`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ---------------------------------
` CIRRUS LOGIC, INC.;
` OMNIVISION TECHNOLOGIES, INC.;
` Petitioners
` v.
` GREENTHREAD, LLC,
` Patent Owner
` ---------------------------------
` Case: IPR2024-00001
` U.S. Patent No. 10,734,481
` Case: IPR2024-00016
` U.S. Patent No. 10,510,842
` Case: IPR2024-00017
` U.S. Patent No. 8,421,195
` Case: IPR2024-00018
` U.S. Patent No. 9,190,502
` Case: IPR2024-00019
` U.S. Patent No. 11,316,014
` Case: IPR2024-00020
` U.S. Patent No. 11,121,222
` Case: IPR2024-00021
` U.S. Patent No. 11,121,222
` ----------------------------------
`
` Deposition of SANJAY BANERJEE, PH.D.
` Conducted Remotely
` Friday, July 19, 2024
` 10:00 a.m.
`
`Reported by: Matthew Goldstein, RMR, CRR
`____________________________________________________
` DIGITAL EVIDENCE GROUP
` 1730 M Street, NW, Suite 812
` Washington, D.C. 20036
`(202) 232-0646
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 1 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
` Deposition of SANJAY BANERJEE, PH.D.,
`conducted remotely:
`
`Page 2
`
` Pursuant to Notice, before Matthew Goldstein,
`RMR, CRR, Notary Public in and for the District of
`Columbia.
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 2 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 3
`
` A P P E A R A N C E S
` ON BEHALF OF THE PETITIONER, CIRRUS LOGIC,
` INC.:
` RAJ PAUL, ESQUIRE
` COVINGTON & BURLING, LLP
` 850 Tenth Street, NW
` One City Center
` Washington, DC 20001
` 202.662.6000
`
` and
`
` ANUPAM SHARMA, ESQUIRE
` COVINGTON & BURLING LLP
` 3000 El Camino Real
` 5 Palo Alto Square
` Palo Alto, California 94306
` 650.632.4709
`
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 3 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 4
`
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` A P P E A R A N C E S C O N T I N U E D
` ON BEHALF OF THE PETITIONER, OMNIVISION
` TECHNOLOGIES, INC.:
` DAVID H. BLUESTONE, ESQUIRE
` BENESCH FRIEDLANDER COPLAN & ARONOFF
` 71 South Wacker Drive
` Suite 1600
` Chicago, Illinois 60606
` 312.517.9564
`
` ON BEHALF OF THE PATENT OWNER, GREENTHREAD,
` LLC:
` ARVIND JAIRAM, ESQUIRE
` MCKOOL SMITH
` 1999 K Street, NW
` Suite 600
` Washington, D.C. 20006
` 202.370.8324
`
` ALSO PRESENT:
` EMRE YUZAK
` KENT COOPER
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 4 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
` C O N T E N T S
`EXAMINATION OF SANJAY BANERJEE, PH.D. PAGE
`
`Page 5
`
`By MR. JAIRAM 6
`By MR. PAUL 134
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 5 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 6
`
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` P R O C E E D I N G S
`Whereupon,
` SANJAY BANERJEE, PH.D.,
`being first duly sworn or affirmed to testify to
`the truth, the whole truth, and nothing but the
`truth, was examined and testified as follows:
` EXAMINATION BY COUNSEL FOR THE PATENT OWNER
`BY MR. JAIRAM:
` Q. Good morning, Dr. Banerjee. My name is
`Arvind Jairam.
` A. Good morning.
` Q. And I'm going to be asking you some
`questions today.
` Will you please state and spell your
`full name for the record?
` A. Sanjay Kumar Banerjee, S-A-N-J-A-Y;
`Kumar, K-U-M-A-R; Banerjee, B-A-N-E-R-J-E-E.
` Q. Thank you.
` Before we begin, I just want to remind
`you of some basic ground rules. You may already
`know this, but I'll just repeat for the sake of
`completeness.
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 6 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 7
` You understand you've been placed under
`oath today just as though you were in court?
