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`UNITED STATES INTERNATIONAL TRADE COMMISSION
`
`WASHINGTON, D.C.
`
`Before The Honorable MaryJoan McNamara
`
`Administrative Law Judge
`INVESTIGATION NO. 337-TA-1044
`KR KK KR KK KR OKO
`
`wk
`
`ke
`
`kK
`
`kK
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`Ke KK KR
`
`IN THE MATTER OF
`
`CERTAIN GRAPHICS SYSTEMS, COMPONENTS
`
`THEREOF, AND CONSUMER PRODUCTS
`
`CONTAINING THE SAME,
`
`commencing at 9:00 a.m.
`
`AUDIO-VISUAL DEPOSITION OF LAURENT LEFEBVRE,
`
`a
`
`witness called on behalf of the Respondents, LG
`
`Electronics,
`
`Inc., LG Electronics U.S.A.,
`
`Inc. and LG
`
`Electronics MobileComm U.S.A.,
`
`Inc. pursuant
`
`to 19
`
`C.F.R. 210.27 and 210.28 and Rule 3.4.1 (Order No. 2),
`
`before Lisa McDonald Valdario,
`
`(CSR #130093),
`
`a
`
`Registered Professional Reporter, Certified Realtime
`
`Reporter, and Notary Public in and for the
`
`Commonwealth of Massachusetts, at the Offices of
`
`Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.,
`
`One Financial Center, 38th Floor, Boston,
`
`Massachusetts
`
`02111, on Wednesday,
`
`June 28, 2017,
`
`VERITEXT NATIONAL COURT REPORTING COMPANY
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`ATI Ex. 2102
`IPR2023-00922
`Page 1 of 312
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`ATI Ex. 2102
`IPR2023-00922
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`

`

`APPEARANCES:
`
`FISH & RICHARDSON, P.C.
`
`McPherson Building
`901 15th Street NW, 7th floor
`Washington, D.C. 20005
`BY: Scott Elengold, Esquire
`elengold@fr.com
`202.783.5070
`
`Attorney for the LG Respondents
`
`MCGUIRE WOODS, LLP
`
`Gateway Plaza
`800 East Canal Street
`
`23219
`Richmond, Virginia
`BY:
`Justin R. Lowery, Esquire
`jlowery@mcguirewoods.com
`804.775.1000
`
`ALSO PRESENT: Marissa Demonte, video operator
`
`Attorney for the Respondents,
`MediaTek and Sigma Designs,
`Inc.
`
`MINTZ, LEVIN, COHN, FERRIS, GLOVSKY AND POPEO, P.C.
`One Financial Center
`
`Boston, Massachusetts
`
`02111
`
`BY: Michael T. Renaud, Esquire
`mtrenaud@mintz.com
`617.348.1870
`
`and Adam Rizk, Esquire
`arizk@mintz.com
`
`Attorney for the Complainants,
`Advanced Micro Devices,
`Inc. and ATI Technologies
`
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`

`

`WITNESS
`
`DIRECT
`
`CROSS
`
`REDIRECT
`
`RECROSS
`
`INDEX
`
`LAURENT LEFEBVRE
`
`BY MR. ELENGOLD
`
`252733
`
`EXHIBIT S5
`
`No.
`
`Description
`
`Exhibit
`
`Respondents' Notice of Deposition of
`
`Laurent Lefebvre
`
`Exhibit
`
`Respondents' First Notice of Deposition
`
`to Complainants Advanced Micro Devices,
`
`and ATI Technologies ULC
`
`Exhibit
`
`R400 Architecture Proposal ver 0.1,
`
`AMD1044_ 0175470 to 485
`
`Exhibit
`
`Transcript of testimony of Mr. Lefebvre
`
`from 11/13/15, AMD1044 12459 to 12617
`
`Exhibit
`
`Transcript of testimony of Mr. Lefebvre
`
`from 11/9/16, AMD1044 175035 to 175287
`
`Exhibit
`
`Declaration of Inventor Laurent Lefebvre
`
`Regarding the Invention Date of U.S. Patent
`
`No. 6,897,871
`
`AMD1044 11617 to 11682
`
`Exhibit
`
`Signature page and errata sheets for
`
`11/13/15 deposition, AMD1044 252730 to
`
`VERITEXT NATIONAL COURT REPORTING COMPANY
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`IPR2023-00922
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`

`

`EX HIBItTS§
`
`No.
