`
`Laurent Lefebvre
`LG Electronics, Inc. v. ATI Technologies ULC
`11/13/2015
`Confidential - Pursuant to the Protective Order
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`) )
`
`} CASE IPR-2015-00325
`
`
`
`LG ELECTRONICS,
`
`INC.,
`
`Petitioner,
`
`) Patent 7,742,053 B2
`
`) CASE TPR-2015-00326
`
`) Patent 6,897,871
`
`CASE IPR-2015-00330
`
`) )
`
`-VS-
`
`ATT TECHNOLOGIES ULC,
`
`Patent Owner.
`
`) Patent 7,327,369 B2
`
`
`
`***X CONFIDENTIAL - PURSUANT TO THE PROTECTIVE ORDER***
`
`VIDEOTAPED DEPOSITION OF LAURENT LEFEBVRE
`
`ON FRIDAY, NOVEMBER 13, 2015
`
`IN MONTREAL, QUEBEC, CANADA.
`
`VIDEOGRAPHER:
`
`DAVID OXILIA
`
`COURT REPORTER: CHERIE KLEIN
`
`
`
`DIGITAL EVIDENCE GROUP
`
`1726 M Street NW, Suite 1010
`
`Washington, DC
`
`20036
`
`(202) 232-0646
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`LG Ex. 1035
`
`LG v. ATI
`
`IPR2015-00325
`
`202-232-0646
`
`LG Ex. 1035, pg 1
`
`AMD1044_0012459
`
`ATI Ex. 2007
`IPR2023-00922
`Page 1 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 1 of 159
`
`
`
`
`
`
`Laurent Lefebvre
`LG Electronics, Inc. v. ATI Technologies ULC
`11/13/2015
`Confidential - Pursuant to the Protective Order
`
`Page 2
`
`APPEARANCES;
`
`FOR PETITIONER:
`
`MAYER BROWN
`
`BY:
`
`BRYAN NESE, ESQUIRE
`
`1999 K Street NW
`
`1
`
`2 3
`
`4
`
`S Washington, D.C. 20006-1101
`
`Tel: 202-263-3266
`
`bnesefmayerbrown.com
`
`FOR PATENT HOLDER
`
`STERNE KESSLER GOLDSTEIN FOX
`
`6
`
`7
`
`8 g
`
`id
`
`it
`
`te
`
`is
`
`BY:
`
`JONATHAN TUMINARO, PhD, ESQUIRE
`
`
`
`TYLER J. DUTTON, ESQUTRE
`
`1i00 New York Avenue, NW
`
`Washington, D.C. 20005
`
`14
`
`Tel: 202-371-2600
`
`is
`16
`
`17
`
`ie
`
`is
`
`jtuminar@skgf.com
`
`tdutton@éskgf.com
`
`ROBINS KAPLAN
`
`BY:
`
`AARON R. FAHRENKROG, ESQUIRE
`
`BRYAN J. MECHELE
`
`800 Lasalle Avenue, Suite 2800
`
`20 Minneapolis, MN 55402
`
`Tel: 612-349-0642
`
`ai
`
`22
`
`afahrenkrog@robinskaplan.com
`
`bmechell@robinskaplan.com
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 2
`
`AMD1044_0012460
`
`ATI Ex. 2007
`IPR2023-00922
`Page 2 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 2 of 159
`
`
`
`Laurent Lefebvre
`LG Electronics, Inc. v. ATI Technologies ULC
`11/13/2015
`Confidential - Pursuant to the Protective Order
`
`
`WITNESS:
`
`LAURENT LEFEBVRE
`
`INDEX
`
`EXAMINATION
`
`BY MR.
`
`
`
`NESE
`
`Page 3
`
`PAGE
`
`INDEX OF EXHIBITS
`
`NUMBER
`
`DESCRIPTION
`
`PAGE
`
`Exhibit
`
`1
`
`Laurent Lefebvre Declaration
`
`In IPR2015-00325
`
`
`NW
`Laurent Lefebvre Declaration
`Exhibit
`
`In IPR2015-00326
`
`Exhibit
`
`3
`
`
`Laurent Lefebvre Declaration
`
`In IPR2015-00330
`
`
`
`
`ho
`
`a
`
`4
`
`)
`
`7
`
`g
`
`il
`
`Exhibit
`
`4
`
`R400 Architecture Proposal from
`
`46
`
`Steve Morein
`
`is
`
`Exhibit 5
`
`R400 Sequencer Specification
`
`71
`
`Version 0.4
`
`is
`
`Exhibit
`
`6
`
`Version 2.0 cf the R400
`
`i7
`
`Exhibit
`
`7
`
`United States Patent
`
`sequencer
`
`7,742,053
`
`is
`
`Exhibit
`
`8
`
`Independent Claims of
`
`Patent 7,742,053
`
`al
`
`Exhibit
`
`9
`
`Log File For the R400
`
`Sequencer Emulator Directory
`
`112
`
`112
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 3
`
`AMD1044_0012461
`
`ATI Ex. 2007
`IPR2023-00922
`Page 3 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 3 of 159
`
`
`
`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`UPON COMMENCING AT 9:03 A.M.
