Page 1
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`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`SAN FRANCISCO DIVISION
`
`ADVANCED MICRO DEVICES,
`INC., AND AT! TECHNOLOGIES
`ULC,
`
`Plaintiffs—-Counter
`Defendants
`
`v.
`
`CASE NO. 3:14-CV-1012-S|
`
`INC., LG
`LG ELECTRONICS,
`ELECTRONICS U.S.A.,
`INC.
`AND LG ELECTRONICS
`MOBILECOMM U.S.A.,
`
`INC. ,
`
`Defendants—Counter
`Claimants.
`
`CORR, CRC
`SoCONNBOoOFFWwWNY=
`ROROROROROROROReeeieeeeeeaofFwoNY|Oo0OBNYDBDOOFFHONH—|-COC
`
`VIDEOTAPED DEPOSITION of ANDREW E. GRUBER
`
`July 27, 2017
`
`Boston, Massachusetts
`
`Reporter: Michael D. O'Connor, RMR,
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards. com | 866-4Team GE
`
`ATI Ex. 2113
`IPR2023-00922
`Page 1 of 233
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`ATI Ex. 2113
`IPR2023-00922
`Page 1 of 233
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`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`SAN FRANCISCO DIVISION
`
`ADVANCED MICRO DEVICES,
`INC., AND AT! TECHNOLOGIES
`ULC,
`
`Plaintiffs—-Counter
`Defendants
`
`v.
`
`CASE NO. 3:14-CV-1012-S|
`
`INC., LG
`LG ELECTRONICS,
`ELECTRONICS U.S.A.,
`INC.
`AND LG ELECTRONICS
`MOBILECOMM U.S.A.,
`
`INC. ,
`
`Defendants—Counter
`Claimants.
`
`CORR, CRC
`SoCONNBOoOFFWwWNY=
`ROROROROROROROReeeieeeeeeaofFwoNY|Oo0OBNYDBDOOFFHONH—|-COC
`
`VIDEOTAPED DEPOSITION of ANDREW E. GRUBER
`
`July 27, 2017
`
`Boston, Massachusetts
`
`Reporter: Michael D. O'Connor, RMR,
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards. com | 866-4Team GE
`
`ATI Ex. 2113
`IPR2023-00922
`Page 1 of 233
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`ATI Ex. 2113
`IPR2023-00922
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`Page 2
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`UNITED STATES INTERNATIONAL TRADE COMMISSION
`
`WASHINGTON, D.C. 20436
`
`In the Matter of:
`
`CERTAIN GRAPHICS SYSTEMS,
`
`COMPONENTS THEREOF, AND CONSUMER
`
`PRODUCTS CONTAINING THE SAME
`
`eeeSee
`
`Thursday, July 27, 2017
`
`8:44 a.m.
`
`Investigation No.
`337-TA-1044
`
`for the Commonwealth of Massachusetts
`
`VIDEOTAPED DEPOSITION of ANDREW E.
`
`GRUBER, held at Fish & Richardson, P.C., One
`
`Marina Park Drive, Boston, Massachusetts,
`
`pursuant to notice, before Michael D.
`
`O'Connor, Registered Merit Reporter,
`
`Certified Realtime Reporter, Certified
`
`Realtime Captioner, and Notary Public in and
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards. com | 866-4Team GE
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`ATI Ex. 2113
`IPR2023-00922
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`Page 3
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`=
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`APPEARANCES:
`
`ATTORNEYS FOR DEFENDANTS - COUNTER
`
`CLAIMANTS:
`
`FISH & RICHARDSON, P. C.
`
`901 15th Street, N.W.
`
`Washington, D.C. 20005
`
`(202) 626-6355
`
`bmeche! |@robinskap|an. com
`
`oclUNUODlUODUUCUMNSOOOCUCRON
`
`BY:
`
`R. ANDREW SCHWENTKER, ESQ.
`
`=
`
`schwentker@fr. com
`
`= =
`
`= i
`
`= w
`
`MIN SUK HUH, ESQ.
`
`huh@fr. com
`
`ATTORNEYS FOR PLAINTIFFS - COUNTER
`
`DEFENDANTS:
`
`ROBINS KAPLAN LLP
`
`800 Lasalle Avenue, Suite 2800
`
`Minneapolis, Minnesota 55402
`
`(612) 349-0172
`
`BY:
`
`BRYAN J. MECHELL, ESQ.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards. com | 866-4Team GE
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`Page 4
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`APPEARANCES (Continued) :
`
`ATTORNEYS FOR ADVANCED MICRO DEVICES,
`
`INC. :
`
`MINTZ, LEVIN, COHN, FERRIS, GLOVSKY &
`
`POPEO, P.C.
`
`One Financial Center
`
`Boston, Massachusetts 02111
`
`(617) 348-1884
`
`BY:
`
`MICHAEL McNAMARA, ESQ.
