6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 1
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`___________________________
`GREENTHREAD, LLC,
`)
` Plaintiff,
`
`))
`
`VS. ) Civil Action No.
`) 1:23-cv-00369-DC
`CIRRUS LOGIC, INC., )
` Defendant. )
`___________________________)
`
`CONFIDENTIAL - OUSIDE ATTORNEYS' EYES ONLY
`ORAL AND VIDEOTAPED DEPOSITION OF
`SCOTT WARRICK
`JUNE 7, 2024
`
`Reported by: Donna Wright, CSR
`
`____________________________________________________
`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. 2083, p. 1 of 118
`Semiconductor v. Greenthread
`
`
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 1
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`___________________________
`GREENTHREAD, LLC,
`)
` Plaintiff,
`
`))
`
`VS. ) Civil Action No.
`) 1:23-cv-00369-DC
`CIRRUS LOGIC, INC., )
` Defendant. )
`___________________________)
`
`CONFIDENTIAL - OUSIDE ATTORNEYS' EYES ONLY
`ORAL AND VIDEOTAPED DEPOSITION OF
`SCOTT WARRICK
`JUNE 7, 2024
`
`Reported by: Donna Wright, CSR
`
`____________________________________________________
`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. 2083, p. 1 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 6
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` THE VIDEOGRAPHER: Here begins the
`deposition of Scott Warrick taking place at
`2801 Via Fortuna in Austin, Texas, in the matter of
`Greenthread, LLC versus Cirrus Logic, Inc., filed in
`the United States District Court for the Western
`District of Texas, Austin Division. The cause number
`is 1:23-CV-00369.
` Today's date is June 7, 2024, and the
`time is 8:13 a.m. Will counsel please identify
`themselves for the record, after which the court
`reporter will swear in the witness.
` MR. MATICH: Nick Matich of McKool Smith
`for the plaintiff, Greenthread.
` MR. OZARKAR: Neil Ozarkar from McKool
`Smith for the plaintiff Greenthread as well.
` MR. LIDDELL: Andrew Liddell for the
`defendant Cirrus Logic, and I'm joined today by my
`colleague Bert Greene, also with Duane Morris, and
`Cirrus Logic's in-house counsel, Michelle Connors.
` THE REPORTER: Okay. Will you raise your
`right hand, please?
` (Witness sworn.)
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 2 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 7
` MR. LIDDELL: Nick, before we begin, I
`would like to designate this entire transcript
`confidential, outside attorneys' eyes only.
` And note for the record today that Mr.
`Warrick is being put up for Topics 24, 25, 28, 29, 31,
`32, 60, 79, 80, 81, 82, 83 and 84 of Greenthread's
`30(b)(6) notice.
` MR. MATICH: Okay. Thank you. We will
`note your designation. Obviously we will see where the
`deposition goes to see if the designation is
`appropriate. And we can get started.
` MR. LIDDELL: I would also just to like
`note for the record that Mr. Warrick has also been
`noticed for his personal deposition, and so any
`testimony outside the scope of designated topics is in
`his personal capacity.
` SCOTT WARRICK,
`having been first duly sworn, testified as follows:
` EXAMINATION
`BY MR. MATICH:
` Q. Okay. Good morning, Mr. Warrick.
` A. Good morning.
`
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 3 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 14
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`it.
` Q. And, again, if you want to see more of any
`document that I show you, you can ask the tech and he
`will scroll -- scroll through it.
` What's your understanding of what this
`document is?
` A. This is the -- this is the suit against Cirrus
`Logic and the underlying claims and questions, as I
`understand it.
` Q. Okay. So would -- do you also understand that
`this document lays out topics on which you are here to
`testify?
` A. Yes.
` Q. Okay. And is the list of topics that
`Mr. Liddell read at the beginning the list of topics on
`which you are here to testify?
` A. Can we repeat that list and go through these?
` Q. Sure. So can we go to --
` A. What page is this?
` Q. -- Topic 24.
` A. Yes.
` Q. Sorry, that's --
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 4 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 15
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` A. Sorry. That's Topic 24.
` Q. Oh, yes, okay.
` So you are here to testify on Topic 24?
` A. Correct.
` Q. And 25?
` A. That's correct.
` Q. And 28?
` A. That's correct.
` Q. 29?
` A. That's correct.
` Q. 31?
` A. That's correct.
` Q. 32?
` A. That's correct.
` Q. 60?
` A. That's correct.
` Q. 79?