` A. Yes.
` Q. And you understand that you are bound to
`answer my questions truthfully today?
` A. Yes.
` Q. If a question is unclear, please let me
`know so that I may rephrase as necessary.
`Otherwise, I will assume that you understood my
`question. Okay?
` A. Okay.
` Q. Because your testimony is being
`transcribed by a court reporter and particularly
`because this remote deposition format means we are
`not in the same room, do you understand that you
`need to answer my questions verbally instead of
`with gestures?
` A. Yes.
` Q. I'm going to do my best and I would ask
`that you please do your best so that we do not
`speak over one another to make the transcript
`cleaner and the court reporter's life easier.
`
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 7 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 8
`
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` Is that okay?
` A. Okay.
` Q. In terms of breaks, we will take breaks
`during the deposition at least every hour. If you
`need one at any time, please let me know. I'll
`just ask that if a question is pending, I'll
`request that you answer the question before taking
`a break. And occasionally I might ask that we
`just wrap up a certain line of questioning before
`we take the break.
` Is that okay?
` A. Sure.
` Q. Any questions from you, sir, before we
`proceed?
` A. No.
` Q. I see that there are at least some
`people in the room with you today. Could you tell
`me about how many?
` A. Four, in addition to me.
` Q. Okay. If it's possible, can you please
`tell me who is in the room with you?
` A. Well --
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 8 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 9
` MR. PAUL: This is Raj Paul, on behalf
`of Covington & Burling, on behalf of petitioners.
`Also with me is Anupam Sharma, also of Covington &
`Burling, also on behalf of petitioners.
` And also with me is Emre Yuzak and Kent
`Cooper, on behalf of real party in interest
`GlobalFoundries.
` MR. JAIRAM: Thanks, Raj.
`BY MR. JAIRAM:
` Q. Dr. Banerjee, are you aware of any
`reason that you may be unable to answer my
`questions truthfully and fully today?
` A. No.
` Q. Are you taking any medications that
`would prevent you from providing honest, accurate,
`and complete answers?
` A. No.
` Q. Are there any health conditions that
`would prevent you from providing honest, accurate,
`and complete answers?
` A. No.
` Q. Do you understand that you have to
`
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 9 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 10
`answer my questions even if your counsel objects,
`unless he directly instructs you not to answer?
` A. Yes.
` Q. I would also like to caution you not to
`discuss the substance of your testimony with
`counsel during any breaks.
` Do you understand that?
` A. Yes.
` Q. I understand that you may have some hard
`copies. Can you please tell me what hard copy
`documents you may have with you?
` A. I have unmarked copies of my
`declarations, the patents, and some of the cited
`prior art, main ones.
` Q. Okay. And I have placed various
`electronic copies of documents in the chat window
`of this Zoom, and I believe that either the
`attorneys there or you should be able to access
`that. And if you are at any time unable to access
`the electronic copies, just let me know, and I
`will see what we can do. Okay?
` A. Okay.
`
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 10 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 11
` Q. I would just ask, sir, that if you do
`refer to any documents other than the ones that I
`am providing to you in the chat window, that you
`please let me know so that there is no confusion
`about which documents are being discussed.
` Is that okay?
` A. Okay.
` Q. And I will just mention that because
`some of the prior art references appear in various
`ones of the IPRs, I have put in the chat window
`just a single copy of each one just, you know, to
`reduce the amount of clutter. But if there's any
`confusion about which document is for which IPR,
`please just ask me, and I will certainly clarify.
`Okay?
` A. Okay.
` Q. We're here today to discuss certain IPR
`proceedings that you provided declarations in.
` Do you understand that?
` A. Yes.
` Q. Specifically, there are seven IPR
`proceedings. They are IPR 2024-00001, -00016,
`
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 11 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 12
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`-00017, -00018, -00019, -00020, and -00021.
` Do you understand that?
` A. Yes.
` Q. For brevity, I'm going to suggest some
`short-form notations so that we can easily refer
`to these various IPRs. I may refer to the IPRs by
`the last three digits of the patent that is
`challenged in each IPR.