`
`Description
`
`Exhibit
`
`Errata sheets for 12/9/16 deposition,
`
`AMD1044_ 0252728 to 252729
`
`Exhibit
`
`R400 August Program Review Summary,
`
`AMD1044 175191 to 175196
`
`Exhibit
`
`R400 Sequencer Specification SEQ,
`
`version 0.42, AMD1044 175216 to 175235
`
`Exhibit
`
`Complainants' Notice of Patent Priority
`
`Dates
`
`Exhibit
`
`U.S. Patent No. 8,760,454
`
`Exhibit
`
`U.S. Patent No. 9,582,846
`
`*** EXHIBITS SENT TO VERITEXT FOR DISTRIBUTION ***
`
`Exhibit
`
`Xenos Sequencer Specification SQ,
`
`Version 3.0, AMD1044 226797 to 851
`
`Exhibit
`
`Complainants Advanced Micro Devices,
`
`Inc. and ATI Technologies ULC's First
`
`Supplemental Responses and Objections to
`
`Respondents LG and Vizio's First Set of
`
`Joint Interrogatories (Nos. 5-8, 12, 18, 34,
`
`49, 51-52, 65-66, 70-71)
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`PROCEEDINGS
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`Page 5
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` VIDEO OPERATOR: Good morning. We are now
`
`
`
`recording and on the record. My name is Marissa
`
`Demonte representing Veritext Mid Atlantic Region.
`
`The date today is June 28, 2017.
`
`The time is 9:00
`
`a.m. This deposition is being held in the Office
`
`of Mintz, Levin located at One Financial Center,
`
`Boston, Massachusetts.
`
`This deposition is being taken In the Matter
`
`of: Certain Graphics Systems Components Thereof,
`
`and Consumer Products Containing the Same,
`
`filed
`
`with the United States Trade Commission.
`
`The name of the witness is Laurent Lefebvre.
`
`At this time,
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`the attorneys will
`
`identify
`
`
`
`Technologies along with Adam Rizk, both of Mintz,
`
`Woods on behalf of the MediaTek and Sigma
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`MR. RENAUD: Michael Renaud on behalf of the
`
`Complainants, Advanced Micro Devices Inc. and ATI
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`VERITEXT NATIONAL COURT REPORTING COMPANY
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`ATI Ex. 2102
`IPR2023-00922
`Page 5 of 312
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`themselves and the parties they represent, after
`
`which our court reporter, Lisa Valdario, will
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`swear in t witness and we can proceed.
`
`
`MR. ELENGOLD: Scott Elengold with Fish &
`
`Richardson on behalf of the LG Respondents.
`
`LOWERY:
`
`Justin Lowery with McGuire
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`MR.
`
`
`
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`Respondents.
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`ATI Ex. 2102
`IPR2023-00922
`Page 5 of 312
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`

`

`LAURENT LEFEBVRE
`
`A witness called for examination, having been
`
`duly sworn,
`
`testified as follows:
`
`DIRECT EXAMINATION
`
`BY MR. ELENGOLD:
`
`Good morning, Mr. Lefebvre.
`
`Good morning.
`
`and plan the future products of AMD, and also
`
`Could you please state your full name for the
`
`record.
`
`Laurent Lefebvre.
`
`And I'll try my best to get that name correct
`
`today as we go, sir. What is your current home
`
`address?
`
`My current home address is
`
`Mr. Lefebvre, what is your current employment?
`
`I
`
`am currently employed by ATI,
`
`a subsidiary of
`
`AMD, as a hardware fellow.
`
`What is a hardware fellow?
`
`It is a title we give to engineers at AMD.
`
`What is your current responsibilities in your
`
`employment?
`
`Currently, my responsibilities are to configure
`
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`Page 7
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`scope the performance area and power that said
`
`products would use.
`
`What
`
`types of products do you work with?
`
`I work on GPUs, which are graphics processers,
`
`APUs, which are integrated graphics processers on
`
`Socs, as well as scope -- SCBUs, semi-custom
`
`business unit products to be embedded in various
`
`customer products.
`
`
`MR. RENAUD:
`
`I'm going to designate the
`
`transcript as highly confidential under the
`
`protective order and I would just say to Laurent,
`
`just go a little bit slower.
`
`you
`ever been deposed before, Mr. Lefebvre?
`
`Have
`
`Yes,
`
`I have been deposed twice.