` A. That's correct.
` Q. 80?
` A. That's correct.
` Q. 81?
` A. That's correct.
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 5 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 16
`
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` Q. 82?
` A. That's correct.
` Q. 83?
` A. That's correct.
` Q. And 84?
` A. That's correct.
` Q. Great.
` And is it your understanding that your
`answers in response to questions for those topics are
`binding on Cirrus Logic?
` A. That is my understanding.
` Q. So I'm going to -- I want to ask you if you
`talked to certain people in preparing for today's
`deposition, and I'm just going to read their names and
`if you can tell me whether or not you spoke to them --
` A. Okay.
` Q. -- to prepare for today's deposition?
` A. Okay.
` Q. Zhonghai Shi?
` A. No, I did not.
` Q. Marc Tarabbia?
` A. Yes.
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 6 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 27
`
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` A. That is Mayank Shah.
` Q. Can you spell that?
` A. M-A-Y-A-N-K, S-H-A-H, I'm going to believe.
` Q. Okay. And did you speak to any of his
`subordinates?
` A. I did not.
` Q. Okay. And what did you -- what did you talk
`to him about?
` A. I talked to him specifically about tool -- I'm
`sorry, the failure analysis tools, equipment,
`techniques, as well as any outside use of such
`techniques at various labs.
` I also discussed with him -- because he
`is a long-term Cirrus employee, I discussed with him
`past -- you know, past employees, past -- past working
`methodologies, these type of things.
` Q. Okay. Let's go back to Alex Barr for a
`second.
` So you -- you said he's part of the
`silicon technology group?
` A. Correct.
` Q. Is he in the silicon technology development
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 7 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 28
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`group?
` A. Yes, he is.
` Q. And what did you talk to him about?
` A. We discussed a number of topics.
`Specifically, we reviewed the patents from -- from this
`case, both the -- both the patents that you -- or that,
`I guess, are involved in the lawsuit, as well as the
`list of patents that -- that was in question, one of
`the questions. I forget which one. So we discussed
`all of that.
` We additionally discussed -- discussed a
`good number of topics about -- regarding, I guess, the
`patents in general.
` Q. And what did Mr. Barr tell you about
`Greenthread's patents?
` A. So we discussed the -- we discussed the patent
`claims. We discussed prior art. We discussed physics
`of -- the physics of what is happening to -- to, you
`know, carriers. We discussed -- yeah, I guess that
`would summarize in large tail what we discussed.
` Q. What did you discuss with regard to the
`patents in -- that are listed in the 30(b)(6) notice --
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 8 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 29
`or, sorry, the Cirrus Logic patent applications that
`are listed in this 30(b)(6) notice?
` A. Yeah, can we go to that page?
` Q. Yeah.
` MR. MATICH: Can we pull up Tab 1, which
`is -- yeah, it's already been marked as -- I believe
`it's Exhibit 3. If we go down to Topic 80. I'm sorry,
`keep going down.
` THE WITNESS: I believe it was before
`that.
` Q. (BY MR. MATICH) Yeah, can we go to topic --
` A. I want to say 34 or something in there. I
`don't have it in front of me, though.
` Q. Sorry. Topic 83.
` A. Sorry about that.
` Q. All right. So just so there is a clear
`record, you discussed with Mr. Barr the patent
`applications listed in Topic 83 of the 30(b)(6) notice?
` A. I did.
` Q. And what did he tell you about those patent
`applications?
` A. We went through the patent applications. I
`
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 9 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 30
`don't -- we just discussed them. I'm not sure he told
`me any conclusion. We discussed each patent
`application.
` Q. And you said you discussed the -- with him the
`physics of carrier movement in relation to
`Greenthread's patents; is that correct?
` A. Correct.
` Q. And what did -- what did Mr. Barr say?
` A. You know, we just discussed how the -- how the
`carriers would be moving versus the claims in the
`patent. I'm not sure he had a conclusion to it.
` Q. Okay. All right. So then you also discussed
`with the -- with Justin Dougherty?
` A. Correct.
` Q. And what did you discuss with Mr. Dougherty?
` A. The overall -- I would say the overall case,
`the involvement -- you know, the involvement of myself
`and the patent applications and just the overall kind
`of review of it.
` Q. What did he tell you as part of those
`conversations?
` A. No -- no conclusions of anything. It was a
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 10 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 38
`you're talking about the patents listed in Topic 83 or
`Greenthread's patents.
` A. Greenthread's patents, yeah.