` For example, the IPR who's last five
`digits are 00001 may be referred to as the
`"'481 IPR" or the "'481 patent IPR," because the
`patent that is challenged in that IPR has '481 as
`its last three digits.
` Is that okay?
` A. Yes.
` Q. And, likewise, the 00016 IPR will be the
`"'842 patent IPR" or just the "'842 IPR," for
`short.
` Is that okay?
` A. Yes.
` Q. And the 00017 IPR, we will call it the
`"'195 patent IPR" or the "'195 IPR."
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 12 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 13
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` Is that okay?
` A. Yes.
` Q. And the 00018 IPR is going to be called
`the "'502 patent IPR" or "'502 IPR." Okay?
` A. Yes.
` Q. And the 00019 IPR will be called the
`"'014 patent IPR" or the "'014 IPR." Okay?
` A. Yes.
` Q. And since you provided two declarations
`in two IPRs against a patent who's three digits
`end in '222, I will say that the -00020 IPR will
`be called "'222 IPR No. 1," and the -00021 IPR is
`"'222 IPR No. 2." Okay?
` A. Okay.
` Q. Of course, you know, these are arbitrary
`kind of notations here, and I'm just trying to
`find a way to easily discuss these with you. And
`if you have any confusion or if you want to refer
`to it in another way that's easily comprehensible,
`that is fine. Okay?
` A. Okay.
` Q. I may refer to these seven IPRs
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 13 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 14
`
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`collectively in some short form, such as "the
`present IPRs" or "these IPRs." Okay?
` A. Okay.
` Q. You understand that Cirrus Logic and
`OmniVision Technologies are the remaining
`petitioners in these IPRs and that Greenthread LLC
`is the patent owner in these IPRs?
` A. Yes.
` Q. I will just call Cirrus Logic by
`"Cirrus" for convenience. Okay?
` A. Okay.
` Q. Have you done any work on behalf of
`Cirrus and OmniVision before the present IPRs?
` A. No. Do you mean technical research or
`legal work?
` Q. Anything.
` Can you please explain fully if you have
`done any work on behalf of Cirrus Logic or
`OmniVision prior to these IPRs?
` A. I've not done any research with either
`company. I cannot recall offhand if I represented
`either of these companies as part of litigation
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 14 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 15
`work. You have my CV, and that is my litigation
`background.
` Q. Thank you.
` A. I may have worked for OmniVision in a
`previous case, but I don't remember exactly.
` Q. Do you perhaps have the ability during a
`break today to kind of explore what, if anything,
`you may have done for OmniVision in a previous
`case?
` A. I don't have my computer with me.
` Q. May I suggest perhaps during a break you
`could check with, I believe, OmniVision's counsel,
`maybe either on the teleconference or with your
`own attorneys. If you could somehow please follow
`up, I may ask a follow-up question about that.
` Is that okay?
` A. Okay.
` Q. You submitted declarations in these
`IPRs; right?
` A. Yes.
` Q. For convenience, I'll refer to the
`declaration that you submitted in the '842 IPR as
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 15 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 16
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`"your '842 declaration." Okay?
` A. Okay.
` Q. And I'll use a similar convention for
`the other declarations, for example, '481
`declaration, '195 declaration, and so forth.
`Okay?
` A. Okay.
` Q. And for short convenience, I may refer
`to your declarations in all of these IPRs as just
`"your declarations." Okay?
` A. Okay.
` Q. And I'll call the patents at issue in
`these IPRs "the challenged patents." Okay?
` A. Okay.
` Q. And I may refer to the claims that are
`challenged in these IPRs by the petitioner of
`these IPRs as "the challenged claims." Okay?
` A. Okay.
` Q. If you have any question or uncertainty
`at any time about which patent or IPR or claim is
`being mentioned, please just mention it, and I
`will do my best to clarify. Okay?
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 16 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 17
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` A. Okay.
` Q. Dr. Banerjee, have you been deposed
`before?
` A. Yes.
` Q. Can you tell me about how many times you
`have been deposed before?
