`
`
`Reported by Michelle D. Knowles, CSR, RPR, CRR, CCRR
`
`
`DIGITAL EVIDENCE GROUP
`
`1726 M Street NW, Suite 1010
`
`Washington, D.C. 20036
`
`(202) 232-0646
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`LG Ex. 1020
`
`LG v. ATI
`
`202-232-0646
`
`IPR2015-00325
`
`LG Ex. 1020, pg 1
`
`AMD1044_0012400
`
`ATI Ex. 2006
`IPR2023-00922
`Page 1 of 59
`
`Andrew Wolfe
`LG Electronics, Inc. v. ATI Technologies ULC
`11/10/2015
`Confidential - Pursuant to Protective Order
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`Page 281
`
`LG ELECTRONICS,
`
`INC.,
`
`} Case IPR2015-00325
`
`Patent 7,742,053 B2
`
`Case TPR2015-00326
`
`Patent 6,897,871
`
`)
`
`} )
`
`)}
`
`Petitioner,
`
`Vv.
`
`ATI TECHNOLOGIES ULC,
`
`} Case IPR2015-00330
`
`Patent Owner.
`
`
`
`Patent 7,327,369 B2
`
`)}
`
`}
`
`***CONFIDENTTAL PURSUANT TO PROTECTIVE ORDER***
`
`
`
`VIDEOTAPED DEPOSITION OF ANDREW WOLFE, PH.D.
`
`VOLUME IL
`
`November 10, 2015
`
`Palo Alto, California
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 1 of 59
`
`
`
`
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`17
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`18
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`19
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`20
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`21
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`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
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`202-232-0646
`LG Ex. 1020, pg 2
`
`AMD1044_0012401
`
`ATI Ex. 2006
`IPR2023-00922
`Page2 of 59
`
`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`VIDECTAPED DEPOSITION OF ANDREW WOLFE,
`
`Page 282
`
`PH.D., called on behalf of the petitioner as a
`
`1
`
`2
`
`3 witness in the above-entitled matter, held at Mayer
`
`Brown LLP, Two Palo Alto Square, Suite 300,
`
`3000 El Camino Real, Palo Alto, California,
`
`commencing at 8:56 a.m. on Tuesday, November 10,
`
`2015, before Michelle D. Knowles, CSR No. 8979.
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`4
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`IPR2023-00922
`Page 2 of 59
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`
`
`Andrew Wolfe
`LG Electronics, Inc. v. ATI Technologies ULC
`11/10/2015
`Confidential - Pursuant to Protective Order
`
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`
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`APPEARANCES ;:
`
`Page 283
`
`On behalf of Petitioner, LG ELECTRONICS,
`
`INC.:
`
`
`MAYER BROWN LLP
`
`BY:
`
`CLIFF A. MATER, PH.D.
`
`Two Palo Alto Square, Suite 300
`
`3000 El Camino Real
`
`Palo Alto, CA 94306-2112
`
`(650) 331-2026
`
`cmaier@mayerbrown.com
`
`MAYER BROWN LLP
`
`
`BYAN NESE, ESQ.
`
`BY:
`
`
`
`1999 K Street, N.W.
`
`Washington, D.C. 2006-1101
`
`(202) 263-3266
`
`bnese@mayerbrown.com
`
`On behalf of Patent Owner, ATL TECHNOLOGIAS ULC, and
`
`tne Witness:
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`BY:
`
`JONATHAN TUMINARO, PH.D.
`
`JAY BIRD, ESQ.
`
`1100 New York Avenue, NW
`
`Washington, DC 20005
`
`(202) 371-2600
`
`jtuminaréskgf.com
`
`jbird@skof.com
`
`20
`
`2i
`
`22
`
`Also Present:
`
`CAREY MOOK, Certified Legal Videographer
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 3
`
`AMD1044_0012402
`
`ATI Ex. 2006
`IPR2023-00922
`Page 3 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 3 of 59
`
`
`
`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`INDEX
`
`Page 284
`
`WITNESS:
`
`PAGE
`
`ANDREW WOLFE, PH.D.
`
`Examination by Mr. Maier
`
`(Resumed)
`
`286
`
`EXHIBITS
`
`DEPOSITION EXHIBITS:
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`g
`
`PAGEK
`
`287
`
`299
`
`301
`
`
`
`
`1 Wolfe Exhibit 12, United States Patent
`
`il
`
`12
`
`5,500,939
`
`
`1s Wolfe Exhibit 13, Declaration of Andrew Wolfe
`
`14
`
`15
`
`Regarding U.S. Patent No. 7,327,365
`
`16 Wolfe Exhibit 14, Declaration of Andrew Wolfe
`
`i?
`
`1g
`
`Regarding Actual Reduction to Practice of
`
`U.S. Patent No. 7,742,053
`
`
`
`26
`
`21
`
`22
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 4
`
`AMD1044_0012403
`
`ATI Ex. 2006
`IPR2023-00922
`Page 4 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 4 of 59
`
`
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`cH
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`Oo
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`7
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`Oo
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`Lo
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`ic
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`il
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`12
`
`i4
`
` 1s
`
`
`
`
`Andrew Wolfe
`LG Electronics, Inc. v. ATI Technologies ULC
`11/10/2015
`Confidential - Pursuant to Protective Order
`
`Page 285
`
`PALO ALTO, CALIFORNIA;
`
`TUESDAY, NOVEMBER 10, 2015, 8:56 A.M.
