10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 1
` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________
`MONOLITHIC POWER SYSTEMS
`) IPR 2024-00468
`INC.,
`) Patent No. 8,421,195
`)
`Petitioner, ) IPR 2024-00469
`) Patent No. 9,190,502
` V. )
`) IPR 2024-00470
`) Patent No. 11,121,222
`GREENTHREAD, LLC, )
`Patent Owner. )
`______________________________)
`
`REMOTE DEPOSITION OF
`STEPHEN A. CAMPBELL, PH.D.
`
`October 17, 2024
`9:00 a.m. Central Daylight Time
`
`Reported by: Lori J. Goodin, RPR, CRR, RSA,
`California CSR #13959
`____________________________________________________
`DIGITAL EVIDENCE GROUP
`1730 M Street, NW, Suite 812
`Washington, D.C. 20036
`(202) 232-0646
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 1 of 68
`Semiconductor v. Greenthread
`
`
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 1
` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________________
`MONOLITHIC POWER SYSTEMS
`) IPR 2024-00468
`INC.,
`) Patent No. 8,421,195
`)
`Petitioner, ) IPR 2024-00469
`) Patent No. 9,190,502
` V. )
`) IPR 2024-00470
`) Patent No. 11,121,222
`GREENTHREAD, LLC, )
`Patent Owner. )
`______________________________)
`
`REMOTE DEPOSITION OF
`STEPHEN A. CAMPBELL, PH.D.
`
`October 17, 2024
`9:00 a.m. Central Daylight Time
`
`Reported by: Lori J. Goodin, RPR, CRR, RSA,
`California CSR #13959
`____________________________________________________
`DIGITAL EVIDENCE GROUP
`1730 M Street, NW, Suite 812
`Washington, D.C. 20036
`(202) 232-0646
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 1 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 2
`
` REMOTE DEPOSITION of
` STEPHEN A. CAMPBELL, PH.D.,
`a Witness in the above-titled action, held on
`Thursday, October 17, 2024, commencing at
`approximately time 9:00 a.m. before Lori J.
`Goodin, RPR, CRR, RSA, California CSR #13959,
`Registered Professional Reporter, Certified
`Realtime Reporter, Realtime Systems
`Administrator, and Certified Shorthand Reporter,
`and Notary Public of the State of Florida, State
`of California, State of Maryland, District of
`Columbia, State of Delaware and Commonwealth of
`Pennsylvania.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 2 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 3
`
` REMOTE APPEARANCES:
`
` FOR THE PATENT OWNER:
` MCKOOL SMITH
` BY: NICHOLAS T. MATICH, ESQUIRE
` BY: ARVIND JAIRAM, ESQUIRE
` 1999 K Street Northwest, Suite 600
` Washington, D.C. 20006
` 202-370-8301
` nmatich@mckoolsmith.com
` ajairam@mckoolsmith.com
`
` FOR THE PETITIONER and WITNESS:
` PERKINS COIE
` BY: MIGUEL J. BOMBACH, ESQUIRE
` 11452 El Camino Real #300
` San Diego, California 92130
` 858-720-5747
` MBombach@perkinscoie.com
`
`Also Present:
` R. Justin Jiang, Perkins Coie
` Danny Ortega, Document Tech
`
`1
`
`23
`
`4
`5
`6
`7
`8
`9
`10
`
`11
`12
`
`13
`14
`
`15
`
`16
`17
`18
`19
`20
`
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 3 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 4
`
` INDEX TO EXAMINATION
`WITNESS: STEPHEN A. CAMPBELL, PH.D.
`
`EXAMINATION BY PAGE
`MR. MATICH 6
`
`1
`2
`
`3 4
`
`5
`
`6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 4 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 5
`
` INDEX TO EXHIBITS
` STEPHEN A. CAMPBELL
` Greenthread, LLC vs Monolithic Power Systems,
` Inc.
` Thursday, October 17, 2024
` Lori J. Goodin, RPR, CRR, RSA
` California CSR #13959
`CAMPBELL
`EXHIBIT DESCRIPTION PAGE
`Exhibit 1 Declaration of Stephen Campbell 11
`Exhibit 2 Figure 16 of US Patent 5,384,476 27
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 5 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 6
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
` THURSDAY, OCTOBER 17, 2024, 9:00 a.m. CDT
` PROCEEDINGS
` * * *
` THE REPORTER: Unless an objection
` is heard at this time, all parties to this
` deposition are appearing remotely and have
` agreed to the witness being sworn in
` remotely.