`
`IN MONTREAL, QUEBEC,
`
`Page 4
`
`CANADA,
`
`BY THE VIDEOGRAPHER: Good morning.
`
`This is tape number one of the videotaped
`
`deposition of Laurent Lefebvre,
`
`taken by Bryan
`
`Nese of Mayer Brown in the matter of LG
`
`Electronics Inc. versus ATI Technologies ULC.
`
`This case is being held in the United States
`
`Patent and Trademark Office before the Patent
`
`Trial and Appeal Board.
`
`The case number is
`
`TPR2015-00325, 326 and 330. This deposition is
`
`being held at the Omni Hotel
`
`in Montreal, Quebec,
`
`Canada on November 13, 2015.
`
`The time on the
`
`video monitor is 9:03 a.m. and my name is David
`
`i
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`e
`
`9
`
`io
`
`it
`
`te
`
`1s
`
`id
`
`
`
`
`
`
`is Oxilia.
`
`
`T am the legal videographer for Digita:
`
`i6
`
`i?
`
`6
`
`is
`
`Evidence Group.
`
`The Court Reporter is Cherie
`
`
`Klein also with Digital Evidence Group. Will
`
`Counsel please introduce themselves and state
`
`whom you represent.
`
`20
`
`MR. NESE: This is Bryan Nese with
`
`
`
`ai Mayer Brown LLP for Petitioner LG Electronics
`
`ee
`
`
`Inc.
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 4
`
`AMD1044_0012462
`
`ATI Ex. 2007
`IPR2023-00922
`Page4 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 4 of 159
`
`
`
`i
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`2
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`3
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`4
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`S
`
`6
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`7
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`g
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`g
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`io
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`it
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`12
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`is
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`14
`
`is
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`16
`
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`
`
`
`
`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`MR. TUMINARO:
`
`Jonathan Tuminaro
`
`Page 5
`
`from the law firm of Sterne Kessler Goldstein &
`
`Fox on behaif of the patent owner, ATI
`
`Technologies ULC.
`
`MR. FAHRENKROG: Aaron Fahrenkrog
`
`from Robins Kaplan LLP on behalf of the patent
`
`owner ATI Technologies ULC.
`
`MR. MECHELL: Bryan Mechell from
`
`Robins Kaplan LLP on behalf of the patent owner
`
`ATI Technologies ULC.
`
`MR. DUTTON: Tyler Dutton from the
`
`law firm Sterne Kessler Goldstein & Fox on behalf
`
`of the patent owner, ATI Technologies ULC.
`
`BY THE VIDEOGRAPHER:
`
`Thank you. The
`
`court reporter will now swear in the Witness.
`
`WITNESS SWORN
`
`EXAMINATION
`
`BY MR. NESE:
`
`Q.
`
`A.
`
`
`Good morning, Mr. Lefebvre.
`
`Good morning.
`
`i?
`
`18
`
`19
`
`20
`
`ai
`
`ee
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 5
`
`AMD1044_0012463
`
`ATI Ex. 2007
`IPR2023-00922
`Page 5 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 5 of 159
`
`
`
`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`Page 6
`
`i
`
`2
`
`3
`
`4
`
`S
`
`6
`
`7
`
`e
`
`g
`
`Q.
`
`I apologize if throughout the cay I
`
`get
`
`the pronunciation of your name incorrect. My
`
`French is terrible,
`
`so I will thank you to excuse
`
`me. Sir, you are here because you submitted
`
`
`three Declarations in these IPR proceedings.
`
`Is
`
`that right?
`
`A.
`
`Q.
`
`That is correct, yes.
`
`Okay. And I would like to hand you
`
`those now.
`
`So we will mark as Exhibit
`
`1 your
`
`
`io Declaration in IPR2015 325. And unfortunately
`
`it
`
`am not going to have enough samples for everyone
`
`12
`
`is
`
`14
`
`today. Mr. Mechell,
`
`I do have one for you.
`
`I
`
`would also like to mark as Exhibit 2 Mr.
`
`
`Lefebvre's Declaration in IPR2015-00326, and I
`
`is will mark as Exhibit
`
`3 Mr. Lefebvre's Declaration
`
`
`
`
`
`
`16
`
`17
`
`6
`
`19
`
`in TPR2015 330.
`
`Exhibits 1,
`
`2 and 3 were marked for
`
`
`identification.
`
`BY MR. NESE:
`
`20
`
`2i
`
`ee
`
`Q.
`
`Mr. Lefebvre, could you please take
`
`
`a look at these Declarations and confirm that
`
`they are indeed accurate copies of the
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 6
`
`AMD1044_0012464
`
`ATI Ex. 2007
`IPR2023-00922
`Page 6 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 6 of 159
`
`
`
`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`i Declarations that you submitted in these
`
`Page 7
`
`proceedings?
`
`A.
`
`Yes,
`
`these are accurate copies of
`
`tne Declarations that I signed.