` A. Once again, it's in my CV, but off the
`top of my head, I think about between a dozen and
`two dozen times, I think.
` Q. Do you know if that was only district
`court cases or at the PTAB only or some
`combination?
` A. I've done IPRs -- or PTABs, several
`ITCs, and one district court.
` Q. Thank you.
` About how many times have you worked on
`behalf of patent owners in any kind of legal
`proceeding?
` A. You mean for the plaintiff as opposed to
`the defendant?
` Q. Yeah, if it's in district court,
`typically a patent owner would be the plaintiff.
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 17 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 18
`
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`If it's before the PTAB in an IPR, the patent
`owner is identified as the patent owner. I'm just
`trying to get a sense of about how many times
`you've done work in any of those types of legal
`proceedings on behalf of patent owner?
` A. I believe it's about 50/50.
` Q. Okay. Thank you.
` Have you prepared expert invalidity or
`validity reports in district court or ITC cases
`before?
` A. Once again, I don't remember exactly. I
`remember I've been in front of the ITC, I think,
`three or four times. District court, only once,
`the Northern District of California. And then
`quite a few PTABs.
` Q. Okay. Have you ever testified in person
`at a trial in district court or at a hearing at an
`ITC proceeding?
` A. Yes.
` Q. About how many times have you testified
`in person at a trial or an ITC hearing?
` A. I remember district court it's been only
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
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`Greenthread Ex. 2058, p. 18 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
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`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 19
`once. The other cases settled before it went to
`trial. ITC, I think four or five times. But it's
`in my CV.
` Q. In the district court case where you
`testified at trial, do you know if that was
`regarding infringement, noninfringement, validity,
`invalidity, or some combination?
` A. It's been a while. I remember I was
`representing Rambus against Samsung. I don't
`remember. It's quite a few years.
` Q. That's okay.
` And about how many times have you worked
`on behalf of a petitioner in an IPR?
` A. Once again, I don't remember exactly. I
`listed all my litigation experience in my CV. My
`impression is it's been about -- so I've done
`about -- I've worked on about a dozen cases where
`there's been substantial work such as writing
`expert reports or being deposed. In many of the
`cases, you get hired, and then it settles before
`you do any significant work. So I did not list
`those.
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`202-232-0646
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`Greenthread Ex. 2058, p. 19 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 20
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` Of the cases where I did substantial
`work, I believe there's about two dozen of those.
`I think the split's been roughly 50/50 I've been
`working for the plaintiff or the defendant. And
`I've underlined them in my CV, the party that I
`was working for.
` Q. Thank you.
` Dr. Banerjee, without telling me the
`substance of any communications you may have had
`with counsel, can you tell me what you have done
`to prepare for your deposition today?
` A. I met with counsel yesterday and then --
`the morning yesterday and...
` Q. Can you tell me approximately the length
`of time that you spent in preparing for today's
`deposition, whether spread out over multiple days
`or over a single day, just kind of a total?
` A. So during July -- I spent a lot of time
`over the last two days, I'd say ten-plus hours.
`And prior to that, during this month, I spent, you
`know, whenever I had some free time, maybe three,
`four hours. So I would say maybe 60 -- maybe 60,
`
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`202-232-0646
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`Greenthread Ex. 2058, p. 20 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 21
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`70 hours total this month.
` Q. Okay.
` A. Prior to that -- prior to that, I didn't
`do that much work on it. As you know better than
`me, you work in spurts, right. So you put in a
`fair bit of effort when you write the reports, and
`then I don't do much work. And then you do more
`work before the deposition.
` Q. You mentioned that you met with counsel
`yesterday. And can you please tell me who -- if
`you are able to remember, who was in attendance?
` A. The same folks who are in the room
`today.
` Q. Okay. And can you tell me what
`documents, if any, you reviewed in preparing for
`today's deposition?
` MR. PAUL: I'll just caution the
`witness, again, to the extent you can without
`involving conversations with counsel.
` THE WITNESS: Thank you.
` I reviewed my declarations, the patents,
`and the key prior art.