`
`Do you remember approximately when each of those
`
`depositions were taken?
`
`I
`
`remember the most recent deposition was taken in
`
`December of last year, and the one before occurred
`
`some time before that, but
`
`I don't exactly recall
`
`when.
`
`products, as well as my previous deposition.
`
`What was the subject matter of your December 2016
`
`deposition?
`
`If memory serves, it was about
`
`the unified shader
`
`patent and some specifications on the R400
`
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`Page 8
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`What was the subject matter of your previous
`
`deposition?
`
`
`MR. RENAUD: Objection.
`
`So my memory is more fuzzy on that one, but it was
`
`also on some form of unified shader patent.
`
`I
`
`think it did include another patent which was more
`
`directed to the sequencer itself, and my testimony
`
`was also part of that deposition, and again,
`
`various specifications of the R400 product.
`
`Have you ever testified at a trial before?
`
`No,
`
`I have not.
`
`And are you
`
`Lefebvre?
`
`represented by counsel here today, Mr.
`
`I'm not aware of any reason.
`
`
`
`
`MR. ELENGOLD: Objection.
`
`I
`
`am represented by counsel
`
`today, yes.
`
`So I know you've been deposed twice now, but
`
`I
`
`just wanted to go over a couple ground rules with
`
`you if that's okay.
`
`Do you understand that you've
`
`sworn to provide truthful and complete responses
`
`to my questions today as if you were in a court of
`
`law?
`
`Yes,
`
`I understand.
`
`Are you aware of any reasons why you cannot give
`
`truthful and complete testimony today?
`
`No,
`
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`As we're going through the day, please ask for any
`
`clarification you have with regard to my question,
`
`and if you answer it, I'll assume you understand
`
`Page 9
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`it.
`
`Is that okay?
`
`That is okay.
`
`And if at any time you need to take a break, don't
`
`hesitate to ask.
`
`If there is a question pending,
`
`T'll ask that you try to answer the question to
`
`the best of your ability, but if you need a break
`
`at any time, please just let me know.
`
`I will.
`
`And finally, please try your best
`
`to answer my
`
`questions audibly as we go through the day just so
`
`the court reporter can get a clean record to your
`
`responses to my questions.
`
`I understand.
`
` Earlier, when we were talking about
`
`the products
`
`that you're currently working with, you mentioned
`
`I believe GPUs, APUs and SOC,
`
`is that correct?
`
`That's what
`
`I
`
`remember my answer was, yes, but we
`
`can go through the transcript if you want.
`
`I'm just trying to bring you back to there so I
`
`can ask a follow-up question if that's okay.
`
`I would like to ask you is what is
`
`That is okay.
`
`And really what
`
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`difference
`between
`
`the
`
`each of those three types
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`Page 10
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`of products?
`
`MR. RENAUD: Objection.
`
`restate
`the
`thr
`types of products so I
`
`Can we
`
`get my answer as clear as possible?
`
`Why don't we take them one at a time. What is
`
`GPU?
`
`Okay.
`
`processing unit.
`
`So the GPU acronym stands for graphics
`
`This is typically a distinct
`
`
`
`
`
`A GPU is a piece of hardware that performs
`
`device that you put into a computer that is
`
`responsible for performing graphics on the
`
`computer,
`
`that is generating images that you see
`
`on your computer.
`
`What is an APU?
`
`APU is an internal acronym at AMD we use that
`
`
` all of the components of the computer are
`
`stands for accelerated processing unit.
`
`Similar to a GPU, but
`
`It's
`
`the main difference is that
`
`integrated on a single chip;
`
`that is,
`
`the CPU and
`
`the GPU are integrated on a single chip, which is
`
`why we call it an APU versus a GPU.
`
`so GPU is dedicated to graphics processing,
`
`is
`
`that right?
`
`
`MR. RENAUD: Objection.
`
`A
`
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`graphics that does not contain a CPU.
`
`What
`
`is an SOC?
`
`An SOC is the fabric,
`
`if you will,
`
`that allows us
`
`to integrate multiple IPs on a single chip.
`
`The
`
`acronym stands for system on chip,
`
`so it's the
`
`fabric that allows to connect and integrate
`
`everything on a single piece of silicon.
`
`Does an SOC contain a GPU?
`
`Soc stands for system on a chip.
`
`It can contain
`
`An SOC is really the process by which we generate
`
`
`
`whatever you want it to contain.