`
`---000---
`
`THE VIDEOGRAPHER: Good morning. We are
`
`now on the record.
`
`This is Video No.
`
`1
`
`in the video
`
`deposition of Andrew Wolfe, Ph.D., Volume No.
`
`IT,
`
`taken by the petitioner in the matter of LG
`
`Flectronics,
`
`Inc. versus ATI Technologies ULC,
`
`in
`
`tne United States Patent and Trademark Office,
`
`Patent Trial and Appeal Board, No.
`
`IPR2015-00325,
`
`326, and 330.
`
`Today's date is Tuesday, November 10th,
`
`2015.
`
`The time on the video screen is 8:56 a.m.
`
`The location, court reporter, and
`
`videographer are the same as Volume No.
`
`TI.
`
`Will all counsel now please state your
`
`appearance for the record.
`
`MR. MATER: Cliff Maier of the firm Mayer
`
`Brown on behalf of LG.
`
`
`
`
`MR. NESE: Bryan Nese with Mayer Brown for
`
`petitioner, LG Electronics,
`
`Inc.
`
`is
`
`i6
`
`17
`
`6
`
`1s
`
`20
`
`ai
`
`22
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 5
`
`AMD1044_0012404
`
`ATI Ex. 2006
`IPR2023-00922
`Page 5 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 5 of 59
`
`
`
`Andrew Wolfe
`LG Electronics, Inc. v. ATI Technologies ULC
`11/10/2015
`Confidential - Pursuant to Protective Order
`
`i
`
`ho
`
`Go
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`4
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`(Ht
`
`Oo
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`7
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`12
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`1s
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`14
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`1s
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`
`
`
`
`MR
`
`» TUMINARO:
`
`Jonathan Tuminaro from
`
`Page 286
`
`Sterne, Kessler, Goldstein & Fox on behalf of the
`
`patent owner, ATI Technologies ULC, and the witness.
`
`MR
`
`. BIRD:
`
`Jay Bird from Sterne, Kessler,
`
`Goldstein & Fox, also on behalf of the patent owner,
`
`ATT ULC Technologies, and the witness.
`
`THE VIDEOGRAPHER: Okay. Did you want to
`
`re-administer the oath or...
`
`MR. MATER:
`
`sure.
`
`ANDREW WOLFE, PH.D.,
`
`having been first duly affirmec, was examined and
`
`testified as follows:
`
`EXAMTNATION BY MR. MATER (RESUMED)
`
`MR. MAIER:
`
`©. Well, welcome back,
`
`Dr. Wolfe.
`
`A.
`
`Heilo.
`
`©. We'll try not to take up your entire day,
`
`
`if we can. We did a good job yesterday of getting
`
`through a lot of stuff, and so I won't remind you of
`
`i6
`
`i?
`
`is
`
`is
`
`20
`
`ai
`
`Oe
`
`all of the introductory, how-to- --
`
`how-to-be-deposed stuff that I went
`
`through
`
`yesterday. But if, at any point, you want a break,
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 6
`
`AMD1044_0012405
`
`ATI Ex. 2006
`IPR2023-00922
`Page 6 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 6 of 59
`
`
`
`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`just let me know.
`
`Let's start out back in Exhibit 2, which
`
`Page 287
`
`is your declaration in the 326 IPR, and let's talk a
`
`little bit about the Kurihara reference.
`
`MR. MATER: And did we distribute Kurihara
`
`yesterday?
`
`I guess not.
`
`MR. NESE: We did not.
`
`MR. MATER: Let's get that in evidence.
`
`(Wolfe Exhibit 12 marked for
`
`
`
`
`i
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`2
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`3
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`4
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`3
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`7
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`io
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`il
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`Le
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`is
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`i4
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`
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`is
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`i6
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`1”
`
`6
`
`19
`
`20
`
`al
`
`ee
`
`identification.)
`
`
`
`MR. MATER: And what's the number?
`
`MR. NESE?
`
`12.
`
`MR. TUMINARO:
`
`Thanks, Bryan.
`
`MR. NESE: Youtre welcome.
`
`MR. MATER:
`
`@.
`
`So just some bookkeeping:
`
`
`In front of you should now be Exhibit 12, which is
`
`United States Patent No. 5,500,939 to Kurihawa --
`
`-hara.
`
`A.
`
`Q.
`
`Do you recognize that?
`
`I do.
`
`
`And that's one of the references that you
`
`analyzed and opined on in Exhibit 2, which is your
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 7
`
`AMD1044_0012406
`
`ATI Ex. 2006
`IPR2023-00922
`Page7 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 7 of 59
`
`
`
`Andrew Wolfe
`LG Electronics, Inc. v. ATI Technologies ULC
`11/10/2015
`Confidential - Pursuant to Protective Order
`
`i
`
`ho
`
`Go
`
`4
`
`an
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`Oo
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` 19
`
`
`
`
`declaration in the 326 proceeding;
`
`is that correct?