`
`mmcnamar a@mintz. com
`
`ATTORNEY FOR THE DEPONENT:
`
`NORTON ROSE FULBRIGHT US, LLP
`
`1301 McKinney, Suite 5100
`
`Houston, Texas 77010
`
`(949) 852-7705
`
`
`
`
`BY:
`
`DANIEL LEVENTHAL, ESQ.
`
`daniel. leventhal @nortonrosefulbright. com
`
`Also Present: Alex Daunais, Videographer
`
`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
`
`ATI Ex. 2113
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`=
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`2 3
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`4
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`5 6 7
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`8
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`9
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`0
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`11
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`13
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`14
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` EEE LSE
`
`
`INDEX
`
`Deposition
`
`of:
`
`ANDREW E.
`
`G
`
`RUBER
`
`By Mr. Schwentker
`
`By Mr. Mechel |
`
`By Mr. McNamara
`
`dea
`
`EXHIBITS
`
`No.
`
`Exhibit
`
`1
`
`Subpoena to Testify at a
`
`Deposition in a Civil
`
`Action
`
`Exhibit 2
`
`Subpoena to Produce
`
`Documents,
`
`Information, or
`
`Objects or to Permit
`
`Inspection of Premises in
`
`a Civil Action
`
`Exhibit 3
`
`Application For
`
`Issuance of
`
`Subpoena Duces Tecum and
`
`Ad Testificandum to Andrew E.
`
`Gruber
`
`BRwR
`
`oOODLOoOlUNCUCUOT
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`12
`
`13
`
`14
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`15
`
`16
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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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`22
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`23
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`24
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`25
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`Page 5
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`Page
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`9, 227
`
`196
`
`198
`
`Page
`
`12
`
`12
`
`12
`
`Exhibit 4
`
`Document entitled "R400
`
`Architecture Proposal"
`
`107
`
`Exhibit 5
`
`Document entitled "Shader
`
`Processor”
`
`98
`
`EEC
`
`TE
`
`ERTL ee SEE
`
`EEESEEE
`
`G
`
`LLC | Worldwide Court Reporting
`regoryEdwards,
`GregoryEdwards, com | 866-4Team GE
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`Page 6
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`No.
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`Page
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`Exhibit 6
`
`Document entitled "R400 Top
`
`Left Specification”
`
`115
`
`Exhibit 7
`
`Document entitled "ATI
`
`Technologies Inc. R400
`
`Program"
`
`Exhibit 8
`
`U.S. Patent No. 6,897,871
`
`Exhibit 9
`
`U.S. Patent No. 8, 760,454
`
`Exhibit 10
`
`U.S. Patent No. 9,582,846
`
`Exhibit 11
`
`Document entitled "R400
`
`Sequencer Specification
`
`SQ"
`
`123
`
`134
`
`135
`
`135
`
`148
`
`Exhibit 12
`
`Document entitled,
`
`“ATI and
`
`NVIDIA Proclaim Different
`
`Graphics Processors
`
`Architecture Goals"
`
`207
`
`Exhibit 13
`
`Document has a title that
`
`says,
`
`"NVIDIA Chief
`
`Architect: Unified Pixel
`
`and Vertex Pipelines — The
`
`Way to Go"
`
`208
`
`1
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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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`8
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`10
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`11
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`12
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`13
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`14
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`15
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`16
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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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`22
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`23
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`24
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`25
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`EXHIBITS (Continued)
`
`
`
`
`oo cregoryEdwards,LLC |Worldwide Court Reporting=
`GregoryEdwards, com | 866-4Team GE
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`Page 7
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`EXHIBITS (Continued)
`
`No.
`
`Page
`
`Exhibit 14
`
`Document entitled,
`
`"Microsoft
`
`Technology Development
`
`Agreement”
`
`Exhibit 15
`
`Document entitled,
`
`“R400
`
`Sequencer Specification
`
`SEQ"
`
`Exhibit 16
`
`Document entitled
`
`210
`
`211
`
`"Executive Review — R400,
`
`October 15, 2002"
`
`214
`
`Exhibit 17
`
`Document entitled "ATI
`
`Technologies Inc.
`
`PD Team
`
`Meeting January 9, 2003"
`
`Exhibit 18
`
`Screen capture
`
`Exhibit 19
`
`Transcript of Andrew E.
`
`Gruber, dated 3/17/15
`
`Exhibit 20
`
`FAQ from NVIDIA website
`
`JeIORIK
`
`216
`
`218
`
`221
`
`224
`
`and ATI Technologies Announce
`
`
`
`
`1
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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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`14
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`16
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`20
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`25
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`oo cregoryEdwards,LLC |Worldwide Court Reporting=
`GregoryEdwards, com | 866-4Team GE
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`Page 8
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`PROCEEDINGS
`
`VIDEOGRAPHER: We are on the
`
`record.