`
`Can an APU contain a GPU?
`
`
`MR. RENAUD: Objection.
`
`An APU and a GPU are different products,
`
`so an APU
`
`can contain graphics processing,
`
`a graphics core,
`
`but it doesn't have to have all the capabilities
`
`of a discrete GPU.
`
`Are they different chips,
`
`an APU and a GPU?
`
`Can you define what you mean by chip?
`
`Do you mean
`
`different pieces of silicon?
`
`Yes.
`
`So yes,
`
`they would be specific different pieces of
`
`silicon.
`
`And an SOC would be a different piece of silicon
`
`or a different chip too?
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`Page 12
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`an APU,
`
`so it can be used by an APU, but it can
`
`also be another piece of silicon if you want it to
`
`be.
`
`And approximately how much of your current
`
`time is
`
`spent working on graphics?
`
`Can you define what you mean by graphics?
`
`It's a
`
`pretty generic term.
`
`Sure. Why don't we come back to that, and first
`
`let me ask you a couple questions about
`
`today.
`
`So when did you find out you were going to
`
`deposed today?
`
`again,
`
`I'm speaking from memory here so excuse
`
`my dates are not exact.
`
`I
`
`remember late 2016
`
`early 2017 receiving a call from Adam.
`
`
`MR. RENAUD:
`
`And you can -- instruct you not
`
`communications.
`
`
`
`provide any content of the call.
`
`THE WITNESS:
`
`sure.
`
`And that made me aware of this pending litigation,
`
`and then I met with counsel several
`
`times since
`
`that date.
`
`Do you have an understanding of what this case is
`
`about?
`
`
`MR. RENAUD: Objection.
`
`You may answer so
`
`long as you don't reveal any attorney/client
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`I understand it's some ki
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`third parties and AMD.
`
`nd of litigation between
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`Page 13
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`Do you understand what kind of litigation?
`
`MR. RI
`
` ENAUD:
`
`Same i
`
`answer so long as you do
`
`attorney/client communica
`
`nstruction.
`
`You may
`
`not reveal any
`
`tions.
`
`So I
`
`am not an attorney so I don't exactly know
`
`what
`
`the complaints or li
`
`tigation is all about.
`
`know that the R400 is part
`
` of that.
`
`in
`
`Approximately when was your first discussion with
`
`counsel about this investigation?
`
`I
`
`think I already answered that question
`
`previously.
`
`You can go back to the log,
`
`I said I
`
`believe around January --
`
`late 2016 to early 2017.
`
`Do you remember any, with
`
`any more detail
`
`approximately when it occurred?
`
`MR. RENAUD:
`
`Objection.
`
`No,
`
`I do no
`
`When was the
`
`I'm sorry.
`
`first time that you met with counsel
`
`regarding this investigat
`
`ion?
`
`you mean in person,
`
`or what do you
`
`By meeting,
`
`ean by meeting?
`
`
`
`EBFarlier you said you met with counsel several
`
`times.
`
`Do you recall that?
`
`Okay.
`
`So I'm assuming you meant,
`
`you mean met
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`person.
`
`Do you recall saying you met with counsel several
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`Page 14
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`times earlier?
`
`I do, yes.
`
`What did you mean by that?
`
`So I meant
`
`taking calls and also meeting in
`
`person.
`
`So which one of the two?
`
`So after your first call with,
`
`I believe you said
`
`it was Mr. Rizk, when was your next communication
`
`with counsel regarding this investigation?
`
`Again,
`
`I'm speaking from memory.
`
`Tt
`
`is fairly
`
`fuzzy, but
`
`I recall another instance of a call and
`
`then a meeting in person in Montreal.
`
`Do you recall who you spoke with on your second
`
`call?
`
`From memory,
`
`call.
`
`I believe Mr. Rizk was present on the
`
`
`
`Who is Pam Horn?
`
`I don't recall who else was on these calls.
`
`Do you recall if there
`were
`other people
`
`on the
`
`call?
`
`There were at least another person from AMD
`
`don't remember more.
`
`Do you remember who that other person was
`
`from
`
`AMD?
`
`Yeah,
`
`that person was Pam Horn.
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`ATI Ex. 2102
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`Page 14 of 312
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`My understanding is she works for the legal
`
`for AMD.
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`Do you know if Pam Horn is an attorney?
`
`I do not know, no.