`
`A,
`
`As part of a combination that was proposed
`
`Page 288
`
`by LG, yes.
`
`Q.
`
`Okay.
`
`I'd like to direct your attention
`
`to page 259, paragraph 319 of the Exhibit 2.
`
`MR. MATER:
`
`T saw the Look.
`
`Q.
`
`And in this paragraph, you're discussing
`
`that it's your opinion that Kurihara does not teach
`
`or suggest the processor unit of claim 20;
`
`is that
`
`correct?
`
`A,
`
`QO.
`
`Tt does say that, yes.
`
`And am IT correct
`
`in understanding that one
`
`of your arguments is that -- well,
`
`let me strike
`
`that.
`
`Does Kurihara suggest that vertex data can
`
`be processed?
`
`A.
`
`QO.
`
`Tt does.
`
`And does Kurihara suggest that pixel data
`
`can be processed?
`
`is
`
`is
`
`i?
`
`is
`
`20
`
`ai
`
`22
`
`A.
`
`Tt does but at a different time, ina
`
`
`different phase.
`
`Q.
`
`So it's your understanding that Kurihara
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 8
`
`AMD1044_0012407
`
`ATI Ex. 2006
`IPR2023-00922
`Page 8 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 8 of 59
`
`
`
`Andrew Wolfe
`LG Electronics, Inc. v. ATI Technologies ULC
`11/10/2015
`Confidential - Pursuant to Protective Order
`
`ho
`
`Go
`
`(Ht
`
`Oo
`
`Oo
`
`Lo
`
`io
`
`it
`
`12
`
`is
`
`id
`
`is
`
`is
`
`
`
`
`suggests that vertex and pixel data cannot be
`
`processed at the same time?
`
`Page 289
`
`MR. TUMINARO: Objection.
`
`Form.
`
`THE WITNESS: Not without adding something
`
`to Kurihara that's not there.
`
`The -- the -- all
`
`Kurihara really teaches is that there are FIFOs that
`
`can either be holding pixel data or can be holding
`
`vertex data, and it only describes the situations
`
`wnere it holds one or the other.
`
`And the real teaching of Kurihara is that
`
`
`you would set the FIFO or refill
`threshold
`
`differently when processing vertex data than when
`
`processing pixel data. And it doesn't even seem to
`
`contemplate and certainly doesn't teach how to deal
`
`with the situation where you could have both vertex
`
`
`and pixel data in the same FIFO or where different
`
`FIFOs could have different types of data.
`
`And in claim 20 requires a -- a processor
`
`unit that executes vertex calculations while pixel
`
`
`
`i?
`
`is
`
`is
`
`20
`
`calculations are still in progress, and that's
`
`ai what's not disclosed in Kurihara.
`
`Oe
`
`MR. MATER:
`
`©.
`
`So I Just want to make
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 9
`
`AMD1044_0012408
`
`ATI Ex. 2006
`IPR2023-00922
`Page 9 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 9 of 59
`
`
`
`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`Page 290
`
`i
`
`2
`
`sure I understand you.
`
`So you agree that in Kurihara,
`
`there are
`
`3 multiple graphics processors; correct?
`
`A.
`
`Q.
`
`There are.
`
`And you agree that those graphics
`
`processors can operate simultaneously; correct?
`
`A,
`
`Yes. Let me take a quick look and see
`
`wnat
`
`the limitations are on that.
`
`They can -- they can operate
`
`simultaneously.
`
`QO.
`
`And you agree that the graphics data in
`
`the FIFO memories can be either vertex data or pixel
`
`data; correct?
`
`MR. TUMINARO:
`
`Op jection.
`
`Form.
`
`THE WITNESS: Yes. As is disclosed in
`
`the FIFOs can either hold -- all the FIFOs
`
`16 Kurihara,
`
`
`
`
`4
`
`S
`
`6
`
`7
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`g
`
`g
`
`id
`
`it
`
`te
`
`is
`
`14
`
`1s
`
`
`
`1”
`
`is
`
`19
`
`can hold pixel data, or all the FIFOs can hold
`
`vertex data.
`
`MR. MATER:
`
`9.
`
`Is it your understanding
`
`20
`
`al
`
`22
`
`that claim 20 requires that a single processor unit
`
`stalls one type of graphics processing operation
`
`while that operation is in progress in order to
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 10
`
`AMD1044_0012409
`
`ATI Ex. 2006
`IPR2023-00922
`Page 10 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 10 of 59
`
`
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`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`Page 291
`
`perform anotner type of graphics processing
`
`operation?
`
`MR. TUMINARO: Objection.
`
`Form.
`
`THE WITNESS:
`
`T think that's right.
`
`There's only a single processor unit that's recited
`
`in claim 20, and the vertex calculations and the
`
`
`
`
`i
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`2
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`3
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`4
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`S
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`id
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`te
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`
`is
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`19
`
`20
`
`al
`
`ee
`
`
`
`pixel calculations both have to operate on the
`
`processor unit.