`
`This is the videographer, Alex
`
`Daunais,
`
`speaking.
`
`Today's date is July
`
`27, 2017, and the time is 8:44 a.m.
`
`We are here in Boston,
`
`Massachusetts to take the deposition of
`
`Andrew E. Gruber
`
`in the matter of
`
`Certain Graphic Systems Components
`
`Thereof and Consumer Products Containing
`
`the Same,
`
`ITC investigation number
`
`337-TA-1044, and also Advanced Micro
`
`Devices,
`
`Inc.
`
`and AT| Technologies ULC
`
`versus LG Electronics,
`
`Inc., LGE
`
`Electronics USA,
`
`Inc. and Electronics
`
` EEE CEE SEER
`
`
`BRwR
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`MobileCGomm USA,
`
`Inc., case number
`
`3:14-CV-1012-S1.
`
`Will counsel please state
`
`themselves.
`
`MR.
`
`SCHWENTKER: Andrew Schwentker
`
`from Fish & Richardson on behalf of the
`
`LG Defendants in the Northern District
`
`of California case and on behalf of the
`
`LG Respondents in the ITC investigation.
`
`TE
`
`TE
`
`EEE
`
`ESE ERTS8
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`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
`
`ATI Ex. 2113
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`Also with me
`
`is Andrew Huh from
`
`Fish & Richardson
`
`MR. MECHELL: Bryan Mechel!
`
`from
`
`Robins Kaplan on behalf of Advanced
`
`Micro Devices,
`
`Inc.
`
`and ATI Technologies
`
`ULC in the Northern District of
`
`California matter for Plaintiffs.
`
`MR. McNAMARA: Michael McNamara
`
`from Mintz Levin on behalf of AMD and
`
`ATI.
`
`MR. LEVENTHAL: Daniel Leventhal,
`
`Norton Rose Fulbright US LLP on behalf
`
`of the witness.
`
`ANDREW E. GRUBER
`
`having been satisfactorily identified by the
`
`production of his driver's license, and duly
`
`sworn by the Notary Public, was examined and
`
`testified as fol lows:
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`Page 9
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`EXAMINATION BY
`
`MR.
`
`SCHWENTKER:
`
`Q.
`
`Good morning, Mr. Gruber.
`
`Can you
`
`please state your full name for the record
`
`LESO
`
`TE aa
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`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`oOONOBOoOFFWYNE
`NRPRKHKHHDBHP||HF||=e=eFeSs=oOoF&WwWNH|80DODDONOBOOOFWONY=
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Andrew Evan Gruber.
`
`Have you been deposed before?
`
`Yes.
`
`How many times?
`
`At
`
`least twice.
`
`It could be three
`
`times.
`
`Probably three.
`
`Q.
`
`And what was the subject matter of
`
`those depositions?
`
`A.
`
`It was an action between NVIDIA
`
`and Qualcomm over multiple patents.
`
`So | was
`
`deposed multiple times in that case.
`
`Q.
`
`A.
`
`Multiple times in that same case?
`
`In that same case, because there
`
`were multiple patents involved.
`
`Q.
`
`What were the patents involved in
`
`those depositions?
`
`A.
`
`| don't recall! the numbers.
`
`They
`
`dealt
`
`in,
`
`in general, with 3D graphics.
`
`Q.
`
`| assume you're aware that you're
`
`a named inventor on some patents with Steve
`
`Morein, Laurent Lefebvre and Andi Skende?
`
`A.
`
`Yes,
`
`| am.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards. com | 866 4Team GE
`
`
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`ATI Ex. 2113
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`Q.
`
`Were the depositions about those
`
`patents or other patents or both?
`
`MR. LEVENTHAL:
`
`Form.
`
`A.
`
`They were about those patents.
`
`I'm not sure that they were exclusively about
`
`those patents
`
`Q.
`
`Okay.
`
`So you may have been
`
`deposed about other patents?
`
`MR. LEVENTHAL:
`
`Form.
`
`Yes.
`
`You have been through the
`
`A.
`
`Q.
`
`
`
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`deposition process two or three times at this
`
`point, but I'll just go over some quick
`
`background with you
`
`You understand that you are under
`
`oath as if you were in a court of
`
`law?
`
`A.
`
`Q.
`
`Yes.
`
`Is there any reason that you
`
`cannot give accurate and complete testimony
`
`today?
`
`A.
`
`Q.
`
`No.
`
`So I'll be asking a series of
`
`questions today, and unless you're instructed
`
`not to answer by your counsel, you'll be
`
`expected to answer my questions
`
`EE ST
`
`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
`
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`Do you understand that?
`
`Yes.
`
`| will assume that you understand
`
`A.
`
`Q.
`
`my questions unless you ask for me to clarify
`
`Okay?
`
`A.
`
`Q.
`
`Okay.