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`Page 15
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`team
`
`Without getting into specifics, what generally was
`
`the subject matter of your call?
`
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`MR. RENAUD:
`
`Instruction not
`
`to answer.
`
`I'm going to follow my counsel and not answer that
`
`question.
`
`Approximately, when was your first meeting with
`
`counsel
`
`in Montreal?
`
`
`
`Did you talk to anyone at AMD that day?
`
`It was some time in spring because it wasn't cold
`
`anymore, but
`
`I don't
`
`remember the specific dates.
`
`Do you recall who you met with?
`
`I met with Mr. Rizk and one of his colleagues that
`
`I don't remember
`
`Anyone else?
`
`the name.
`
`No, not
`
`in that meeti
`
`Where did you meet?
`
`
`
`We met at
`
`the Hilton Hotel
`
`in Laval, which is
`
`north of Montreal.
`
`Approximately how long did you meet for?
`
`If I
`
`remember correctly,
`
`that was about,
`
`I would
`
`say three-quarters of a day.
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`ATI Ex. 2102
`IPR2023-00922
`Page 15 of 312
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`ATI Ex. 2102
`IPR2023-00922
`Page 15 of 312
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`You mean if I
`
`talked to anyone at AMD that day of
`
`Page 16
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`the meeting or --
`
`Yes.
`
`And by -- you know,
`
`let me rephrase correctly to
`
`make sure I understand your question. Did I
`
`talk
`
`to anyone at AMD that I was going to a meeting, or
`
`about
`
`the content of the meeting, or talk to
`
`anyone at AMD during that day?
`
`Let's take all of those.
`
`So first, did you talk
`
`to anyone at AMD about
`
`the content of the meeting?
`
`Not that
`
`I
`
`remember, no.
`
`Did you talk to anyone from AMD at the meeting?
`
`I was the sole person of AMD present at
`
`the
`
`meeting.
`
`Did you call anyone at AMD during the meeting?
`
`During the meeting itself, no,
`
`I did not talk to
`
`anyone at AMD.
`
`When was your next conversation with counsel
`
`regarding this investigation?
`
`My next -- again,
`
`if I recall correctly, my next
`
`verbal conversation with counsel was here in
`
`T ask the court reporter to
`
`
`
`Boston.
`
`When was that?
`
`That was, started Monday morning up until today.
`
`
`MR. ELENGOLD:
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`ATI Ex. 2102
`IPR2023-00922
`Page 16 of 312
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`ATI Ex. 2102
`IPR2023-00922
`Page 16 of 312
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`

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`
`please mark Exhibit 1.
`
`
`(Document marked Exhibit
`
`1 for
`
`identification.)
`
`
`Mr. Lefebvre, have you seen Exhibit
`
`1 before?
`
`I believe I've seen this piece of paper or
`
`collection of piece of paper in a bigger document
`
`before, yes.
`
`
`Do you know what Exhibit
`
`1
`
`is?
`
`It reads: Respondents’ Notice of Deposition of
`
`Laurent Lefebvre, so.
`
`Do you understand that you are noticed to be
`
`deposed today in your personal capacity?
`
`MR. RENAUD: Objection.
`
`Yes,
`
`MR.
`
`I do understand that.
`
`ENGOLD: And I'm going to ask the
`
`Again, it reads: Respondents! First Notice of
`
`
`
`
`
`
`
`court reporter to please mark Exhibit 2.
`
`
`(Document marked Exhibit
`
`2 for
`
`identification.)
`
`
`Mr. Lefebvre, have you seen Exhibit
`
`2 before?
`
`I have seen a document that looks very much like
`
`this.
`
`It was not exactly in the same form, but it
`
`contains the same number of items than this
`
`document.
`
`
`Do you know what Exhibit
`
`2
`
`is?
`
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`ATI Ex. 2102
`IPR2023-00922
`Page 17 of 312
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`ATI Ex. 2102
`IPR2023-00922
`Page 17 of 312
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`Page 18
`
`Deposition to Complainants Advanced Micro Devices
`
`Inc. and ATI Technologies, ULC.
`
`Do you understand that you have been designated by
`
`complainants AMD and ATI
`
`to testify today on their
`
`behalf for certain topics?
`
`Yes,
`
`I understand that.
