ww
`
`cn
`
`
`
`26
`
`21
`
`very soon after,
`
`the companies merged -- I'm not
`
`sure exactly when, but
`
`I began working on an APU
`
`product, which is an accelerator processor which
`
`is -- combines the -- a GPU, graphics processor
`
`design with a CPU, and our teams -- design teams
`
`merged. Our tools would've -- we interacted with
`
`each other. We worked together.
`
`So from a technical perspective TI
`
`believe I'm familiar with ATI's practices at the --
`
`at and before -- well, at least at the time of the
`
`merger,
`
`their practices were very Similar to AMD's
`
`own practices.
`
`QO.
`
`Okay. What about
`
`the time before the
`
`merger?
`
`Do you know what ATI's practices were like
`
`then?
`
`A.
`
`I can see a historical
`
`record of their
`
`files in their revision control tool that they used
`
`prior to 2006. And it's -- based on my experience,
`
`it's -- it's consistent with my own experiences as a
`
`design or business process.
`
`It would be -- it's
`
`consistent with what
`
`I was familiar with already and
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 27
`
`AMD1044_0012062
`
`ATI Ex. 2005
`IPR2023-00922
`Page 27 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 27 of 84
`
`
`
`
`
`
`12
`
`i4
`
`is
`
`iG
`
` is
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`Page 28
`
`i
`
`2
`
`3
`
`4
`
`cn
`
`6
`
`7
`
`8
`
`ice]
`
`io
`
`il
`
`what
`
`I would expect to see:
`
`The files,
`
`the types of
`
`files,
`
`the method of retaining files and time
`
`stamping files, revision control.
`
`QO.
`
`So apart from looking at the way that
`
`ATI had maintained their files and their revision
`
`control system, Perforce,
`
`is there anything else you
`
`can say about ATI's business practices prior to
`
`2006?
`
`MR. TUMINARO: Objection,
`
`form.
`
`A.
`
`Besides they're a graphics processor
`
`company that designs graphics processors,
`
`so I don't
`
`have that much more to add.
`
`BY MR. NESE:
`
`QO.
`
`Do you have anything more to add?
`
`MR. TUMINARO: Objection,
`
`form,
`
`asked and answered.
`
`A,
`
`No.
`
`
`
`
`
`MR. NESE: Would you mind if we go
`
`off the record just for five minutes to try to get
`
`the LiveNote worked out.
`
`MR. TUMINARO:
`
`Sure.
`
`Take a break.
`
`THE VIDEOGRAPHER: Going off the
`
`i?
`
`i8
`
`is
`
`20
`
`21
`
`22
`
`www. DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1015, pg 28
`
`AMD1044_0012063
`
`ATI Ex. 2005
`IPR2023-00922
`Page 28 of 84
`
`ATI Ex. 2005
`
`IPR2023-00922
`Page 28 of 84
`
`
`
`Calvin H. Watson
`LG Electronics, Inc. v. ATI Technologies ULC
`11/4/2015
`Confidential Business Information - Subject to Protective Order
`
`i
`
`2
`
`3
`
`4
`
`S
`
`6
`
`7
`
`8
`
`ice]
`
`io
`
`il
`
`12
`
`is
`
`i4
`
`is
`
`record.
`
`Time is 9:29,
`
`Page 29
`
`(Recess Taken From 9:29 a.m. To 9:37
`
`a.m.)
`
`THE VIDEOGRAPHER: Back on tne
`
`record.
`
`Time is 9:37.
`
`BY MR. NESE:
`
`QO.
`
`Okay. Welcome back, Mr. Watson.
`
`Do you
`
`know what happened to ATI's cocuments when it merged
`
`with AMD?
`
`MR. TUMINARO: Objection,
`
`form.
`
`A,
`
`The technical documents, my
`
`understanding is that they were unchanged,
`
`that --
`
`it's my understanding that they existed in the
`
`Perforce,
`
`they stayed there,
`
`they still exist there
`
`today, and I don't know of anything, other than
`
`being maintained as is,
`
`that
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