`
`Whereupon,
` STEPHEN ALAN CAMPBELL
`a witness called for examination, having been
`first duly sworn, was examined and testified as
`follows:
` * * *
` EXAMINATION
`BY MR. MATICH:
` Q. Good morning, Dr. Campbell.
` A. Good morning.
` Q. Could you please state and spell
`your full name for the record.
` A. My name is Stephen Alan Campbell,
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 6 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 7
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`S-T-E-P-H-E-N, A-L-A-N, C-A-M-P-B-E-L-L.
` Q. And, you are currently --
` What is your current occupation?
` A. I am retired from the University of
`Minnesota. So, I retain a status of Emeritus
`Professor of Electrical and Computer Engineering.
` Q. And where are you physically located
`right now?
` A. I am in Arden Hills, Minnesota, a
`suburb of the twin cities.
` Q. And what building are you located
`in?
` A. I am at my home which is 3248
`Sandeen Road, Arden Hills, Minnesota, 55112.
` Q. Is there anything that would prevent
`you from testifying completely and truthfully
`today?
` A. No.
` Q. You have no medical issues that
`would interfere with your ability to testify
`today?
` A. No.
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 7 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 8
` Q. You're not on any medications that
`would interfere with your ability to testify
`today?
` A. No.
` Q. You have no personal issues that are
`distracting you from your testimony today?
` A. No.
` Q. Have you ever been deposed before?
` A. No.
` Q. So, I assume that the Monolithic
`lawyers went over the rules of the deposition
`with you, but, I'll go over them now just so we
`have a record of it and to make sure you
`understand; is that okay?
` A. Yes, that's fine.
` Q. You understand that I'll ask you a
`series of questions and you are required to give
`truthful answers?
` A. Understood.
` Q. And you understand that you, the
`court reporter is going to be taking down
`everything that I say and everything that you
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 8 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 9
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`say?
` A. Yes.
` Q. And you understand that you need to
`wait for me to ask you a question and finish
`asking the question before you speak, because the
`court reporter can't take down two things at
`once.
` A. Yes.
` Q. So, I'll try and avoid starting a
`new question until you have finished your answer.
` And if you could do the same; avoid
`starting your answer until I have finished asking
`the question.
` Does that work?
` A. Yes, that's fine.
` Q. And you understand that the
`statements and testimony you're giving today are
`under oath?
` A. Yes.
` Q. And you understand that you're under
`the penalty of perjury?
` A. Yes.
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 9 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 10
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
` Q. And you understand that the
`testimony you are giving today is no different
`than if we were in a court of law or if there
`were officials at the Patent Office present
`before us?
` A. Yes.
` Q. What's your understanding of the
`nature of these proceedings?
` A. My understanding of the proceedings
`is that there are a series of patents that are
`owned by patent owner and these patents, the
`validity of these patents are being challenged.
` Q. And you understand that the patent
`owner is a company called Greenthread?
` A. Yes.
` Q. All right. So, if I refer to
`Greenthread or Greenthread's patents, you'll
`understand what I mean?
` A. Yes.
` Q. And, you understand that the patent
`challenger is a company called Monolithic?
` A. Yes.
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 10 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 11
` MR. MATICH: And, could we pull up
`Tab 1 and mark it as Exhibit 1.
` (Exhibit 1 marked for
` identification.)
`BY MR. MATICH:
` And, Dr. Campbell, during the course
`of this deposition, I'm going to show you some
`documents.
` I will primarily be showing you your
`declaration in these proceedings.
` But if you need to see any of the
`documents referenced in your declaration, feel
`free to ask and we can make that happen.
` A. All right.
` Q. And if I ask you a question and you
`need to see other portions of the document, you
`are free to direct the tech, Danny, to scroll to
`other parts of the document.
` A. All right.
` Q. Dr. Campbell, is Exhibit 1 your
`declaration in these proceedings?
` A. From this first page, I would say
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 11 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 12
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`yes.
` Q. If you need to look at the rest of
`the document to confirm that it's a complete and
`accurate copy of your declaration, please do
`that.
` A. All right. Are we going to go
`through 150 pages?
` Q. I am willing to represent to you
`that I believe this is the full and complete
`version.
` But if you want to verify for
`yourself, you're more than welcome to.
` A. I will take you at your word that it
`is a full copy.
` Q. Dr. Campbell, do you see about
`halfway up the first page of your declaration it
`says PTAB Case Numbers.
` And then it lists the IPR 2024-00468
`and then a patent number and then some other
`proceeding numbers?
` A. Yes. I can see that.
` Q. Is it your understanding that the
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 12 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 13
`IPR 2024- numbers represent, identify different
`proceedings on different patents?
` A. Yes.