`
`We can take a break any time you
`
`want.
`
`The only thing that
`
`| would ask is that
`
`you answer any pending question, and then we
`
`can take a break
`
`A.
`
`Okay.
`
`(Document marked as Exhibit
`
`1
`
`for identification)
`
`(Document marked as Exhibit 2
`
`for identification)
`
`(Document marked as Exhibit 3
`
`for identification)
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` LEER
`Page 12
`
`Q.
`
`Mr. Gruber,
`
`the court reporter has
`
`handed you three exhibits.
`
`The first exhibit,
`
`Exhibit 1,
`
`is a subpoena to testify at a
`
`deposition in a civil action
`
`Do you see that?
`
`Yes.
`
`And Exhibit 2 is a subpoena to
`
`A.
`
`Q.
`
`produce documents,
`
`information or objects or to
`
`LESO TE
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`TE aa
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`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`Page 13
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`permit
`
`inspection of a premises in a civil
`
`action?
`
`A.
`
`Q.
`
`Yes.
`
`And Exhibits 1 and 2 are from the
`
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`Northern District of California
`
`Exhibit 3 is a subpoena duces
`
`tecum and ad testificandum from the
`
`International Trade Commission.
`
`Do you see
`
`that?
`
`A.
`
`Q.
`
`before?
`
`Yes.
`
`Have you seen these documents
`
`A.
`
`|
`
`received the subpoena to produce
`
`documents and to testify.
`
`| don't know if
`
`these are the exact same ones, but they look
`
`certainly similar.
`
`| don't think that I've seen
`
`Exhibit 3 before
`
`Q.
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`Do you understand that you are
`
`here today in response to a subpoena?
`
`A.
`
`Q.
`
`Yes.
`
`And do you understand that you're
`
`here to testify in connection with both a
`
`District Court
`
`litigation between AMD and ATI
`
`versus LG Electronics, as well as an
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`EE ST
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`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`Page 14
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`International Trade Commission investigation?
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`A.
`
`Q.
`
`Yes.
`
`Could you turn to Exhibit 3.
`
`There are two attachments, Attachments A and B
`
`If you could turn to Attachment A first. What
`
`l'm referring to is Attachment A
`
`A.
`
`Q.
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`A.
`
`ls that near the end?
`
`No.
`
`It's towards the beginning
`
`Attachment A.
`
`| see what you're
`
`saying, yes.
`
`Q.
`
`If you could turn to Page 10 of
`
`Attachment A.
`
`A.
`
`Q.
`
`production?
`
`A.
`
`Q.
`
`Okay.
`
`Do you see requests for
`
`Yes.
`
`Have you seen these requests for
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`| believe that
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`| have.
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`|
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`certainly received a request for production,
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`and this could have been it.
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`| don't have a
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`clear memory of whether this exactly was what
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`the request was
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`Q.
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`A.
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`Okay.
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`There was a request for production
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`EE ST
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`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`and was owned by Qualcomm, and on the advice of
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`associated with the subpoena that
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`|
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`received
`
`Q.
`
`Okay.
`
`So if we could turn to
`
`Exhibit 2, Page 4,
`
`there's a list of requests
`
`for production there.
`
`Is that the list of
`
`requests for production that you were referring
`
`to?
`
`A.
`
`Q.
`
`Yes.
`
`Did you search for documents in
`
`response to these requests for production?
`
`A.
`
`Q.
`
`A.
`
`Yes,
`
`| did.
`
`And did you find anything?
`
`|
`
`found things related to my
`
`employment at AMD and ATI. Anything else that
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`| had would have been transferred as part of
`
`Qualcomm's acquisition of ATI's mobile group,
`
`my counsel,
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`| did not produce those
`
`Q.
`
`But you had —- you did find
`
`documents that you did not produce?
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`A.
`
`| didn't
`
`look through all of my
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`electronic-related information that was on my
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`Qualcomm-owned equipment.
`
`So | can't —-
`
`|
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`can't say definitively that
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`|
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`found documents
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`there.
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`| didn't
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`look through those
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`Page 15
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`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`EEESEEE
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`ATI Ex. 2113
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`Page 16
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`electronic documents that were owned by
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`Qualcomm based on the advice of my counsel
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`that
`
`they weren't required as part of the
`
`production
`
`Q.
`
`Okay.
`
`You mentioned you found
`
`documents related to your employment at AMD and
`
`ATI.
`
`Did you provide those to your counsel?
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`were?
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`| did.
`
`Do you recall what those documents
`
`They were mostly related to
`
`employment agreements and stock option grants
`
`Q.
`
`A.
`
`Q.
`
`Okay. Anything else?
`
`| don't recall anything else
`
`Then turning back to Exhibit 3,
`
`the request for production that we were looking
`
`at.
`
`A.
`
`Q.
`
`Yes.