`
`So I think that's -- that's
`
`
`
`correct.
`
`MR. MATER:
`
`©. And it's your
`
`understanding that if one operation is stalled and
`
`
`then another operation is performed,
`
`that those two
`
`operations are performed simultaneously?
`
`A,
`
`Not simultaneously but while still in
`
`progress. And actually, it wouldn't have to be
`
`stalled.
`
`They -- they could both be executing
`
`concurrently in a single processor unit if some- --
`
`somehow -- or they could be -- they could be both in
`
`
`the pipeline of a single processor unit.
`
`
`lt's -- it's a little bit broader than
`
`
`that, but -- but if the processor units are simple,
`
`then -- then one would have to stall.
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 11
`
`AMD1044_0012410
`
`ATI Ex. 2006
`IPR2023-00922
`Page 11 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 11 of 59
`
`
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`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`Page 292
`
`i
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`g
`
`io
`
`it
`
`QO.
`
`What does it mean when you say
`
`that -- strike that.
`
`What does it mean when you refer to
`
`“interleaving calculations of different types" in
`
`paragraph 320?
`
`A.
`
`There's no disclosure in Kurihara that --
`
`that while -- that -- that -- that vertex and pixel
`
`operations,
`
`for example, can occur in close
`
`proximity to each other in time or in space. All
`
`that's described is that the FIFOs fill up with one
`
`type of data, and then that whole phase is
`
`
`
`i?
`
`is
`
`is
`
`
`
`
`12
`
`is
`
`i4
`
`is
`
`i6
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`completed.
`
`And there's no description of placing data
`
`of a different type into any one of the FIFOs while
`
`
`any operation of a different type or from a previous
`
`phase is still in progress.
`
`QO.
`
`Is it your understanding that claim 20 of
`
`
`the '871 patent requires interleaving calculations
`
`of different tyoes?
`
`20
`
`ai
`
`Oe
`
`A.
`
`It doesn't require it, but that would be
`
`one way ~- that -- that was essentially what was
`
`implied in the invalidity allegations,
`
`is that they
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 12
`
`AMD1044_0012411
`
`ATI Ex. 2006
`IPR2023-00922
`Page 12 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 12 of 59
`
`
`
`Andrew Wolfe
`LG Electronics, Inc. v. ATI Technologies ULC
`11/10/2015
`Confidential - Pursuant to Protective Order
`
`Page 293
`
`would be interleaved, and -- and it was just a
`
`misreading of the reference.
`
`QO.
`
`So claim 20 would permit a situation in
`
`which the processor unit is capable of
`
`simultaneously performing two operations?
`
`MR. TUMINARO: Objection.
`
`Form.
`
`THE WITNESS:
`
`MR. MAIER:
`
`
`
`It could.
`
`©. Let's turn to page 261 of
`
`
`
`
`ho
`
`Go
`
`(Ht
`
`Oo
`
`Oo
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`g
`
`ic
`
`it
`
`12
`
`is
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`id
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`is
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`i6
`
`1”
`
`16
`
`is
`
`
`
`20
`
`al
`
`Oe
`
`Exhibit 2.
`
`Earlier, with respect to the 325 IPR, we
`
`talked about objective indicia of nonobviousness.
`
`Here in Exhibit 2, you also have some discussion of
`
`objective indicia of nonobviousness.
`
`One of the things that you talk about is
`
`ATT's Xenos chip;
`
`is that correct?
`
`A
`
`QO.
`
`Correct
`
`And that chip was used in the Xbox 360;
`
`is
`
`that correct?
`
`A.
`
`Q.
`
`Yes.
`
`And the Xbox 360 was generally directed
`
`toward gaming;
`
`is that correct?
`
`A.
`
`I guess that's correct; although,
`
`I think
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 13
`
`AMD1044_0012412
`
`ATI Ex. 2006
`IPR2023-00922
`Page 13 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 13 of 59
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`is
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`20
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`22
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`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`i Microsoft marketing might not agree.
`
`They -- they
`
`Page 294
`
`2
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`3
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`4
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`6
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`7
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`g
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`g
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`16
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`ii
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`12
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`1s
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`id
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`is
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`i6
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`
`Saw it as a -- as a multidimensional platform for
`
`gaming and video and a number of other applications.
`
`QO.
`
`Is it your understanding that the Xbox 360
`
`was directed to engineering applications like
`
`SOLTDWORKS?
`
`A.
`
`QO.
`
`No.
`
`Ts it your understanding that ATI's Xenos
`
`chip practiced any claim of the '871 patent?
`
`A.
`
`O.
`
`Yes, it is.
`
`And on what do you base that
`
`understanding?
`
`MR. TUMINARO:
`
`I'll caution the witness
`
`not
`
`to disclose the substance of any attorney
`
`communication you may have had or work that you did
`
`at the direction of counsel that's not
`
`in your
`
`report.
`
`
`THE WITNESS:
`
`It's my understanding that
`
`the key functionality in the R400 source code that I
`
`analyzed for this case is still present
`
`in the Xenos
`
`enip.