`
`Q.
`
`Thank you. Did you write each of
`
`these Declarations?
`
`A.
`
`I did not write these Declarations.
`
`These were written for me by Lawyers working for
`
`
`ATI AMD.
`T did review, however, each and every
`
`one of these Declarations,
`
`read through them all,
`
`provided some comments and corrected
`
`inaccuracies, and as well as reviewed the
`
`calendar, dates and names of everyone cited in
`
`these Declarations.
`
`Q.
`
`But these Declarations are written
`
`im your words; correct?
`
`
`
`
`2
`
`3
`
`4
`
`S
`
`6
`
`7
`
`e
`
`g
`
`16
`
`il
`
`te
`
`1s
`
`i4
`
`15
`
`i6
`
`17
`
`1g
`
`19
`
`
`
`20
`
`2i
`
`Oe
`
`
`
`MR. TUMINARO: Objection.
`
`Form.
`
`THE WITNESS:
`
`They are written in
`
`whoever wrote them words, but
`
`I did review them
`
`for accuracy.
`
`
`
`
`BY MR. NESE:
`
`Q.
`
`Did you receive any compensation for
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 7
`
`AMD1044_0012465
`
`ATI Ex. 2007
`IPR2023-00922
`Page7 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 7 of 159
`
`
`
`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`Page 8
`
`i
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`e
`
`g
`
`io
`
`ii
`
`te
`
`is
`
`i4
`
`is
`
`Signing these ceclarations?
`
`A,
`
`I did not receive any compensation
`
`for signing these Declarations, outside of my
`
`normal salary from AMD,
`
`I mean.
`
`QO.
`
`A.
`
`So no consulting fee?
`
`No, not that FT am aware of.
`
`Just my
`
`regular salary.
`
`Q.
`
`I would hope if you got a consulting
`
`fee, you would be aware of it.
`
`I would want to
`
`be.
`
`no.
`
`A.
`
`I did not receive a consulting fee,
`
`Q.
`
`Sir, other than the documents you
`
`referrec to in your Declarations, did you review
`
`any documents in the course of preparing these
`
`i6 Declarations?
`
`
`
`
`
`
`17
`
`1g
`
`19
`
`20
`
`al
`
`ee
`
`MR. TUMINARO: Objection. Form.
`
`THE WITNESS:
`
`I reviewed the
`
`
`
`documents citec in the Declarations, yes.
`
`BY MR. NESE:
`
`Q.
`
`Did you review any other documents
`
`other than those cited in the Declarations?
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 8
`
`AMD1044_0012466
`
`ATI Ex. 2007
`IPR2023-00922
`Page 8 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 8 of 159
`
`
`
`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`i
`
`2
`
`A,
`
`I did not review directly any other
`
`documents other than those cited in these
`
`3 Declarations.
`
`Page 9
`
`4
`
`S
`
`Q.
`
`Did you indirect_y review any other
`
`documents other than those cited in the
`
`6 Declarations?
`
`7
`
`8
`
`9
`
`A.
`
`I reviewed perforce logs that we
`
`used to build the calendar,
`
`the diligence
`
`calendar, but no.
`
`TI mean,
`
`I just reviewed the
`
`io Declaration documents and that's pretty much it,
`
`il
`
`as well as the Declarations themselves,
`
`12
`
`1s
`
`obviously.
`
`QO.
`
`Are there any errors in your
`
`14 Declarations,
`
`that you are aware of?
`
`
`
`
`
`
`is
`
`A.
`
`T
`
`am aware that a citation is
`
`
`is missing or mislabelled in one of my Declarations
`
`1”
`
`1g
`
`is
`
`
`that I found while reviewing it after the fact,
`
`and that's in the 053 Declaration,
`
`to be exact.
`
`Tt's missing an Exhibit
`
`in the Exhibit list.
`
`20
`
`ai
`
`22
`
`Q.
`
`A,
`
`Q.
`
`You are referring to Exhibit 1?
`
`IT
`
`
`am referring to Exhibit 1.
`
`What is the name of the citation
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 9
`
`AMD1044_0012467
`
`ATI Ex. 2007
`IPR2023-00922
`Page 9 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 9 of 159
`
`
`
`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`Page 10
`
`i
`
`2
`
`3
`
`4
`
`S
`
`6
`
`7
`
`e
`
`g
`
`io
`
`1
`
`12
`
`is
`
`id
`
`is
`
`
`
`
`
`
`that's missing? Excuse me.
`
`I believe you said
`
`that there was an Exhibit missing. Which Exhibit
`
`is missing?
`
`A.
`
`On page 29, Exhibit 2074 is cited,
`
`and it is not present in the list of Exhibits of
`
`that Declaration.
`
`Q.
`
`Thank you for pointing that out.
`
`Are there any other errors that you are aware of
`
`in your Declarations?
`
`A.
`
`IT
`
`am not aware of any other errors
`
`in my Declarations.
`
`Q.
`
`Mr. Lefebvre, have you ever been
`
`deposed before?