`
`for which you're a named inventor to testify today
`
`And Mr. Lefebvre,
`
`if you'll refer in that document
`
`
`in front you in Exhibit 2, my understanding is
`
`that you have been identified for topics one,
`
`seven, eight, nine, 17, 18, 33, and 86; with
`
`respect to two of the patents in this litigation,
`
`and those two patents both have you listed as a
`
`named inventor.
`
`We generally refer to them as the
`
`Morein patents because he is the first listed
`
`inventor.
`
`Do you understand the two patents I'm
`
`referring to if I say the Morein patents at
`
`issue
`
`in this investigation?
`
`For the sake of precision,
`
`I would like you to
`
`refer to them by number so I can tell which patent
`
`exactly you're talking about, but
`
`I generally am
`
`aware of the field, yes.
`
`Okay. And do you understand that you've been
`
`designated for those topics for the two patents
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`ATI Ex. 2102
`IPR2023-00922
`Page 18 of 312
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`ATI Ex. 2102
`IPR2023-00922
`Page 18 of 312
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`

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`on behalf of AMD and ATI?
`
`Page 19
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`
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`MR. RENAUD: Objection, and you may answer,
`
`but I'm just going to insert in the record that
`
`all of those subjects are subject
`
`to objections
`
`that have been made in writing, but sorry, please
`
`answer the question.
`
`Yes.
`
`I can testify to the facts related to those
`
`patents with the understanding I'm not an attorney
`
`so I can't really go, you know, beyond my
`
`knowledge.
`
`You're prepared to testify today though on those
`
`topics we just identified.
`
`Yes.
`
`MR. RENAUD:
`
`Same objection. He's prepared
`
`subject
`
`to the objections.
`
`
`
`What did you
`
`Okay.
`
`do to prepare for today's deposition?
`
`MR. RENAUD:
`
`And you may answer that
`
`question without revealing any attorney/client
`
`
`
`and I reviewed a wealth of specifications, as well
`
`communications.
`
`
`
`THE WITNESS:
`
`So I met with counsel
`
`in person,
`
`like I said
`
`before, once in Montreal and then here in Boston
`
`
`
`extensively for two days prior to this deposition,
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`ATI Ex. 2102
`IPR2023-00922
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`ATI Ex. 2102
`IPR2023-00922
`Page 19 of 312
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`Page 20
`
`as my prior depositions, my prior testimonies.
`
`I
`
`browsed through the patents,
`
`I had discussion with
`
`AMD representatives, and reviewed some
`
`presentations and the various elements that were
`
`Exhibits in my previous depositions.
`
` Let's try and take those one at a time.
`
`What documents did you review during your
`
`meeting in Montreal?
`
`In Montreal,
`
`I don't recall reviewing any
`
`particular documents. We had more discussions
`
`about
`
`the subject that I was about
`
`to be deposed
`
`on, but
`
`I don't recall reviewing particular
`
`documents per se.
`
`What documents did you review during your
`
`preparation here in Boston?
`
`I'm going to give you the best list I can tell
`
`with the understanding it's probably not going to
`
`be exhaustive because there was a wealth of
`
`documents, and so like I said before, we could go
`
`
`
`specifications did you review?
`
`
`
`back to the log, but
`
`they involve my depositions,
`
`my testimonies and various Exhibits, and
`
`
`
`presentations that were held on the AMD Perforce
`
`server, PERFORCE.
`
`Starting with the specifications, what
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`ATI Ex. 2102
`IPR2023-00922
`Page 20 of 312
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`ATI Ex. 2102
`IPR2023-00922
`Page 20 of 312
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`Page 21
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`Again, speaking from memory here,
`
`I recall
`
`reviewing at least the sequencer specification of
`
`the R400 chip versions 0.4 and version 2.0. And I
`
`believe for that particular deposition,
`
`the
`
`specification that I reviewed,
`
`that was it.
`
`Those were the only two specifications you've
`
`reviewed in preparation for your deposition today,
`
`is that correct?
`
`These are the depositions I recall being reviewed.
`
`So I know for sure I reviewed those,
`
`T may have
`
`reviewed other documents.
`
`There was a big binder.
`
`At least those.
`
`
`
`there were
`
`You said you reviewed your depositions.
`
`Is that
`
`referring to the two depositions we discussed
`
`earlier?
`
`
`MR. RENAUD: Objection.
`
`Yes,
`
`that
`
`is referring to the two depositions that
`
`I did before, yes.
`
`And you reviewed both transcripts this week?
`
`MR. RENAUD: Objection.