`
`MR. MAIER:
`
`©. And what's the basis of
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 14
`
`AMD1044_0012413
`
`ATI Ex. 2006
`IPR2023-00922
`Page 14 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 14 of 59
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`
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`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`that understanding?
`
`Page 295
`
`A.
`
`QO.
`
`That's been represented to me by ATI.
`
`So there's no -- there's no evidence that
`
`
`
`
`
`
`i
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`2
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`4
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`
`i?
`
`is
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`19
`
`
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`20
`
`2i
`
`Ze
`
`you can give me today that that's the case;
`
`is tnat
`
`correct?
`
`A.
`
`QO.
`
`T
`
`think that's right.
`
`Have you prepared a claim chart that
`
`compares the functionality of the Xenos chip to any
`
`claim of the '871 patent?
`
`MR. TUMINARO: Objection.
`
`Form.
`
`THE WITNESS: Only to the extent that it's
`
`consistent with the earlier development versions
`
`that
`
`I analyzed.
`
`MR. MATER:
`
`©. And how do you know that
`
`it's consistent with those earlier development
`
`versions?
`
`A.
`
`That's what the developers have
`
`represented to me.
`
`QO.
`
`You mention an article in Computer
`
`authored by Greg Humphreys in paragraph 324;
`
`is that
`
`correct?
`
`A.
`
`Yes
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 15
`
`AMD1044_0012414
`
`ATI Ex. 2006
`IPR2023-00922
`Page 15 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 15 of 59
`
`
`
`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`Page 296
`
`i
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`e
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`g
`
`io
`
`il
`
`Q.
`
`Is there information in that article
`
`sufficient to allow you to determine that the Xenos
`
`chip practiced any claim of the '871 patent?
`
`A.
`
`QO.
`
`A.
`
`No, not
`
`in the article alone.
`
`Does Microsoft operate chip fabs?
`
`T'm not aware of them operating any chip
`
`fabs, but
`
`I -- I wouldn't necessarily know.
`
`Q.
`
`You say in paragraph 325 that the Xenos
`
`chip was based on ATI's design;
`
`is that correct?
`
`A.
`
`QO.
`
`Yes.
`
`Did -- are you aware of whether or not
`
`te Microsoft modified that design in any way?
`
`is
`
`14
`
`is
`
`is
`
`i?
`
`6
`
`
`
`
`
`
`A.
`
`O.
`
`It's my understanding they did not.
`
`What is your understanding of what it
`
`meant that -- when you say that Microsoft had the
`
`Xenos chip fabricated?
`
`A,
`
`It's my understanding that the tapeout
`
`files were provided from ATI
`
`to Microsoft, and then
`
`19 Microsoft entered a contract with the fabrication
`
`20
`
`ai
`
`ee
`
`facility to have the chips built.
`
`Q.
`
`Are you aware of whether or not the
`
`Xbox 360 was marked with the '871 patent number?
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 16
`
`AMD1044_0012415
`
`ATI Ex. 2006
`IPR2023-00922
`Page 16 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 16 of 59
`
`
`
`Andrew Woife
`LG Electronics, Inc. v. ATI Technologies ULC
`11/10/2015
`Confidential - Pursuant to Protective Order
`
`
`A.
`
`Q.
`
`T
`
`am not aware one way or the other.
`
`Are you -- are you aware of whether or not
`
`ATI marks any of its products with the '871 patent
`
`Page 297
`
`number?
`
`A.
`
`Q.
`
`T don't know one way or the other.
`
`You mention in paragraph 325
`
`Dean Takahasni;
`
`is that correct?
`
`A,
`
`Q.
`
`A.
`
`Yes.
`
`What books has Dean Takahashi written?
`
`Oh,
`
`I don't know if I know all of his
`
`
`
`
`ho
`
`Go
`
`cH
`
`Oo
`
`Oo
`
`Lo
`
` g
`
`20
`
`21
`
`books, but he wrote a book on the Xbox and he wrote
`
`a book on the Xbox 360. Primarily, he's been a
`
`daily journalist through most of his career.
`
`He was
`
`the Silicon Valley editor for the Wall Street
`
`Journal, and he worked at -- at Red Herring and --
`
`and now at GameBeat.
`
`Q.
`
`In paragraph 325, you say you -- he
`
`-~—- you
`
`
`know "he interviewed Microsoft staff extensively to
`
`develop the facts reported in his book."
`
`A.
`
`Uh-huh.
`
`Q. What's the basis for that knowledge?
`
`A.
`
`I was
`
`in regular communication with him
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 17
`
`AMD1044_0012416
`
`ATI Ex. 2006
`IPR2023-00922
`Page 17 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 17 of 59
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`
`
`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`i
`
`2
`
`3
`
`4
`
`S
`
`6
`
`7
`
`e
`
`9
`
`io
`
`ii
`
`te
`
`is
`
`i4
`
`is
`
`wnen he was making the trios and scheduling the
`
`interviews, and he was telling me about
`
`them at the
`
`Page 298
`
`time.
`
`QO.
`
`A.
`
`Q.