`
`So |
`
`take it that you did not
`
`specifically search for documents responsive to
`
`these requests for production?
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`A.
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`| did within my personally owned
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`papers.
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`I did not within information that
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`|
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`didn't have personal ownership of.
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`MR. LEVENTHAL:
`
`To interject,
`
`the
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`EE ST
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`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`ATI Ex. 2113
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`Page 16 of 233
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`production that was made in ND Cal was
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`reproduced in ITC with both
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`confidentiality designations as
`
`responsive to Exhibit 3, and then the
`
`LinkedIn profile that were produced
`
`yesterday was produced responsive to
`
`request for production No.
`
`1
`
`in Exhibit
`
`3.
`
`MR.
`
`SCHWENTKER: Okay
`
`Understood.
`
`Q.
`
`If you could turn in Exhibit 3 to
`
`—- after Attachment A,
`
`there's an Attachment
`
`B --
`
`A.
`
`Q.
`
`Yes.
`
`—- which lists a number of
`
`deposition topics.
`
`Do you see those?
`
`A.
`
`Q.
`
`Yes.
`
`Have you seen those deposition
`
`topics before?
`
`A.
`
`Q.
`
`Yes.
`
`You understand you're here to
`
`testify with respect to these topics?
`
`MR. LEVENTHAL: Object to the
`
`1
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`2
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`Page 17
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`form.
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`A.
`
`Yes.
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`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`Page 17 of 233
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`ATI Ex. 2113
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`Page 17 of 233
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`Q.
`
`What did you do to prepare for
`
`your deposition?
`
`A.
`
`| produced my personal papers
`
`associated with my employment at AMD and ATI.
`
`Other than that —- and | had some depo prep as
`
`to form with my
`
`lawyer, but that was
`
`it.
`
`MR. LEVENTHAL:
`
`| caution you not
`
`to reveal
`
`the contents of any
`
`communication
`
`Q.
`
`When did you meet with your
`
`attorney?
`
`MR. LEVENTHAL:
`
`Form.
`
`A.
`
`| met with him over the phone
`
`earlier in the week
`
`Q.
`
`A.
`
`Q.
`
`For how long?
`
`|'d say about 45 minutes.
`
`Did you review any documents to
`
`prepare for your deposition?
`
`A.
`
`Q.
`
`No.
`
`When did you find out that you
`
`would be deposed?
`
`MR. LEVENTHAL:
`
`Form.
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`Page 18
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`A.
`
`Well,
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`|
`
`received a subpoena early
`
`in the year.
`
`| didn't find out the actual date
`
`of the deposition until a few weeks ago.
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`LESO TE
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`TE aa
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`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`Page 18 of 233
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`ATI Ex. 2113
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`Page 18 of 233
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`Page 19
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`preparation for your deposition besides your
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`23
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`24
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`Q.
`
`Do you have an understanding of
`
`what —— strike that.
`
`So you understand that there are
`
`two separate lawsuits at
`
`issue here today?
`
`A.
`
`Q.
`
`Yes.
`
`So one is the Northern District of
`
`California lawsuit and one is the ITC
`
`investigation; do you understand that?
`
`A.
`
`Q.
`
`Yes.
`
`Do you have an understanding of
`
`what the Northern District of California
`
`lawsuit
`
`is about?
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`No.
`
`No?
`
`No.
`
`Do you have an understanding of
`
`what the ITC investigation is about?
`
`A.
`
`Q.
`
`attorney?
`
`A.
`
`Q.
`
`No.
`
`Did you speak with anyone else in
`
`No.
`
`I'd like to turn to your
`
`background. Are you currently employed?
`
`A.
`
`|
`
`am.
`
`
`
`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`LEE
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`ATI Ex. 2113
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`Page 19 of 233
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`Page 20
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`Q
`
`A
`
`Q.
`
`A
`
`Where?
`
`At Qualcomm.
`
`What's your position?
`
`|'m a vice-president of GPU
`
`architecture.
`
`Q.
`
`A.
`
`Q.
`
`Qua | comm?
`
`that?
`
`A.
`
`Q.
`
`oOTFfoSF
`
`A.
`
`GPU architecture?
`
`Yes.
`
`How long have you been at
`
`Since 2009.
`
`And where did you work before
`
`| worked for AMD
`
`How long have you worked for AMD?
`
`Since the acquisition of ATI.
`
`When was that?
`
`| believe it was 2004, but
`
`| can't
`
` LEER
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`say with certainty
`
`Q.
`
`Before the acquisition, you were
`
`with ATI?
`
`A.
`
`Q
`
`A.
`
`Q
`
`| was.
`
`How long had you been with ATI?
`
`| started with ATI
`
`in 1994.
`
`Can you take me through your roles
`
`at AT| and AMD, starting in 1994?
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`LESO TE
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`TE aa
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`LLC | Worldwide Court Reporting
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`GregoryEdwards. com | 866-4Team GE
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`Page 20 of 233
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`Page 21
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`A.