` Q. Okay.
` A. I did refresh myself with the -- specifically
`the patent in No. 83, which I am listed on, because I
`didn't recall -- I recall it was abandoned, but I
`didn't recall it. I specifically read that one over.
` But I refreshed my understanding of
`Greenthread patents.
` Q. And all told, about how many hours did you
`spend preparing for this deposition?
` A. Between -- I would say, in earnest, between
`January and today, 80-plus hours or something, you
`know.
` Q. Okay. So the -- this deposition wasn't
`noticed until May.
` A. Correct.
` Q. So how did you start preparing in January?
` A. So in January I was in -- I was in Asia, and
`specifically I was meeting with the foundries, TSMC in
`this case. I had -- I was -- I had a discussion with
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 11 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 39
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`TSMC, TD and TSMC counsel about the -- about
`Greenthread's claims and patents and -- and I continued
`to just kind of keep my understanding of what was --
`what was going on.
` So from that point until, in earnest,
`discussions with people for the deposition, I mean,
`that's where I started having, you know, more detailed
`discussions about -- about you know, the people
`involved and refreshing myself on all of that.
` Q. Okay. But focusing on the period since the
`deposition was noticed --
` A. Uh-huh.
` Q. -- about how much time did you spend
`preparing?
` A. What day -- so May 27, roughly. I don't know.
`I mean, call it ten to 12 hours.
` Q. Okay. Great.
` MR. MATICH: Could we pull up Tab 2 and
`mark it as -- are we on Exhibit 4?
` EXHIBIT TECH: We're on Exhibit 4.
` (Exhibit 4 marked)
` Q. (BY MR. MATICH) Mr. Warrick, I'm going to --
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 12 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 40
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`Exhibit 4 is a series of screenshots of what I
`understand to be your LinkedIn profile. The -- it's
`formatted this way because you can't -- it's the
`easiest way to get the same information on one or two
`pages. There's actually two pages, so can we scroll to
`Page 2?
` So, Mr. Warrick, do you recognize the
`information that's in Exhibit 4?
` A. Yes.
` Q. Okay. Is this information from your LinkedIn
`profile?
` A. Yes.
` Q. Is there anything inaccurate in what's here?
` A. No.
` Q. Okay. Do you have other experience or
`education in the semiconductor field that is not
`represented in Exhibit 4?
` A. No.
` Q. Is there any professional or educational
`experience relevant to this case that is not
`represented in Exhibit 4?
` A. No.
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 13 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 71
` Q. What's your understanding of n+ and n- and p+
`and p-?
` A. I mean, the normal -- the normal lexicon, for
`lack of a better word, is -- p+ is a heavily-doped or
`more heavily-doped p-type region. The n+ would be
`similarly a more heavily-doped n-type region.
` N-, keeping with the same, you know, kind
`of structure, the n- would be a lesser-doped region.
` Q. Does the temperature of a device affect
`carrier motion?
` A. Can you clarify for me, are you talking
`operating temperature or what -- what are we talking
`about?
` Q. Just in general, in a transistor, if it gets
`hotter, does a carrier -- is there more resistance to
`carrier motion?
` A. So for transistor self-heating, yes, it
`affects carrier mobility.
` Q. And what is transistor self-heating?
` A. Essentially the transistor, in operating, is
`becoming -- you know, becoming more -- becoming hot.
` Q. Is there anything that affects the ease of
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 14 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 72
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`carrier movement in a semiconductor device?
` A. So the ease of carrier movement in a
`semiconductor device, you know, the size of the device
`matters, the doping of the device matters, the
`potential on the device matters, the -- yeah, all of --
`I would say it's probably a long list of these type of
`physics attributes, which affect the movement of
`carriers.
` Q. Okay. Is silicon a resistor or a conductor,
`intrinsic silicon?
` A. It's a semiconductor.
` Q. The silicon without any doping in it, is
`that -- is that a conductor or a resistor?
` A. I mean, it's a semiconductor. Silicon without
`any doping would be a semiconductor.
` Q. Okay. What --
` A. It would have low level of conduction, you
`know, to -- to basically get it to be conductor, you
`need to have dopants.
` Q. But there's an inherent level of resistance in
`silicon?
` A. Correct.
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 15 of 118
`Semiconductor v. Greenthread
`
`
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`6/7/2024
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`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 91
`
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` A. Melanson.
` Q. Melanson?
` A. Yeah.
` Q. And he reports directly to the CEO?