`
`So you know Dean Takahashi personally?
`
`Todo.
`
`Is there anything in any of the claims of
`
`the '871 patent that re- -- strike that.
`
`Does the -- does the term "unified shader"
`
`appear anywhere in the claims of the '871 patent?
`
`A.
`
`Yes.
`
`OQ. Where is that?
`
`A.
`
`Q.
`
`A,
`
`Preamble of claim 15,
`
`for example.
`
`Anywhere else?
`
`It's referred back to as "the shacer" in
`
`the depending claims.
`
`A person of ordinary skill
`
`would understand that to be referring to a unified
`
`snader.
`
`QO.
`
`
`And claim 15 doesn't Just claim a unified
`
`snader.
`
`It claims a specific unified shader;
`
`
`
`
`
`
`i6
`
`7
`
`6
`
`19
`
`20
`
`al
`
`Oe
`
`correct?
`
`A.
`
`Q.
`
`It does.
`
`Is it possible to design a graphics chip
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 18
`
`AMD1044_0012417
`
`ATI Ex. 2006
`IPR2023-00922
`Page 18 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 18 of 59
`
`
`
`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`Page 299
`
`with a unified shader that doesn't infringe
`
`claim 15?
`
`MR. TUMINARO: Objection to form.
`
`THE WITNESS: Depends how you define
`
`"unified shader."
`
`I mean, certainly not -- it
`
`depends how you define "unified shader."
`
`i
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`g
`
`g
`
`io
`
`it
`
`12
`
`is
`
`14
`
`is
`
`is
`
`1”
`
`16
`
`19
`
`
`
`
`
`
`structure that doesn't practice claim 15.
`
`I'd have
`
`
`
`Certainly, you could de- -- have a
`
`to look at it to see whether or not anybody would
`
`call it a unified shader or not.
`
`MR. MATER: Let's jump to the third IPR.
`
`
`(Wolfe Exhibit 13 marked for
`
`identification.)
`
`MR. MATER: This is 13?
`
`MR. NESE: Yes.
`
`MR. TUMINARO:
`
`Thank you.
`
`MR. MATER:
`
`©.
`
`So in front of you now
`
`should be a document marked as Exhibit 13 entitled
`
`"DECLARATION OF ANDREW WOLFE REGARDING U.S. PATENT
`
`20
`
`ai
`
`ee
`
`NO. 7,327,369."
`
`This appears to be a declaration submitted
`
`by you in IPR2015-00330;
`
`is that correct?
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 19
`
`AMD1044_0012418
`
`ATI Ex. 2006
`IPR2023-00922
`Page 19 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 19 of 59
`
`
`
`Andrew Wolfe
`LG Electronics, Inc. v. ATI Technologies ULC
`11/10/2015
`Confidential - Pursuant to Protective Order
`
`i
`
`ho
`
`Go
`
`4
`
`cH
`
`Oo
`
`7
`
`Oo
`
`Lo
`
`id
`
`it
`
`12
`
`is
`
`i4
`
`is
`
`A.
`
`Correct.
`
`MR. TUMINARO:
`
`I'll cust note for the
`
`record that this is black and white, and it was
`
`produced in color.
`
`MR. MATER: Fair enough.
`
`Q.
`
`In this declaration, do you offer any
`
`Opinions as to any of the prior art alleged to
`
`invalidate the patent?
`
`A,
`
`I offer the opinion that it's not,
`
`in
`
`fact, prior art,
`
`that it postdates conception and
`
`reduction to practice.
`
`Q.
`
`Do you offer any opinions as to whether or
`
`not any of that alleged prior art is missing any of
`
`the limitations of any of the claims?
`
`A,
`
`Q.
`
`T dontt.
`
`And so your argument is that it's not
`
`prior art because of prior conception and reduction
`
`to practice;
`
`is that correct?
`
`A.
`
`That's my opinion.
`
`
`
`
` g
`
`16
`
`i?
`
`is
`
`is
`
`20
`
`al
`
`22
`
`MR. MATER: And then we're done with that
`
`one,
`
`so that was pretty easy.
`
`Let's do the final,
`
`the -- that one.
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 20
`
`AMD1044_0012419
`
`ATI Ex. 2006
`IPR2023-00922
`Page 20 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 20 of 59
`
`
`
`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`Page 301
`
`(Wolfe Exhibit 14 marked for
`
`
`
`identification.)
`
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`e
`
`g
`
`io
`
`ii
`
`te
`
`1s
`
`14
`
`is
`
`
`
`is
`
`i?
`
`6
`
`19
`
`20
`
`21
`
`22
`
`MR. MATER:
`
`0.
`
`In front of you now should
`
`be Exhibit 14, which is entitled "DECLARATION OF
`
`ANDREW WOLFE REGARDING ACTUAL REDUCTION TO PRACTICE
`
`OF U.S. PATENT NO. 7,742,053." And this appears to
`
`be a -- I believe it's a supplementary or a second
`
`declaration for Case IPR2015-00325.
`
`Is this a declaration that you offered in
`
`that matter?
`
`A.
`
`Tt is.