`
`A.
`
`T have never been deposed before,
`
`no.
`
`Q.
`
`Okay.
`
`If it's okay with you,
`
`I
`
`would like to go over just a few ground rules for
`
`the deposition,
`
`to make things go a little
`
`smoother today.
`
`Is that all right?
`
`is
`
`i?
`
`is
`
`is
`
`20
`
`al
`
`ee
`
`A.
`
`Q.
`
`Yes, that's all right.
`
`Okay. As you may have noticed there
`
`is a Court reporter here, Ms. Klein. Ms. Klein
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 10
`
`AMD1044_0012468
`
`ATI Ex. 2007
`IPR2023-00922
`Page 10 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 10 of 159
`
`
`
`Laurent Lefebvre
`LG Electronics, Inc. v. ATI Technologies ULC
`11/13/2015
`Confidential - Pursuant to the Protective Order
`
`Page il
`
`i
`
`ho
`
`Go
`
`4
`
`cH
`
`6
`
`7
`
`8
`
`Lo
`
`id
`
`it
`
`12
`
`is
`
`id
`
`is
`
`is going to be taken down everything that I
`
`am
`
`saying as well as everything that you are saying,
`
`and you heard her mention earlier it would be
`
`helpful if we both speak slowly.
`
`Is that okay
`
`with you?
`
`A.
`
`Yes, that's okay with me.
`
`Is this
`
`speed correct? Okay.
`
`QO.
`
`And also, because she needs to take
`
`down everything we are both saying, we need to
`
`have verbal statements on the record.
`
`So today
`
`can you make sure to give me verbal responses to
`
`the questions that IT will be asking you?
`
`A.
`
`Yes.
`
`I will make every effort to
`
`give you a verbal response to any questions that
`
`you ask me.
`
`Q.
`
`And also it would be helpful for Ms.
`
`Klein if we don't talk over each other.
`
`I will
`
`try to co my best not to talk over you.
`
`Can you
`
`try to do your best not to talk over me?
`
`
`
`
` g
`
`16
`
`17
`
`is
`
`is
`
`20
`
`al
`
`ee
`
`A.
`
`Q.
`
`Absolutely.
`
`I will do my best.
`
`Wonderful.
`
`I typically take breaks
`
`every hour or so.
`
`If you need a break before
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 11
`
`AMD1044_0012469
`
`ATI Ex. 2007
`IPR2023-00922
`Page 11 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 11 of 159
`
`
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`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`1
`
`2
`
`3
`
`4
`
`S
`
`6
`
`7
`
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`
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`tnat,
`
`for any reason, please feel free to Let me
`
`Page 12
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`know.
`
`A.
`
`Q.
`
`Yes.
`
`The only thing I would ask is if we
`
`are in the middle of a question,
`
`I just would
`
`like you to fully answer a question before we go
`
`on the break.
`
`Is that okay?
`
`A.
`
`Q.
`
`Yes,
`
`From time to time you may hear your
`
`Lawyer, Mr. Tuminaro, make objections to some of
`
`the questions that I am asking. However, unless
`
`he specifically instructs you not to answer a
`
`question,
`
`I still need an answer to the question.
`
`Can you do that for me?
`
`A.
`
`Yes,
`
`I will answer the questions
`
`unless advised not
`
`to by my Counsel.
`
`QO.
`
`Great.
`
`The last thing is that the
`
`Patent Trial and Appeal Board has a rule that
`
`prohibits Witnesses from talking about their
`
`
`
`i?
`
`is
`
`is
`
`20
`
`al
`
`testimony with their Lawyers while a deposition
`
`is going on, and that includes during the breaks.
`
`Oe Will you abide by that rule today?
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 12
`
`AMD1044_0012470
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`ATI Ex. 2007
`IPR2023-00922
`Page 12 of 159
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`ATI Ex. 2007
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`IPR2023-00922
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`
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`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`Page 13
`
`i
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`3
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`5
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`6
`
`7
`
`A,
`
`QO.
`
`Yes,
`
`I will obey by that rule today.
`
`Thank you. Sir, what did you do to
`
`prepare for today's deposition?
`
`A.
`
`For today's deposition I had several
`
`discussions with the Attorneys team. Like stated
`
`before,
`
`I reviewed the specifications listed as
`
`Exhibits in my Declaration.
`
`I aiso reviewed
`
`
`g Declarations for -- reviewed the perforce logs to
`
`9
`
`id
`
`ii
`
`make sure that all of the dates and change list
`
`numbers were correct as best to my knowledge and
`
`
`obviously,
`lixe I said,
`reviewed the Declaration
`
`te
`
`is
`
`
`
`
`
`
`and also reviewed a little bit of the RTL code
`
`that was created at the time.
`
`Q.
`
`When you say you reviewed the RTL
`
`code that was created at the time, what are you
`
`referring to?
`
`A.
`
`I
`
`am referring to the
`
`
`sq-thread_arb.v file which is presented as an
`
`Exhibit
`
`to 074 and 2097 in my Declarations.