` A. I would have to check that. That's my -- I
`can check and get back. I don't -- I assume that's who
`he reports to. I don't know.
` Q. Do all of the fellows report to the CEO?
` A. No.
` Q. Who are the other fellows that you are aware
`of?
` A. Axel Thomsen, Eric King and Paul Lesso.
` Q. Are they all in the United States?
` A. Three of the four are in the U.S.
` Q. Which one is not in the U.S.?
` A. Paul Lesso.
` Q. Is he based in the UK?
` A. Correct.
` MR. MATICH: Can we pull up Tab 5 and
`mark it as Exhibit 8?
` (Exhibit 8 marked)
` Q. (BY MR. MATICH) Have you seen -- Mr. Warrick,
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 16 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 92
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`have you seen Exhibit 8 before?
` A. Not in -- maybe not in its entirety. If you
`go down, maybe I can see if I have seen portions of it.
`I don't believe I have seen the entirety of it.
` Is this the -- is this the work that --
`that you had TechInsights do?
` A. It's a report by TechInsights.
` Q. Okay. I saw some of this.
` Q. Okay.
` A. I believe.
` Q. And you're welcome to scroll through it if you
`need to, or you can direct Henry to --
` A. Okay. Because I was -- my scroll is not --
` Q. Yeah, yours won't work. But if you want to
`direct Henry to go down.
` THE WITNESS: If you could maybe just go
`down and just let me make sure -- go down a little
`more. Yeah, keep going. Is this a teardown or -- keep
`going. Okay. Keep going. Next, please. Next,
`please. Next, please. Keep going. Keep going. Next,
`please. Next, please. Next, please. Next, please.
`Next, please. Next, please. Okay. Next, please.
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 17 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 93
`
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`Next, please.
` I don't know how many pages this is. Can
`you maybe just scroll to the end and go up from the
`bottom? I was just trying to see if this is the one
`where I think there was some analysis done by
`TechInsights of some analytical type things.
` Is that this report?
` Q. (BY MR. MATICH) I believe so.
` Can we go to Page 45?
` A. That would probably be easier.
` Q. Yeah. I want to give you the opportunity to
`familiarize yourself with the document.
` A. Yeah. So I have not seen the whole document,
`but I have seen portions of it.
` Q. Have you seen -- do you recognize Page 45?
` A. Yeah, probably. I mean, in a list of full
`things that I have looked at, yes.
` Q. Okay.
` MR. MATICH: And the -- could we zoom in
`on the part that says, "Source wells," in the image
`that has pink and yellow and purple, I guess.
` EXHIBIT TECH: Yeah.
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 18 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 94
`
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`
` Q. (BY MR. MATICH) Do you see the parts
`indicating source wells there?
` A. I do.
` Q. And do you see how it kind of grades from pink
`into purple where the arrows are pointing?
` A. Vertically?
` Q. Yes.
` A. Yes.
` Q. Okay. And what's your understanding of the
`significance of that color change?
` A. I mean, I'm not familiar with this technique.
`This -- but that is -- I assume that's looking at
`dopant gradients.
` Q. Okay. And the -- I also want to give you the
`chance to look at the legend on the right-hand side, if
`you want to discuss -- get some information on that.
` A. Yeah.
` Q. So it's your understanding that that change
`from pink to purple is a -- is a dopant gradient?
` A. That's what this is saying, yes.
` Q. Okay. Can you tell me if --
` MR. MATICH: Sorry, Henry. Can we zoom
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 19 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 95
`
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`
`in again on the source wells section there?
` Q. (BY MR. MATICH) Can you tell me if the
`gradient there would aid carrier movement downward?
` MR. LIDDELL: Objection, form.
` THE WITNESS: I cannot tell you that.
` Q. (BY MR. MATICH) Why not?
` A. I don't have an understanding of what the
`benefit of that gradient would be or the degradation of
`that gradient.
` Q. What do you mean by the degradation of the
`gradient?
` A. I don't understand the -- what that
`degradation result would be.
` Q. By degradation, I don't understand what you
`mean.
` A. I mean, it's -- the dopant has diffused.
` Q. Yeah.
` A. And so it's diffused for a reason. I don't,
`you know, know the reason it has diffused. It's
`naturally diffusing, of course, and there is -- you
`know, the fabs will diffuse it, but I don't know
`whether this is as intended or beyond intended.
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 20 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 96
` Q. And you can't tell me -- but can you tell me
`the -- leaving aside intent for a moment, you can't
`tell me what the effect of that gradient is?