`
`MR. TUMINARO:
`
`I'm just going to object to
`
`form, but...
`
`MR. MATER: Okay.
`
`Q.
`
`The -~- earlier you were -- just a minute
`
`ago, you were talking about, with respect to the
`
`330,
`
`some -- that -- that one of your opinions was
`
`that there was conception and reduction to practice
`
`that predated some of the alleged prior art, and
`
`that was based on the R400 chip;
`
`is that correct?
`
`A.
`
`Q.
`
`The R400 design, yes.
`
`And this declaration addresses similar
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 21
`
`AMD1044_0012420
`
`ATI Ex. 2006
`IPR2023-00922
`Page 21 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 21 of 59
`
`
`
`Andrew Wolfe
`LG Electronics, Inc. v. ATI Technologies ULC
`11/10/2015
`Confidential - Pursuant to Protective Order
`
`Page 302
`
`arguments but with respect to the '053 patent;
`
`is
`
`that correct?
`
`A.
`
`Yes, an actual reduction to practice and a
`
`constructive reduction to practice.
`
`Q.
`
`And maybe we can save a little bit of
`
`time.
`
`The evidence and the details regarding the
`
`actual re- -- reduction to practice and conception,
`
`do they differ between the three IPRs?
`
`A.
`
`Q.
`
`Yes.
`
`Other than comparing to the patent claims
`
`and comparing to the dates or the actual --
`
`they're -- they're not all based on the R400?
`
`A,
`
`Oh,
`
`they are all based on tne R400 but
`
`different pieces of R400 code, and different pages
`
`in the document correspond to different claim
`
`elements.
`
`Q.
`
`Okay.
`
`I understand that.
`
`We would be looking at different
`
`i6
`
`i?
`
`16
`
`is
`
`
`
`
`ho
`
`Go
`
`(Ht
`
`Oo
`
`Oo
`
`Lo
`
`10
`
`il
`
`12
`
`is
`
`i4
`
`is
`
`
`
`20
`
`ai
`
`22
`
`structures in the R400, different Verilog, but it's
`
`the same R400 that we're talking about
`
`in all of
`
`these cases; correct?
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 22
`
`AMD1044_0012421
`
`ATI Ex. 2006
`IPR2023-00922
`Page 22 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 22 of 59
`
`
`
`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`Page 303
`
`A.
`
`Tt is. Although,
`
`for the conception
`
`documents, for one of the patents, at least, maybe
`
`for -- I'm trying to remember which.
`
`I
`
`think for
`
`the '871 and '369 patents,
`
`I Look at two different
`
`versions of the conception documents at two
`
`different dates.
`
`QO.
`
`A.
`
`Okay.
`
`Actually,
`
`let me just check and make sure
`
`T have that.
`
`No. That's actually for the '053.
`
`I
`
`look
`
`at the conception documents as of two different
`
`dates,
`
`two different versions.
`
`Q.
`
`Ts it your understanding that actual
`
`reduction to practice requires proof of either an
`
`embodiment of a claimed invention or performance of
`
`a process that includes all limitations of the
`
`claimed invention?
`
`
`
`
`1
`
`é
`
`3
`
`4
`
`5
`
`6
`
`7
`
`e
`
`9
`
`id
`
`it
`
`te
`
`is
`
`id
`
`is
`
`is
`
`i?
`
`is
`
`is
`
`20
`
`al
`
`ee
`
`
`
`
`
`A.
`
`That's what counsel has asked me to apply
`
`as a legal principle for purposes of this
`
`proceeding.
`
`QO.
`
`And that's the legal principle you applied
`
`in performing your analysis?
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 23
`
`AMD1044_0012422
`
`ATI Ex. 2006
`IPR2023-00922
`Page 23 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 23 of 59
`
`
`
`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`i
`
`2
`
`3
`
`4
`
`S
`
`6
`
`7
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`
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`
`
`
`
`A.
`
`Q.
`
`Yes.
`
`On paragraph -- in paragraph 23 on page 9,
`
`Page 304
`
`you describe that you examined two types of source
`
`code.
`
`You talk about RTL code and Verilog and
`
`emulator code in C++;
`
`is that correct?
`
`A.
`
`Q.
`
`Correct.
`
`And you examined those types of source
`
`code as part of your analysis of actual reduction to
`
`practice?
`
`A,
`
`Yes.
`
`The RTL code is the evidence of
`
`actual reduction to practice.
`
`The Ct+ code is --
`
`basically corroborates it.
`
`MR. TUMINARO:
`
`Just -- I'm going to
`
`designate the transcript as confidential under the
`
`protective order as we're getting into source code.
`
`MR. NESE: Both days or just today?
`
`MR. TUMINARO: Well,
`
`I think I'il
`
`designate the whole thing, and then we'll -- we can
`
`
`
`17
`
`1g
`
`is
`
`20
`
`21
`
`Oe
`
`figure it out afterwards.
`
`
`MR. NESE: Okay.
`
`MR. MATER:
`
`©. When you say that you
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 24
`
`AMD1044_0012423
`
`ATI Ex. 2006
`IPR2023-00922
`Page 24 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 24 of 59
`
`
`
`
`
`
`Page 305
`
`examined the source code, what do you mean?