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 21 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 22
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`BY MR. JAIRAM:
` Q. Okay. And I think we will be talking
`about each of those things a little bit later here
`today.
` Regarding the declarations, can you tell
`me who wrote the declarations that you submitted
`in these IPRs?
` A. These are my declarations that capture
`my opinions. Of course, you prepare them in
`collaboration with the attorneys.
` Q. Okay. And approximately how long did
`you spend writing the declarations? I would say
`in total there's seven declarations. So if you
`could give a ballpark on how long you spent
`preparing all of the declarations.
` A. I'm guessing, I don't remember exactly,
`but certainly 100-plus hours.
` Q. Okay. Can you tell me about how much
`money you have billed so far to anyone for your
`work in these seven IPRs?
` A. I don't have the breakdown per IPR, but
`I think I have a round sense of the total amount.
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 22 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 23
`Probably -- not counting work done this month, for
`which I've not submitted expenses, I believe
`it's -- I'll do a rough $100,000.
` Q. Okay.
` A. Maybe less.
` Q. Okay. Thank you.
` Dr. Banerjee, do you have a typical
`process that you follow when drafting a report or
`a declaration?
` A. I generally leave it up to the
`attorneys. So in a few cases they've asked me to
`write reports from scratch. For example, in the
`Rambus/Samsung case, I remember they had me draft
`it from scratch, and then they edited it. But in
`general, it's a collaborative process with the
`attorneys, and that has been the case in this
`case.
` Q. Okay. Can you tell me what your current
`job title is, please?
` A. I'm the Cockrell Chair Professor of
`Electrical and Computer Engineering at the
`University of Texas at Austin. And I'm also
`
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`
`Greenthread Ex. 2058, p. 23 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 24
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`director of Microelectronics Research Center.
` Q. Do you hold any other job titles besides
`those two?
` A. I'm on the advisory board start-up, but
`no, other than that, no.
` Q. What is the start-up?
` A. The name of the company is Applied Novel
`Devices.
` Q. Is that start-up listed on your CV that
`you submitted?
` A. Yes.
` Q. Okay. Apart from that start-up, have
`you held any other jobs outside of academia?
` A. Yes. After I got my Ph.D., I started
`working for Texas Instruments in Dallas.
` Q. Did you know the inventor of the
`challenged patents before the present IPRs?
` A. So I did not work with him. I heard him
`speak at a couple of company meetings, but
`subsequently, I did meet him in connection with
`another patent case where we were on the same side
`as experts.
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 24 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 25
` Q. So we're referring to Dr. Rao, who is
`the named inventor of the challenged patents. And
`you understand that he was previously employed by
`Texas Instruments; right?
` A. Yes.
` Q. Did your time of employment at Texas
`Instruments include any time at which Dr. Rao was,
`as far as you're aware, also at Texas Instruments?
` A. Yes, we overlapped.
` Q. And what impression did you have of
`Dr. Rao at the time that there was overlap?
` MR. PAUL: Objection; form.
` THE WITNESS: As I said, I did not have
`any technical interactions with him. I was a part
`of the corporate research and development group.
`He was in one of the business units, I believe is
`the name of that group. So I had no technical
`interactions with him.
`BY MR. JAIRAM:
` Q. Apart from -- strike that.
` Had you heard anyone else relay any
`impressions of Dr. Rao to you in connection with
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`
`202-232-0646
`
`Greenthread Ex. 2058, p. 25 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 26
`the time when you were both at Texas Instruments?
` MR. PAUL: Objection to form.
` THE WITNESS: I don't recall.
`BY MR. JAIRAM:
` Q. When you heard Dr. Rao speak at a couple
`of company meetings, were those meetings giving
`you an impression of Dr. Rao?
` MR. PAUL: Objection to form.
` THE WITNESS: It's been 40 years, I
`believe. And I think I heard him only once at a
`meeting, and it was a sort of general pep talk to
`the troops. So I -- at this point, I can't think
`of having any impression, positive or negative.