`
`id
`
`is
`
`i6
`
`i?
`
`is
`
`is
`
`20
`
`ai
`
`QO.
`
`So did you review any other RTL code
`
`
`other than the Exhibits that are in your
`
`ee Declarations?
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 13
`
`AMD1044_0012471
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`ATI Ex. 2007
`IPR2023-00922
`Page 13 of 159
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`ATI Ex. 2007
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`IPR2023-00922
`Page 13 of 159
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`26
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`ee
`
`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`i
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`2
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`3
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`S
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`MR. TUMINARO: Objection.
`
`Form.
`
`THE WITNESS: Not that I recall,
`
`neo.
`
`Page 14
`
`BY MR. NESE:
`
`QO.
`
`Okay.
`
`You also said you had
`
`discussions with your Lawyers, and I don't want
`
`you to reveal any of the substance of the
`
`discussions that you had with your Lawyers, but
`
`can you tell me who you met with?
`
`A.
`
`As best of my knowledge,
`
`IT met with
`
`everyone in the room today. More often with
`
`Jonathan, because he was my primary contact, but
`
`T had like discussions with every Lawyer present
`
`in the room today. Bryan, Tyler, Aaron and
`
`Jonathan.
`
`Q.
`
`Except for me; right? We didn't
`
`have any discussions before this; right?
`
`A.
`
`Outside of today, no.
`
`I have never
`
`
`talked to you before.
`
`Q.
`
`A.
`
`Q.
`
`You haven't had the pleasure yet.
`
`Not yet.
`
`Did you meet with any other Lawyers
`
`other than the four Attorneys who are
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 14
`
`AMD1044_0012472
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`ATI Ex. 2007
`IPR2023-00922
`Page 14 of 159
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`ATI Ex. 2007
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`IPR2023-00922
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`
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`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`Page 15
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`it
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`te
`
`is
`
`representing ATI Technologies here today?
`
`MR. TUMINARO: Objection.
`
`Form.
`
`
`
`THE WITNESS:
`
`I had some discussions
`
`with the internal Counsel of AMD, which I don't
`
`know if they are Lawyers or not.
`
`Probably, but
`
`outside of this Counsel and the AMD
`
`representative of the legal departments; no,
`
`I
`
`did not have any other discussions that I recall.
`
`BY MR. NESE:
`
`Q.
`
`And when did you have these meetings
`
`with your Lawyers to prepare for your deposition
`
`today?
`
`A.
`
`We met once in person last year in
`
`
`
`
`
`
`i4 Montreal,
`
`then two more times at my house.
`
`If I
`
`is
`
`is
`
`i?
`
`is
`
`is
`
`
`recall correctly it was some time last year and
`
`the year before. And we also met yesterday again
`
`in Montreal.
`
`Q.
`
`And was it Mr. Tuminaro that you met
`
`with a year ago in Montreal?
`
`20
`
`ai
`
`ee
`
`MR. TUMINARO: Objection to the
`
`extent it calls for work product, and I
`
`am going
`
`to instruct the Witness not to answer.
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 15
`
`AMD1044_0012473
`
`ATI Ex. 2007
`IPR2023-00922
`Page 15 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 15 of 159
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`
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`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`i
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`2
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`3
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`4
`
`S
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`6
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`10°
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`il
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`12
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`id
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`is
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`
`
`
`
`
`THE WITNESS:
`
`I am going to follow
`
`Page 16
`
`my legal counsel and not answer that question.
`
`BY MR. NESE:
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Are you currently employed?
`
`Yes,
`
`I am currently employed.
`
`Who is your current employer?
`
`My current employer is AMD
`
`Incorporated in Markham -- Toronto, Ontario.
`
`Q.
`
`And what is your current position at
`
`AMD?
`
`A,
`
`My current position is a fellow
`
`position in hardware graphics architecture.
`
`Q.
`
`And what are your current
`
`
`responsibilities as a fellow in hardware graohics
`
`and architecture?
`
`A.
`
`My current responsibilities include
`
`specifying and measuring performance of the
`
`various graphics products that AMD does today.
`
`I
`
`am also responsible to answer questions by
`
`i6
`
`i?
`
`is
`
`is
`
`20
`
`al
`
`ee
`
`customers and meet with them to go over hardware
`
`
`graphic specifications.
`
`I am also the primary
`
`contact for the graphics team to the internal AMD
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 16
`
`AMD1044_0012474
`
`ATI Ex. 2007
`IPR2023-00922
`Page 16 of 159
`
`ATI Ex. 2007
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`IPR2023-00922
`Page 16 of 159
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`
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`12
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`1s
`
`14
`
`15
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`
`
`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`Page 17
`
`APU team,
`
`so to understand and answer any
`
`questions the SoC teams might have in the --
`
`during the creation of the SOC's. And I am
`
`responsible to give the executive boards as well
`
`as AMD executives performance, power and area
`
`estimates for a variety of the graphics
`
`processors that AMD develops internally and
`
`externally.