`
`A.
`
`TI read it,
`
`I reviewed it,
`
`I studied it to
`
`the point that I could understand how it operated,
`
`and then I documented relevant portions of it for
`
`the purpose of preparing this report.
`
`©.
`
`The -- let's talk first about
`
`the emulator
`
`code.
`
`A.
`
`QO.
`
`A.
`
`QO.
`
`A.
`
`QO.
`
`code?
`
`code?
`
`Okay.
`
`That was written in C++;
`
`is that correct?
`
`Yes.
`
`Did you attempt to compile the emulator
`
`No.
`
`Did you attempt to execute the emulator
`
`A. Well, without compiling it, it wasn't
`
`executable.
`
`Q.
`
`
`Did you attempt to apply any inputs to the
`
`emulator code to see what the outouts would be?
`
`A,
`
`No.
`
`It's my understanding that ATI did
`
`
`and that they have and will testify about that
`
`
`
`experience, but
`
`I didn't do it.
`
`11/10/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Andrew Wolfe
`Confidential - Pursuant to Protective Order
`
`
`1
`
`é
`
`3
`
`4
`
`5
`
`6
`
`7
`
`g
`
`3
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`
`19
`
`20
`
`al
`
`22
`
`
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 25
`
`AMD1044_0012424
`
`ATI Ex. 2006
`IPR2023-00922
`Page 25 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 25 of 59
`
`
`
`
`
`
`Q.
`
`Have you seen any results of executing the
`
`emulator code?
`
`A,
`
`I don't think directly.
`
`I think that the
`
`results I've seen are the results of executing the
`
`RTL. And I
`
`think that I've heard witnesses say that
`
`the results of the emulator code were identical, but
`
`I don't think I've seen them separately.
`
`QO.
`
`Have you -- well, let's -- let's talk
`
`about that a little bit.
`
`Is it your understanding that one of the
`
`purposes of the emulator code is that you would
`
`apply the same inputs to the RTL and the emulator
`
`code and determine whether or not you get the same
`
`outputs?
`
`A.
`
`That's my understanding of one of its
`
`purposes, yes.
`
`Q.
`
`A.
`
`And is that called logic verification?
`
`I don't know that I've heard the term
`
`"logic verification" used.
`
`I -- I -- it -- I've
`
`heard it referred to as "verification."
`
`Q.
`
`Are there other types of verification that
`
`need to be performed when one is designing a chip?
`
`Andrew Wolfe
`LG Electronics, Inc. v. ATI Technologies ULC
`11/10/2015
`Confidential - Pursuant to Protective Order
`
`
`
`ho
`
`Go
`
`cH
`
`Oo
`
`Oo
`
`Lo
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`io
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`it
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`12
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`is
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`id
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`is
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`16
`
`7
`
`6
`
`is
`
`20
`
`ai
`
`ee
`
`
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 26
`
`AMD1044_0012425
`
`ATI Ex. 2006
`IPR2023-00922
`Page 26 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 26 of 59
`
`
`
`Andrew Wolfe
`LG Electronics, Inc. v. ATI Technologies ULC
`11/10/2015
`Confidential - Pursuant to Protective Order
`
`Page 307
`
`A.
`
`Yeah. There's timing verification.
`
`Sometimes there's functional verification. Depends
`
`on what
`
`the process is at an individual company.
`
`QO.
`
`Do you know what
`
`the process was at A- --
`
`at ATI when they were designing the R400?
`
`MR. TUMINARGO: Objection to form.
`
`THE WITNESS:
`
`MR. MATER:
`
`
`
`In general,
`
`I do.
`
`9.
`
`You state in paragraph 23
`
`
`
`
`ho
`
`Go
`
`(Ht
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`
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`
`6
`
`19
`
`
`
`that RTL is used to instantiate a hardware design.
`
`What did you mean by the term
`
`"instantiate"?
`
`A.
`
`To create an embodiment,
`
`to create a --
`
`what we sometimes call a realization.
`
`So once you
`
`think of a hardware design, you have to actually
`
`create a version of it. And RTL is a specification
`
`language,
`
`so it creates 4 version of a hardware
`
`design in which the specific design decisions and
`
`
`specific structure and function decisions have to be
`
`made.
`
`20
`
`ai
`
`ee
`
`QO.
`
`It's your understanding that RTL creates
`
`hardware?
`
`A.
`
`In a sense.
`
`In the same sense that --
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1020, pg 27
`
`AMD1044_0012426
`
`ATI Ex. 2006
`IPR2023-00922
`Page 27 of 59
`
`ATI Ex. 2006
`
`IPR2023-00922
`Page 27 of 59
`
`
`
`Andrew Wolfe
`LG Electronics, Inc. v. ATI Technologies ULC
`11/10/2015
`Confidential - Pursuant to Protective Order
`
`ho
`
`Go
`
`(Ht
`
`Oo
`
`8
`
`9
`
`io
`
`ii
`
`12
`
`is
`
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`
`is
`
`16
`
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