`
`Do you have a specific question
`
`about that or do you just want
`
`like an overal |
`
`summary?
`
`Q.
`
`A.
`
`An overall
`
`summary
`
`MR. McNAMARA: Objection
`
`| was
`
`involved in the architecture
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`
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`of the initial
`
`3D graphics at ATI,
`
`their
`
`initial 3D graphics product, and | continued
`
`that role throughout my ATI employment.
`
`At one point ATI had multiple
`
`design teams, and | was
`
`in charge of the GPU
`
`architecture for the East Coast design team.
`
`Q.
`
`And when you say the East Coast
`
`design team, where is that based?
`
`A.
`
`It was based in Marlboro, Mass. at
`
`the time.
`
`It's now based in Boxboro,
`
`Massachusetts.
`
`But
`
`| was at the Marlboro
`
`location.
`
`Q.
`
`What was your position when you
`
`started at ATI
`
`in 1994?
`
`A.
`
`| was a —- my role was to drive
`
`the 3D architecture.
`
`| might have started on a
`
`contracting basis and switched over to a
`
`full-time employment.
`
`| switched over at some
`
`point.
`
`| don't recall when that happened
`
`EE ST
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`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`ATI Ex. 2113
`IPR2023-00922
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`Page 22
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`Q.
`
`From a contractor to a full-time
`
`emp | oyee?
`
`A.
`
`Q.
`
`Yes.
`
`And then did you have different
`
`titles during your time at ATI?
`
`A.
`
`Yes. Most of the time | was a
`
`principal.
`
`Q.
`
`And do you recall when you became
`
`a principal?
`
`A.
`
`Q.
`
`A.
`
`had?
`
`| do not.
`
`Do you recall any other titles you
`
`| don't.
`
`| mean,
`
`it, you know,
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`was some kind of engineering title, senior
`
`engineer or something like that, but
`
`| don't
`
`recall
`
`the exact title
`
`Q.
`
`Would that have been before or
`
`after principal?
`
`A.
`
`That would be prior to principal.
`
`Principal was my
`
`last title at ATI and AMD.
`
`Q.
`
`Okay.
`
`So you became a principal
`
`at ATI, and then that title carried over to
`
`AMD?
`
`A.
`
`| cannot say for sure that
`
`| was a
`
`principal at ATI.
`
`| don't recall when | became
`
`EE ST
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`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`ATI Ex. 2113
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`Page 22 of 233
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`ATI Ex. 2113
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`Page 22 of 233
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`Page 23
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`a principal.
`
`Q.
`
`Okay.
`
`And did you have any other
`
`titles at AMD?
`
`A.
`
`No. Well, as | say,
`
`if | started
`
`at AMD and | was not a principal,
`
`| could have
`
`been a senior engineer, and then made a
`
`principal during my time at AMD
`
`Q.
`
`A.
`
`Q.
`
`But at the time of the acquisition
`
`| was a principal.
`
`—— by Qualcomm, you were a
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`principal?
`
`A.
`
`Q.
`
`Yes.
`
`Okay.
`
`And what did Qualcomm
`
`acquire from ATI?
`
`A.
`
`Q.
`
`A.
`
`AMD?
`
`The mobile graphics -——-
`
`MR.
`
`SCHWENTKER: Strike that.
`
`What did Qualcomm acquire from
`
`The mobile graphics group, as wel
`
`as some assets associated with that.
`
`Q.
`
`A.
`
`How large is that group?
`
`MR. LEVENTHAL:
`
`Form.
`
`It was not very large as to the
`
`group that
`
`| was
`
`immediately associated with
`
`LESO TE
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`TE aa
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`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`ATI Ex. 2113
`IPR2023-00922
`Page 23 of 233
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`ATI Ex. 2113
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`Page 23 of 233
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`Page 24
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`| would say under ten people, but they also
`
`acquired some display group assets that were
`
`based in Toronto that were larger, but
`
`I'm not
`
`sure how large.
`
`Q.
`
`And you also mentioned some assets
`
`associated with the mobile graphics group
`
`What are those assets?
`
`A.
`
`Some of our
`
`like physical
`
`laptops
`
`but
`
`| believe they also acquired some
`
`intellectual property assets as well.
`
`Q.
`
`A.
`
`Do you know what those are?
`
`| don't know in any detail.
`
`|
`
`just know that Qualcomm did acquire some rights
`
`to use AMD intellectual property,
`
`so that we
`
`did not have to worry about
`
`impinging on AMD
`
`intellectual property in future Qualcomm
`
`
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`1
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`2
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`designs.
`
`Q.
`
`What's your educational
`
`background?
`
`A.
`
`| have a Bachelor's of Science in
`
`electrical engineering and computer science
`
`from MIT
`
`Q.
`
`A.
`
`Q.