`
`I read both transcripts, yes.
`
`
`
`You said you reviewed testimony. What
`
`testimony
`
`did you review to prepare for today's deposition?
`
`So as best
`
`I recall again, and if you have the
`
`documents we can look at
`
`them,
`
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`IPR2023-00922
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`ATI Ex. 2102
`IPR2023-00922
`Page 21 of 312
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`

`

`testimonies that were made on how the R400
`
`Page 22
`
`implemented the unified,
`
`the various unified
`
`shader patent, and those are at least the
`
`testimonies that I've been reviewing that were
`
`part of the big binder of documents.
`
`What
`
`is a unified shader?
`
`MR. RENAUD: Objection.
`
`Can you be more precise about what you mean? Are
`
`
`
`
`
`implemented was a shader that was able to operate
`
`
`
`you talking about
`
`project?
`
`the unified shader in the R400
`
`You just mentioned how the R400 implemented the
`
`unified shader patent, right?
`
`Do you recall that?
`
`MR. RENAUD: Objection.
`
`
`
`Can you give me back my answer exactly?
`
`Why don't
`
`Okay.
`
`I just ask again.
`
`Did the R400 implement
`
`the unified shader patents
`
`that you referred to?
`
`
`MR. RENAUD: Objection.
`
`So again,
`
`I'm not an attorney so I can't talk how
`
`the patent and everything interlocks, but
`
`the R400
`
`product had a unified shader, yes.
`
`What was the unified shader in the R400?
`
`So the particular unified shader that the R400
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`Page 23
`
`on pixels and vertices using the same piece of
`
`hardware.
`
`Is there a name for that piece of hardware?
`
`We call it the unified shader, but you know, with
`
`the understanding this is just one definition of
`
`the term in that particular product.
`
`Did you work on the unified shader in the R400?
`
`In the R400,
`
`I was the main architect for the
`
`sequencer, which is effectively the block that
`
`allows -- one of the block that allows the unified
`
`shader to operate.
`
`It is the block that sequences
`
`the instructions and makes various decisions about
`
`how the work is split between pixels and vertices,
`
`and so in that respect, and many discussions I had
`
`with the lead architects, Steve Morein and Andy
`
`Gruber, yes,
`
`I worked on the unified shader.
`
`Is the sequencer a part of the unified shader?
`
`Can you restate,
`
`the workload balance between pixels and
`
`
`
`
`
`I did not get that question.
`
`please?
`
`Sure.
`
`shader?
`
`Is the sequencer a part of the unified
`
`The sequencer is a block of the R400 that
`
`is
`
`inside the unified shader that allows the shaders
`
`or the programs to operate, and makes decision
`
`about
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`ATI Ex. 2102
`IPR2023-00922
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`ATI Ex. 2102
`IPR2023-00922
`Page 23 of 312
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`vertices.
`
`
`You mentioned reviewing some Exhibits this week.
`
`
`Were you referring to the Deposition Exhibits from
`
`Page 24
`
`your prior depositions?
`
`MR. RENAUD: Objection.
`
`Yes,
`
`I meant -- I was referring to some of the
`
` Exhibits of my previous depositions.
`
`What presentations did you review to prepare for
`
`your deposition?
`
`While I don't recall the specifics,
`
`some of the
`
`Do you recall the author of that presentation?
`
`
`
`
`
`
`presentations I reviewed were part of the Exhibits
`
`of my previous depositions, and I also reviewed
`
`other presentations to refresh my memory and
`
`prepare me to testify on behalf of AMD on certain
`
`topics.
`
`Do you recall any details regarding any
`
`presentations you reviewed to prepare for today?
`
`
`
`MR. RENAUD: Objection.
`
`So I mean,
`
`I recall two specific presentations
`
`
`that were new, at least not part of the Exhibits
`
`before,
`
`that related about what Netlist 3 was in
`
`terms of the R400 product and how that particular
`
`netlist was ported on a hardware simulator named
`
`IKOS.
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`IPR2023-00922
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`ATI Ex. 2102
`IPR2023-00922
`Page 24 of 312
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`Page 25
`
`No,
`
`I do not.
`
`Were you already personally familiar with that
`
`presentation before your review?
`
`I must admit,
`
`I did not
`
`remember it.
`
`It was a
`
`long time ago.
`
`I might have been familiar with it
`
`way back when, but when it was re-presented to me,
`
`it was new.