`BY MR. JAIRAM:
` Q. Was Dr. Rao ever your supervisor or in
`your supervisory line of command?
` A. No, as I said, I was part of the
`corporate R&D group, he was in a business unit.
`No overlap.
` Q. Do you know if Dr. Rao's role in the
`business unit would have had any influence or
`control over anything that you did at Texas
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`202-232-0646
`
`Greenthread Ex. 2058, p. 26 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 27
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`Instruments?
` MR. PAUL: Objection to form.
` THE WITNESS: I don't believe so. As a
`fresh Ph.D. out of college, I was kind of focused
`on the technical part.
`BY MR. JAIRAM:
` Q. Did you ever read any of Dr. Rao's
`technical publications when you were at Texas
`Instruments?
` A. No.
` Q. Have you ever subsequently read any of
`Dr. Rao's publications after your time at Texas
`Instruments ended?
` A. Other than these patents that have been
`asserted, I don't think so.
` Q. Okay. Can you tell me about the subject
`matter, in a broad sense, that you worked on at
`Texas Instruments?
` A. Yes, I was a part of the team, that
`being the world's first 4-megabit DRAM, D-R-A-M,
`dynamic random access memory.
` (Reporter seeks clarification.)
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 27 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 28
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` THE WITNESS: DRAM, D-R-A-M, is the
`acronym. It stands for dynamic random access
`memory.
` (Reporter seeks clarification.)
` THE WITNESS: Yeah, 4-megabit,
`M-E-G-A-B-I-T.
`BY MR. JAIRAM:
` Q. Have you ever applied for a patent
`regarding any work of yours, either the
`memory-related work that you just mentioned or any
`other work?
` A. Yes, I have 35 patents, some when I was
`at TI, and then some when I've -- when I joined
`the University of Texas. Those are listed in my
`CV. And I was elected a fellow of the National
`Academy of Inventors based on my patent
`portfolios.
` Q. Can you tell me why you left TI?
` A. I always wanted to be in academia. And
`for me it was not a question of if, but when. I
`have a younger brother who also is an electrical
`engineer, went to the same school for his Ph.D. at
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2058, p. 28 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 29
`Illinois and then he joined academia right away
`and he was enjoying it a lot.
` So when I joined TI, my intention was
`always to join academia, but I wanted some
`industry experience. So that's why I switched. I
`had a great time at TI. I love the company.
` Q. Okay. Did you work on trench capacitor
`DRAM at TI?
` A. Yes. I worked on the physics of those
`memory cells.
` Q. Did trench capacitor DRAM become
`commercially successful?
` MR. PAUL: Objection to form.
` THE WITNESS: The idea of trench
`capacitors was used in many different DRAM
`memories by multiple companies, and some of those
`in that time frame did become successful.
`BY MR. JAIRAM:
` Q. Did stacked capacitor DRAMs eventually
`become what was more commonly used compared to
`trench capacitor DRAM?
` A. Given from the time frame that you're
`
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`Greenthread Ex. 2058, p. 29 of 168
`Cirrus Logic, et al. v. Greenthread
`IPR2024-00016
`
`
`
`7/19/2024
`
`Cirrus Logic, Inc. et al. v. Greenthread, LLC
`
`Sanjay Banerjee, Ph.D.
`
`Page 30
`looking at, in more recent times, indeed, stacked
`capacitors have become more popular than trench
`capacitors.
` Q. Around the time that you left Texas
`Instruments, were stacked capacitor DRAMs
`beginning to replace trench capacitor DRAMs?
` A. I don't remember exactly, but I think
`so. There are two camps, that stacked capacitor
`camp and the trench capacitor camp, and they were
`both being researched.
` Q. Did Texas Instruments begin to phase out
`research in trench capacitor DRAMs about the time
`that you left Texas Instruments?
` A. Once again, I don't recall exactly, but
`I think so. They got out of the memory business a
`few years later. I do remember that.
` Q. Do you know how long Dr. Rao -- just a
`ballpark estimate, do you have any idea of how
`long Dr. Rao worked at Texas Instruments?
` A. I know that