`
`When did you receive —-
`
`1981.
`
`Do you have any postgraduate
`
`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`ATI Ex. 2113
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`education?
`
`A.
`
`Q.
`
`No.
`
`Did you work on specific products
`
`while you were at ATI and AMD?
`
`A.
`
`Q.
`
`A.
`
`Yes.
`
`What products did you work on?
`
`As
`
`| mentioned,
`
`| worked on their
`
`first 3D product, which is called the Rage.
`
`We
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`had a Rage ||,
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`a Rage II|, after which | worked
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`on a product called the R400, which — I'm
`
`sorry, after the Rage series was the Radeon
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`series.
`
`There was the Radeon 100 and the
`
`Radeon 200.
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`The Radeon 300 or something called
`
`R300 was one that
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`| did not work on, because
`
`that was done out of our California group.
`
`The
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`R400 was done out of my group.
`
`The successor
`
`to that was the R500 and the R600, which | also
`
`worked on.
`
`Q.
`
`Just to make sure | understand.
`
`You worked on the Radeon 100 and Radeon 200,
`
`you did not work on the R300, but then you
`
`worked on the R400, R500 and R600?
`
`A.
`
`Correct.
`
`Some of those products
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`were never produced, but there was stil |
`
`internal projects
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` LEER
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`LESO TE
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`TE aa
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`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
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`ATI Ex. 2113
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`Page 26
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`Q.
`
`A.
`
`Which ones did you not produce?
`
`The R400 was never produced.
`
`The
`
`R500 was never produced either.
`
`The R400 and
`
`R500 -- the R400 was delayed and turned into
`
`the R500, and the R500 was delayed and turned
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`into the R600, and the R600 was eventual ly
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`produced.
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`frame?
`
`When was the R600 produced?
`
`| don't recall.
`
`Do you recall an approximate time
`
`If you pressed me,
`
`| would say
`
`around 2006, but
`
`| could be wrong about that.
`
`Q.
`
`You said the R400 was delayed
`
`Why was
`
`it delayed?
`
`A.
`
`There were two reasons for
`
`it.
`
`One was
`
`it was simply a difficult product.
`
`It
`
`was a lot of stuff that had to get right.
`
`There were changes throughout the design, and
`
`not all of those were ready in time for the
`
`market window.
`
`Another reason for the delay was
`
`that a
`
`lot of the technology and the basic
`
`design was directed at the Xbox 360 contract
`
`that ATI had won from Microsoft.
`
`So that split
`
`LESO TE
`
`TE aa
`
`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
`
`ATI Ex. 2113
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`ATI Ex. 2113
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`Page 26 of 233
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`
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`contract that split some of the resources that
`
`
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`
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`SEE
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`some of the resources that were needed to
`
`finish the design
`
`MR. MECHELL:
`
`| designate the
`
`transcript highly confidential and
`
`attorneys eyes only under the protective
`
`order of the Northern District of
`
`California at this time
`
`Q.
`
`What do you mean when you say that
`
`because it was directed at the Xbox 360
`
`were needed to finish the design?
`
`MR. LEVENTHAL:
`
`Form.
`
`A.
`
`Well,
`
`the basics of the design
`
`were similar for both the R400 and the Xbox
`
`360.
`
`There were differences as well.
`
`Microsoft wanted a different memory system,
`
`for
`
`instance, and we had to support all
`
`the
`
`requirements and customer
`
`interface of
`
`Microsoft from an engineering point of view.
`
`So we split our engineering team.
`
`So some people were dedicated to dealing with
`
`the Microsoft-specific requirements while
`
`others of the engineering team pushed on with
`
`the desktop market product.
`
`Q.
`
`And by “desktop market product, "
`
`
`
`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
`
`LEE
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`EEESEEE
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`Page 27
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`ATI Ex. 2113
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`Page 27 of 233
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`Page 28
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`are you referring to the R400?
`
`A.
`
`Q.
`
`A.
`
`Yes.
`
`So the —- strike that.
`
`Have you heard of the Xenos?
`
`Yes.
`
`That was another code name
`
`for the Microsoft product.
`
`Q.
`
`Okay.
`
`So the Xenos was the
`
`product for the Xbox 360?
`
`A.
`
`Q.
`
`Correct.
`
`And that was a different product
`
`than the R400?
`
`
`
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`MR. MECHELL: Objection to form.
`
`A.
`
`Correct.
`
`MR. MECHELL:
`
`For the record, when
`
`counsel for District Court objects,
`
`|'m
`
`not going to object as well.
`
`So you can
`
`keep the transcript as clear as
`
`possible.
`
`Is that fine?
`
`MR.
`
`SCHWENTKER: That's fine
`
`MR. McNAMARA:
`
`And we'll also
`
`designate the entirety of the transcript
`
`as confidential business information in
`
`the ITC protective order.
`
`MR.