`
`It did not ring any bells, put it
`
`that way.
`
`Do you recall the date of that presentation?
`
`I stated before,
`there
`were
`
`As
`
`two presentations I
`
`believe, and they were, one of them was
`
`in January
`
`and the other one, February.
`
`I don't recall the
`
`particular year unfortunately, but
`
`I'm sure if you
`
`can -- these were produced,
`
`so if you can find
`
`them,
`
`I can review them with you and can give you
`
`more definition as to the date.
`
`How do you know they were produced?
`
`
`
`Did both presentations relate to the netlist for
`
`Because counsel told me that they were produced.
`
`MR. RENAUD: While that answer is fine,
`
`I
`
`remind you, Laurent, any conversations with
`
`counsel are off limits.
`
`Saying what was produced,
`
`if you know it, I'll allow, but just be careful.
`
`Okay.
`
` THE WITNESS: Yes, sir.
`
`
`
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`ATI Ex. 2102
`IPR2023-00922
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`the R400?
`
`Page 26
`
` Any other presentation you recall reviewing?
`
`presentations that you recall reviewing in
`
`Again, you have the documents so we can review
`
`them and I can give you more details.
`
`I'm talking
`
`from memory.
`
`I recall one presentation was about
`
`telling what Netlist 3 was, and the other
`
`presentation was saying how that list was used or
`
`when it was ported to IKOS.
`
`Again, do you mean new presentations or
`
`Exhibits?
`
`presentations that were part of the previous
`
` Both. Any presentations that you recall reviewing
`
`in preparation for your deposition today.
`
`So there was a presentation in, at least in my
`
`previous testimony about
`
`the one tri,
`
`triangle,
`
`that was part of the Exhibits that
`
`I recall, and
`
`
`
`there was
`
`some slides about
`
`the AMD's roles and
`
`responsibilities of various people in the R400
`
`project.
`
`Again,
`
`I'm talking from memory.
`
`You can
`
`bring up the slides and we can look at them. This
`
`is a non-exhaustive list of the presentations that
`
`I recall.
`
`Any new presentations other than those two netlist
`
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`ATI Ex. 2102
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`ATI Ex. 2102
`IPR2023-00922
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`Page 27
`
`preparation for your deposition today?
`
`There were a wealth of PDF documents -- not PDF,
`
`power points presentations on the table that I
`
`looked at, but
`
`I don't recall the specifics on
`
`them unfortunately.
`
`So I know there were more,
`
`but --
`
`Did you review the patents in preparation for your
`
`deposition today?
`
`MR. RENAUD: Objection.
`
`
`
`I recall it because it was very
`
`Yeah, we can go back to the record again.
`
`IT
`
`think
`
`I stated that before, yes,
`
`I did browse through
`
`two patents in preparation for this deposition.
`
`Do you recall any details about
`
`those two patents
`
`you reviewed?
`
`They were both unified shader patents on which I
`
`was listed as an inventor, and they had numbers on
`
`them distincting them but, you know,
`
`if you bring
`
`them up,
`
`I'm sure I can tell you which ones and
`
`confirm that they were the patents I reviewed.
`
`Did you review any other documents that we haven't
`
`discussed in preparation for your deposition
`
`today?
`
`Like I said,
`
`there were a wealth of documents that
`
`I reviewed.
`
`I recall one of them was the IKOS
`
`User Manual.
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`ATI Ex. 2102
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`ATI Ex. 2102
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`Page 28
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`thick. And there might be more.
`
`Like I said, it
`
`was a lot of documents that were browsed through.
`
`Did you speak with any AMD or ATI people to
`
`prepare for your deposition today?
`
`I recall having phone calls with a few people from
`
`AMD. Yes.
`
`Who did you speak with from AMD?
`
`I
`
`remember David Christie and a few other people
`
`that I don't
`
`remember the names of.
`
`They are not
`
`the
`
`I me
`
`gathering 1
`
`documents,
`n
`
`[They are no
`
` [The only pe
`
`preparation
`
`an,
`
`I understand that they were
`
`noformation on behalf of AMD, and
`
`but
`
`I don't recall the specific names.
`
`t people I work with very often.
`
`rson you remember speaking with in
`
`for your deposition today at AMD is
`
`doing in that role though.
`
`David Christie,
`
`is that correct?
`
`MR. RENAUD: Objection.
`
`Yes, and but
`
`Pam Ho

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