`
`MR. TUMINARO: Bryan, at this time I
`
`am going to designate the transcript confidential
`
`under the Protective Order,
`
`to the extent
`
`confidential
`
`information is coming up.
`
`MR. NESE: Okay.
`
`BY MR. NESE:
`
`Q.
`
`A.
`
`What do you mean by SOC's?
`
`So SOC is an acronym that means
`
`system on a chip.
`
`It's a new flavour of graphic
`
`-- of chips that we do at AMD where everything
`
`from the CPU to the graphic core to multimedia
`
`components is integrated into a single silicon
`
`device to save costs, and area and power.
`
`is
`
`i?
`
`6
`
`is
`
`20
`
`al
`
`22
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 17
`
`AMD1044_0012475
`
`ATI Ex. 2007
`IPR2023-00922
`Page 17 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 17 of 159
`
`
`
`Laurent Lefebvre
`LG Electronics, Inc. v. ATI Technologies ULC
`11/13/2015
`Confidential - Pursuant to the Protective Order
`
`Page 18
`
`QO.
`
`Do your current responsibilities as
`
`a fellow in hardware, graphics and architecture
`
`reguire the writing of source code?
`
`A.
`
`My current responsibilities do not
`
`require me to write any RTL source code nor C sim
`
`per se;no -- C Simulation -- Ct.
`
`QO.
`
`How long have you had the position
`
`of a fellow in hardware, graphics and
`
`architecture?
`
`A.
`
`I believe,
`
`if I am recalling
`
`correctly,
`
`I was promoted in September 2013.
`
`Q.
`
`A.
`
`When did you begin working for AMD?
`
`I started working for AMD in
`
`September of 2000 right out of school, where I
`
`moved to Boston to work for the Marlboro office.
`
`Go
`
`(Ht
`
`Oo
`
`Oo
`
`Lo
`
`io
`
`it
`
`12
`
`is
`
`id
`
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`
`i6 Actually, back then it was called ATI
`
`
`
`
`
`
`1”
`
`is
`
`is
`
`20
`
`al
`
`Oe
`
`Technologies,
`
`to be correct.
`
`Q.
`
`Thank you, and I understand the two
`
`companies merged in 2006. And at that time did
`
`
`you begin worxing for AMD?
`
`A,
`
`So to be completely fair,
`
`I was an
`
`
`ATI employee from September 2002 to January --
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 18
`
`AMD1044_0012476
`
`ATI Ex. 2007
`IPR2023-00922
`Page 18 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 18 of 159
`
`
`
`
`
`
`is
`
`i6
`
`i?
`
`6
`
`is
`
`20
`
`ai
`
`ee
`
`Laurent Lefebvre
`LG Electronics, Inc. v. ATI Technologies ULC
`11/13/2015
`Confidential - Pursuant to the Protective Order
`
`Page 19
`
`ho
`
`Go
`
`(Ht
`
`Oo
`
`Oo
`
`Lo
`
`id
`
`il
`
`12
`
`is
`
`id
`
`
`
`sorry -- from September 2000 to January 2003, at
`
`which point
`
`I moved to Montreal and became a
`
`contractor who worked for ATI but as an external
`
`contractor. And then in September of 2007,
`
`if
`
`memory serves me right,
`
`then AMD, which at the
`
`time bought ATI before, rehired me as a permanent
`
`employee from Markham.
`
`Q.
`
`So you mentioned you began working
`
`for ATI right out of school.
`
`Do you hold any
`
`degrees?
`
`A,
`
`IT hold two degrees.
`
`One of them is
`
`an engineering degree in computer science from
`
`the Ecole Polytechnique of Montreal right here,
`
`and the second degree that
`
`I own is a master's
`
`degree in computer graphics from the University
`
`of Montreal.
`
`QO.
`
`And when did you get your
`
`engineering degree in computer science?
`
`A.
`
`So my degree in computer engineering
`
`and computer science would have been granted
`
`around June of 1998.
`
`Q.
`
`And it that when you got your ring
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 19
`
`AMD1044_0012477
`
`ATI Ex. 2007
`IPR2023-00922
`Page 19 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 19 of 159
`
`
`
`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`Page 20
`
`i
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`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`g
`
`g
`
`on the pinky finger of your working hand?
`
`A.
`
`That is about when I got my ring,
`
`maybe a bit before, because the ceremony occurs a
`
`bit before the graduation.
`
`Q.
`
`And after June 1998 did you go to
`
`grad school full-time, working on your masters?
`
`A.
`
`Yes. Right after I was -- I
`
`received my degree from Ecole Polytechnique I
`
`joined full-time the computer science lab in
`
`io University of Montreal
`
`to work on my masters for
`
`it
`
`wo years.
`
`
`
`i?
`
`16
`
`is
`
`
`
`
`12
`
`is
`
`id
`
`15
`
`i6
`
`Q.
`
`Mr. Lefebvre, when did you first
`
`hear about these proceedings?
`
`A.
`
`T don't really recall the exact
`
`date,
`
`to be honest.