`
`SCHWENTKER: Okay
`
`MR. MECHELL:
`
`And counsel, under a
`
`EE ST
`
`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
`
`ATI Ex. 2113
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`Page 28 of 233
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`ATI Ex. 2113
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`Page 28 of 233
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`Page 29
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`similar approach,
`
`if counsel makes an
`
`objection,
`
`I'll try to keep the
`
`transcript clean as well, and please
`
`assume it's adopted as well.
`
`MR.
`
`SCHWENTKER:
`
`Come on.
`
`You
`
`guys just are being lazy
`
`MR. McNAMARA: We can talk all
`
`over you. That's fine,
`
`too. Whatever
`
`way you want to go about
`
`it.
`
`MR.
`
`SCHWENTKER: That's fine
`
`Did you work on the Xenos?
`
`| was on the R400 product.
`
`|,
`
`in
`
`Q.
`
`A.
`
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`
`
`that sense,
`
`interacted and had a role on the
`
`Xenos team as well, but my primary role was
`
`pushing forward the desktop effort.
`
`Q.
`
`A.
`
`Where was the R400 team?
`
`Most of the R400 team was
`
`in the
`
`Marlboro office.
`
`There were some people
`
`working in the Orlando office
`
`Q.
`
`A.
`
`Where was the Xenos team?
`
`The Xenos team was primarily in
`
`the Orlando office, but there were some people
`
`in the Marlboro office working on it as well.
`
`It was not a clean split in between the two
`
`offices.
`
`LESO TE
`
`TE aa
`
`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
`
`ATI Ex. 2113
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`Page 29 of 233
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`ATI Ex. 2113
`IPR2023-00922
`Page 29 of 233
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`R400?
`
`Q.
`
`A.
`
`When did you start working on the
`
`| haven't
`
`looked at that
`
`Page 30
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`documentation recently.
`
`So | have —-
`
`|
`
`couldn't say off the top of my head when it
`
`was.
`
`Q.
`
`What documentation are you
`
`referring to?
`
`A.
`
`Design documentation that
`
`| recal|
`
`seeing in the previous ITC case
`
`Q.
`
`You're not referring to the
`
`documentation that you have in your possession?
`
`A.
`
`Q.
`
`No.
`
`| don't have any of that.
`
`Earlier you said that one of the
`
`reasons —— one of the two reasons the R400 was
`
`delayed was because it was difficult.
`
`Do you
`
`recall saying that?
`
`A.
`
`Q.
`
`A.
`
`Yes.
`
`What was difficult about the R400?
`
`The primary reason why it was
`
`late
`
`was that the memory interface associated with
`
`it was aggressive.
`
`It had various kinds of
`
`compression associated with it, and it just
`
`took us a long time to get that working
`
`correctly. That's why we were able to come out
`
`EE ST
`
`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
`
`ATI Ex. 2113
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`Page 30 of 233
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`ATI Ex. 2113
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`Page 31
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`with the Xenos product earlier than the R400,
`
`because it used a different memory interface
`
`that didn't have a lot of the complexity of the
`
`R400 interface
`
`Q.
`
`What do you mean by “memory
`
`interface"?
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`25
`
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`
`
`A.
`
`The part of the logic that talked
`
`to the frame buffer and did the final blending
`
`associated with the frame buffer.
`
`Q.
`
`So you said that that was the
`
`primary reason.
`
`The primary reason why it was
`
`late was that the memory interface associated
`
`with it was aggressive?
`
`A.
`
`Q.
`
`A.
`
`Yes.
`
`Are there other reasons?
`
`It was a difficult task on a lot
`
`of fronts.
`
`So |
`
`think that development didn't
`
`go as well as our
`
`initial schedule was.
`
`It was
`
`the memory interface that was the long haul.
`
`|
`
`think a lot of the rest of the
`
`logic was working fairly well. That's why it
`
`gave us confidence to commit to Microsoft for
`
`the Xbox part, which aside from the memory
`
`interface,
`
`| mean,
`
`the rest of the Xbox part
`
`was very similar to what we were working on for
`
`EE ST
`
`LLC | Worldwide Court Reporting
`GregoryEdwards,
`GregoryEdwards. com | 866-4Team GE
`
`ATI Ex. 2113
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`Page 31 of 233
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`Page 32
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`the R400 and used the same database
`
`Q.
`
`What do you mean by “the same
`
`database"?
`
`A.
`
`There was a fork at one point, but
`
`they all started based on the same database.
`
`In other words,
`
`the R400 product was —- the
`
`R400 design was used and then forked to do the
`
`particular changes required by Microsoft.
`
`Q.
`
`A.
`
`And what was
`
`in that database?
`
`All of the graphics accelerator
`
`functions.
`
`So we had a command processor, we
`
`had a setup engine, we had a unified shader, we
`
`had a rasterizer, we had a texture
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