` A. No.
` MR. LIDDELL: Objection, form.
` Q. (BY MR. MATICH) Okay. And why not?
` A. I don't know -- I don't -- you know, I don't
`have a knowledge of why that would be -- or the effect
`of that diffused grading here.
` Q. Is -- is that because there's other things
`that might affect carrier movement besides the
`gradient?
` A. Yes.
` MR. MATICH: Thanks. We can take this
`down.
` THE WITNESS: Is it potential for a bio
`break?
` MR. MATICH: Yes, we can go off the
`record.
` THE VIDEOGRAPHER: Going off the record.
`The time is 10:53.
` (Recess from 10:53 a.m. to 11:25 a.m.)
`
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 21 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 155
` Instruct the witness not to answer.
` THE WITNESS: I'll follow the advice of
`counsel.
` Q. (BY MR. MATICH) How many years have you been
`working in the semiconductor industry?
` A. I started with Motorola in '97 and I have been
`in the industry since.
` Q. All of those roles have been technical roles?
` A. They -- yeah, as I moved up I got into less
`and less technical roles. From '97 through -- through
`my stint in France, so 2007, and they were all
`technical roles primarily focused on the fab. I mean,
`I was in the fab, you know, working on stuff.
` 2007 to 2009, I was in design for
`manufacturing, so looking at the type of things you're
`talking about, how many -- how many contacts should be
`there to keep it from blowing up, these type of things.
` And then from 2009 to present day, time
`at Apple exclusive -- or excluded, I have been in, you
`know, more management roles.
` Q. But your current role is still sufficiently
`technical that you're applying for patents with your
`
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 22 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 156
`
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`
`name on it?
` A. Yeah, it's still sufficiently technical. I
`would say as technology continues to speed down the
`path, I find myself, you know, less and less attuned to
`exactly what's going on, you know, in semiconductors
`for sure. But, you know, that's -- I think that's kind
`of natural.
` Q. You mentioned working at fabs?
` A. Correct.
` Q. Which fabs did you work at?
` A. So I was at -- I started at Motorola when it
`had fabs, Motorola fab in California. And they moved
`me here to fabs in Austin, I was at a couple fabs in
`Austin.
` I did an expat in France for four years
`at a -- at a three-way partnership between Philips
`Research, Motorola and STMicroelectronics. I was in
`that fab and then came back.
` Q. And that was from roughly 1997 to 2007?
` A. Yes, that's exactly when that was, yeah.
` Q. And what were you doing in those fabs?
` A. So initial roles, I started out in lithography
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 23 of 118
`Semiconductor v. Greenthread
`
`
`
`6/7/2024
`
`Greenthread, LLC v. Cirrus Logic, Inc.
`Confidential - Outside Attorneys' Eyes Only
`
`Scott Warrick
`
`Page 157
`and I was running lithography equipment. I mean, I was
`the -- I started out running photoresist track codes.
` And then I gradually moved into the
`optics side of it. So I was running -- I did a lot of
`work on Nikon and Cannon scanners. I had spent a lot
`of time at ASML working on emerging lithography. So
`those were the kind of roles I did.
` At the -- in the three-way partnership in
`France, I was the -- I was the lead of the gate module
`development.
` THE REPORTER: Gate?
` THE WITNESS: Gate, G-A-T-E, yeah.
` Gate module development, which was
`working on, at that time, 45-nanometer and 32-nanometer
`processes.
` Q. (BY MR. MATICH) What about between your role
`at Apple and your role at -- your current role at
`Cirrus Logic?
` MR. LIDDELL: Objection, form.
` THE WITNESS: Yeah, the role at -- the
`role at Apple -- first of all, I had no direct reports
`at Apple. So I was an individual contributor. I was,
`
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`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2083, p. 24 of 118
`Semiconductor v. Greenthread
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
`
`
`
`
`
`Civil Action No. 1:23-cv-00369-DC
`
`
`
`JURY TRIAL DEMANDED
`
`
`
`GREENTHREAD, LLC
`
`Plaintiff,
`
`vs.
`
`CIRRUS LOGIC, INC.
`
`Defendant.
`
`
`
`
`
`
`
`NOTICE OF DEPOSITION OF CIRRUS LOGIC, INC.