`
`It -- yes.
`
`Probably two,
`
`three years ago. Around that time.
`
`I cannot be
`
`more precise than that.
`
`I don't really recall.
`
`Q.
`
`How did you first hear about these
`
`proceedings?
`
`20
`
`2i
`
`ee
`
`MR. TUMINARO:
`
`I am just going to
`
`caution the Witness not
`
`to disclose the substance
`
`of any communications you may have had with
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 20
`
`AMD1044_0012478
`
`ATI Ex. 2007
`IPR2023-00922
`Page 20 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 20 of 159
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`
`
`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`Page 21
`
`i
`
`2
`
`3
`
`4
`
`Counsel. You can answer how you learned about
`
`these proceedings.
`
`THE WITNESS:
`
`If memory serves,
`
`I
`
`think it's either Jonathan or Bryan tnat called a
`
`5 meetina through AMD legal department that I was
`
`6
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`7
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`g
`
`3
`
`id
`
`ii
`
`needed to, you know, depose,
`
`to talk about --
`
`MR. TUMINARO: Don't talk about the
`
`substance.
`
`Just how did you learn about it.
`
`THE WITNESS: Yes.
`
`BY MR. NESE:
`
`Q.
`
`You believe it was either Mr.
`
`12 Mechell or Mr. Tuminaro that first told you about
`
`
`
`
`
`
`is
`
`i4
`
`15
`
`16
`
`i?
`
`6
`
`19
`
`these proceedings two to three years ago.
`
`Is
`
`that right?
`
`A.
`
`Q.
`
`That is T what
`
`I recall; yes.
`
`I would like to talk about
`
`the
`
`industry you are involved in for a little bit.
`
`Do you have an understanding of how graphics
`
`
`
`processors are designed?
`
`20
`
`al
`
`ee
`
`A.
`
`I have a very good idea of how
`
`graphics processors are designed; yes, given this
`
`is what we have been doing for 15 years now.
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 21
`
`AMD1044_0012479
`
`ATI Ex. 2007
`IPR2023-00922
`Page 21 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 21 of 159
`
`
`
`Laurent Lefebvre
`LG Electronics, Inc. v. ATI Technologies ULC
`11/13/2015
`Confidential - Pursuant to the Protective Order
`
`
`Page 22
`
`Q.
`
`And can you walk me through how
`
`engineers typically design a graphics process
`
`or?
`
`MR. TUMINARO: Objection.
`
`Form.
`
`THE WITNESS:
`
`So the typical flo
`
`w of
`
`
`
`
`ho
`
`Go
`
`(Ht
`
`Oo
`
`Oo
`
`Lo
`
` g
`
`20
`
`21
`
`development is the writing -- in development
`
`starts with the writing of architectural
`
`specifications where architects meet and disc
`
`uSS,
`
`you know,
`
`the various features that are neede
`
`do in
`
`the chip. After specifications are drafted we go
`
`and write C++ code to simulate these
`
`specifications and start understanding the ru
`
`les
`
`and capabilities, and at the same time RTL
`
`developers start to write the register transf
`
`er
`
`layer code for the chip. This code is then
`
`synthesized and turned into what we call gate
`
`level net lists, which are sent to physical
`
`design for place and route, and finally send
`
`Co
`
`Fab's for fabrication.
`
`BY MR. NESE:
`
`Q.
`
`SO you mentioned that there are
`
`there is C++ code for simulation.
`
`Is that ri
`
`ght?
`
`A.
`
`That is correct.
`
`AMD uses a CH+t
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`Ex. 1035, pg 22
`
`LG
`
`AMD1044_0012480
`
`ATI Ex. 2007
`IPR2023-00922
`Page 22 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 22 of 159
`
`
`
`
`
`
`
`
`that the same person cannot
`
`introduce the same
`
`error in botn the register transfer layer and the
`
`code that is used to validate that code.
`
`So
`
`typically the architect is the person that's
`
`Laurent Lefebvre
`LG Electronics, Inc. v. ATI Technologies ULC
`11/13/2015
`Confidential - Pursuant to the Protective Order
`
`model that we call the reference model to be used
`
`Page 23
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`as a check environment so that the people that
`
`write the RTL code can verify for themselves
`
`against a golden medel.
`
`QO.
`
`You also mentioned that there is
`
`register transfer level code written, RTL.
`
`Is
`
`that right?
`
`A.
`
`Yes.
`
`In order to produce a chip the
`
`main element that is needed is the source
`
`
`register transfer layer code.
`
`Q.
`
`Will the same engineer or a group of
`
`1
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`Go
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`4
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`an
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`Oo
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`7
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`Lo
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`id
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`it
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`engineers usually write -- let me start over. My
`
`
`apologies. Will the same engineer or engineering
`
`team write both the C++ code and the RTL code?
`
`A.
`
`At AMD we strongly try not to,
`
`so
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`12
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`is
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`going to write the specification as well as the C
`
`simulation version of that block, and another
`
`person or another group of persons would write
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 23
`
`AMD1044_0012481
`
`ATI Ex. 2007
`IPR2023-00922
`Page 23 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 23 of 159
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`
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`i?
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`is
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`19
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`ee
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`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`i
`
`2
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`3
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`4
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`5
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`6
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`7
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`Page 24
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`the register transfer layer.
`
`Q.
`
`I would like to know more about this
`
`synthesis process that you described.
`
`Can you
`
`give me some more detail about what's involved in
`
`the gate level net list?
`
`MR. TUMINARO: Objection,
`
`form.
`
`THE WITNESS:
`
`Synthesis 18 a process
`
`-- is an automated process by which a tool takes
`
`
`the register transfer layer source code and
`
`transforms it into gates which are, you know,
`
`"and gates", or "or gates" or whatever gates are
`
`available into the physical library that the PD
`
`team will use to fabricate the chip. This flow
`
`is fully automated, and there is no human
`
`intervention needed to go from the RTL to the
`
`gate level simulation.
`
`There is also a formal
`
`validation tool that is provided by the company
`
`
`
`to formally validate
`that does the synthesis tool
`
`that the generated gates are eguivalent to the
`
`RTL code.
`
`
`
`
`BY MR. NESE:
`
`Q.
`
`How long does this synthesis process
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 24
`
`AMD1044_0012482
`
`ATI Ex. 2007
`IPR2023-00922
`Page 24 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 24 of 159
`
`
`
`
`
`
`
`
`i?
`
`6
`
`19
`
`20
`
`al
`
`Oe
`
`Laurent Lefebvre
`LG Electronics, Inc. v. ATI Technologies ULC
`11/13/2015
`Confidential - Pursuant to the Protective Order
`
`Page 25
`
`ho
`
`Go
`
`(Ht
`
`Oo
`
`Oo
`
`Lo
`
`id
`
`it
`
`12
`
`is
`
`id
`
`is
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`is
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`take?
`
`A,
`
`The synthesis time varies based on
`
`the size of each block.
`
`It can go from anywhere
`
`between one hour to 24 hours, depending on really
`
`the size of the design that you are trying to
`
`synthesize.
`
`Q.
`
`And how does a company know that its
`
`RTL code has been synthesized properly?
`
`MR. TUMINARO: Objection,
`
`form.
`
`THE WITNESS: Like I said,
`
`the
`
`company that provides the synthesis tool also
`
`provides a formal equivalence tool that verifies
`
`-- that the generated gates are fully -- formaliy
`
`equivalent to the RTL code.
`
`So after the
`
`synthesis tool is run, we run this tool and, if
`
`any errors or any issues are found,
`
`then the tool
`
`is flagging them and you know, we file a bug to
`
`the company that writes the synthesis tool so
`
`that it can be fixed.
`
`I mean, omce you pass the
`
`formal compliance tool you are guaranteed that
`
`the gates that you generated are equivalent
`
`to
`
`the RTL.
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 25
`
`AMD1044_0012483
`
`ATI Ex. 2007
`IPR2023-00922
`Page 25 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 25 of 159
`
`
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`
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`i?
`
`is
`
`is
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`20
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`ai
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`ee
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`11/13/2015
`LG Electronics, Inc. v. ATI Technologies ULC
`Laurent Lefebvre
`Confidential - Pursuant to the Protective Order
`
`
`Page 26
`
`i
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`2
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`3
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`4
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`5
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`6
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`7
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`e
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`9
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`16
`
`it
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`te
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`is
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`14
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`
`
`BY MR. NESE:
`
`Q.
`
`So if the compliance tool finds a
`
`bug, who fixes it?
`
`Is it the team that wrote the
`
`RTL code, or is it synthesis team,
`
`the validation
`
`team,
`
`the Fab?
`
`A.
`
`So typically the tool will just file
`
`warnings that -- meaning that some gates are --
`
`could be different than what the code really
`
`wanted to do.
`
`So you can go two ways with this.
`
`Once you find one of this,
`
`the RTL code team
`
`could just rewrite the portion of the code that
`
`is problematic in such a way that it's simpler to
`
`synthesize and did not raise this issue. We have
`
`also found issues with the tool itself,
`
`in which
`
`case the company that provides the tool needs to
`
`go and fix the issue in the tool.
`
`QO.
`
`In a typical design process how
`
`often does the validation tool find a bug and
`
`then that requires the RTL team to rewrite some
`
`of the code?
`
`A.
`
`I don't really know how often.
`
`I
`
`know it occurs, but since I was not the person
`
`www .DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2015
`
`202-232-0646
`LG Ex. 1035, pg 26
`
`AMD1044_0012484
`
`ATI Ex. 2007
`IPR2023-00922
`Page 26 of 159
`
`ATI Ex. 2007
`
`IPR2023-00922
`Page 26 of 159
`
`
`
`Laurent Lefebvre
`LG Electronics, Inc. v. ATI Technologies ULC
`11/13/2015
`Confidential - Pursuant to the Protective Order
`
`Page 27
`
`
`
`
`ho
`
`Go
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