` PURSUANT TO FED. R. CIV. P. 30(b)(6)
`
`PLEASE TAKE NOTICE THAT pursuant to Federal Rule of Civil Procedure 30(b)(6),
`
`Plaintiff Greenthread, LLC (“Greenthread”) by and through its counsel, will take the deposition of
`
`Defendant Cirrus Logic, Inc. (“Cirrus Logic” or “Defendant”), upon the matters for examination
`
`identified in Schedule A below. This deposition will take place on June 21, 2024 at 9:00 AM local
`
`time at the offices of McKool Smith, 303 Colorado Street, Suite 2011, Austin, TX 78701, or such
`
`other time or location agreed to by the parties, before a Notary Public or other officer duly
`
`authorized to administer oaths. The deposition will take place within the time duration provided
`
`by Rule 30(d) and with the understanding, as provided in the Advisory Committee Notes to the
`
`2000 Amendment to Rule 30, that “the depositions of each person designated under Rule 30(b)(6)
`
`should be considered a separate deposition.” Notice is further given that the deposition testimony
`
`will be recorded by stenographic means, by videotape, and real time transcription services may be
`
`utilized.
`
`1
`
`Greenthread Ex. 2083, p. 25 of 118
`Semiconductor v. Greenthread
`
`
`
`
`
`PLEASE TAKE FURTHER NOTICE THAT pursuant to Fed. R. Civ. P. 30(b)(6),
`
`Cirrus Logic is required to designate one or more appropriate person(s) to testify fully on its behalf
`
`with respect to each of the topics listed in Schedule A, and the person(s) so designated shall be
`
`required to testify as to each of those matters known or reasonably available to Cirrus Logic.
`
`Please provide notice of the identity of the witness(es) you designate to Greenthread’s counsel no
`
`later than ten (10) days prior to the date of the deposition.
`
`Dated: May 24, 2024
`
`MCKOOL SMITH, P.C.
`
`/s/ Alan L. Whitehurst
`Alan L. Whitehurst
`D.C. Bar No. 484873
`awhitehurst@mckoolsmith.com
`Nicholas J. Matich
`D.C. Bar No. 1024907
`nmatich@mckoolsmith.com
`Arvind Jairam
`D.C. Bar No. 1017133
`ajairam@mckoolsmith.com
`MCKOOL SMITH, P.C.
`1999 K Street NW
`Washington, DC 20006
`Telephone: 202-370-8300
`Telecopier: 202-370-8344
`
`
`Samuel F. Baxter
`Texas Bar No. 01938000
`sbaxter@mckoolsmith.com
`Jennifer Truelove
`Texas Bar No. 24012906
`jtruelove@mckoolsmith.com
`MCKOOL SMITH, P.C.
`104 East Houston Street, Suite 300
`Marshall, TX 75670
`Telephone: 903-923-9000
`Telecopier: 903-923-9099
`
`John B. Campbell
`Texas Bar No. 24036314
`jcampbell@mckoolsmith.com
`MCKOOL SMITH, P.C.
`
`2
`
`Greenthread Ex. 2083, p. 26 of 118
`Semiconductor v. Greenthread
`
`
`
`303 Colorado Street, Suite 2100
`Austin, Texas 78701
`Telephone: 512-692-8700
`Telecopier: 512-692-8744
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`ATTORNEYS FOR PLAINTIFF
`GREENTHREAD, LLC
`
`
`
`
`
`
`
`3
`
`Greenthread Ex. 2083, p. 27 of 118
`Semiconductor v. Greenthread
`
`
`
`DEFINITIONS
`
`For the purposes of these requests, the following definitions shall apply:
`
`1.
`
`The term “Action” refers to the above-captioned action, Greenthread, LLC v.
`
`Cirrus Logic, Inc., No. 1:23-cv-00369 (W.D. Tex.).
`
`2.
`
` “Accused Products” is defined as the products identified and discussed in
`
`Greenthread’s Complaint and/or Infringement Contentions, Including any supplements or
`
`amendments thereto. Accused Products include products made (in whole or in part), used, sold,
`
`offered for sale, or imported into the United States by Cirrus Logic or its customers, that comprise
`
`or consist of the same or similar structures, features, or functionalities as the exemplary Cirrus
`
`Logic CLI1793B1 power management integrated circuit identified in and discussed in
`
`Greenthread’s Complaint and/or Infringement Contentions. Accused Products include, but are not
`
`limited to, the following product categories/types: amplifiers, decoder and encoder integrated
`
`circuits (ICs), digital-to-analog converters, analog-to-digital converters, digital clocks, haptic
`
`drivers, voice processor ICs, and other ICs. Accus
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