` Q. And you understand that this
`declaration pertains to the proceedings and the
`patents listed here on the first page?
` A. Yes.
` Q. It is also -- is it your
`understanding that for Patent Number 11,121,222
`that today's deposition and these proceedings is
`only about Claim 44 in that patent?
` A. I don't, I did not know that. Okay.
` Q. And is it your understanding that
`there are other IPR proceedings in which you have
`submitted a declaration?
` A. This is the only declaration that I
`have submitted.
` Q. Okay. You didn't submit a
`declaration in IPR proceedings challenging other
`Greenthread patents?
` A. To the best of my knowledge, this is
`the only document that I produced.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 13 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 14
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
` Q. Okay. And you understand that
`across all of the proceedings in which you have
`submitted a declaration, there are some common or
`similar issues?
` A. Yes. Pretty much so.
` Q. And you understand that the claims
`in each of the patents use the same or similar
`language in parts --
` A. Yes. Sorry.
` Q. And did you interpret and apply the
`claim language consistently across all the
`patents?
` A. Yes.
` Q. Dr. Campbell, on your CV it says
`that you worked for several years as a consultant
`for a law firm called WilmerHale?
` A. Yes.
` Q. What was the nature of your work for
`WilmerHale?
` A. It was challenging a patent that was
`related to a process technology that the patent
`owner claimed that the company was infringing on
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 14 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 15
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`their patent.
` Q. Can you tell me who the accused
`infringer was?
` A. I don't think I'm allowed to
`disclose that. It's a major semiconductor
`fabrication company.
` Q. Can you tell me who the patent owner
`was?
` A. University of Arizona.
` Q. And is that the only case you worked
`on for WilmerHale?
` A. That's correct.
` Q. Was your work on that case made
`public?
` A. Not to the best of my knowledge.
` Q. So, you did not submit an expert
`report in that litigation?
` A. That is correct.
` Q. Is that the only time you've been
`involved in patent litigation?
` A. Yes.
` Q. Your CV also mentions a patent that
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 15 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 16
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`you applied for?
` A. Yes, that is true.
` Q. Is that the only patent you've ever
`applied for?
` A. Yes.
` Q. Did that patent issue?
` A. I was not the primary person on that
`patent. It was one of my colleagues.
` I don't know if it issued or not.
` Q. About how much work -- scratch that.
` About how many hours worth of work
`did you do for WilmerHale?
` A. This is, was several years ago.
` My guess would be somewhere between
`50 and 100 hours.
` Q. Over the course of three years?
` A. No, that took about a year. It
`could have been 18 months. Something like that.
` MR. MATICH: Could we scroll down to
`PDF Page 112.
` DOCUMENT TECHNICIAN: Sorry counsel,
` which page is that?
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 16 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 17
` MR. MATICH: The PDF Page 112. It's
` Appendix A. Next page, please.
`BY MR. MATICH:
` Q. Dr. Campbell, it lists here
`consulting 2019 to 2021 WilmerHale.
` A. Yes.
` Q. And that's what you were referring
`to?
` A. Yes. It was late '19 -- again, late
`2019 and wound up early 2021.
` Q. Okay. So, it wasn't, it spanned
`three calendar years, but the work was
`approximately a little more than a year?
` A. Yes.
` Q. Okay. What did do you to prepare
`for your deposition today?
` A. I re-read the patents that are
`subject to this process.
` And I re-read my declaration. And I
`looked at a few of the patents that we reference
`in the declaration.
` Q. Did you speak to anyone to prepare
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 17 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 18
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`for today's deposition?
` A. I had a session with lawyers from
`Perkins Coie to, since this is my first time
`going through a deposition, to tell me what to
`expect.
` Q. Which Perkins Coie lawyers did you
`talk to?
` A. Miguel Bombach, Justin Jiang, and
`Brianna, I'm sorry, I don't remember Brianna's
`last name off the top of my head.
` Q. And about how many hours did you
`spend talking to them?
` A. Six hours, I believe. Six hours,
`yes.
` Q. Was that all in one day?
` A. No, it was spread across three days.
` Q. And which three days?
` A. Monday, Tuesday, and Wednesday of
`this week.
` Q. Other than the prior art references,
`the Greenthread patents and your declaration, did
`you look at any documents in preparation for
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 18 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 19
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`today's deposition?
` A. Briefly. There was a couple of
`calculations that I wanted to do.
` And so, I looked up some things from
`books.
` But that whole process was probably
`less than 20 minutes.
` Q. And what calculations did you do?
` A. One was electric field calculations
`and dopant gradient, yes. That was the primary
`thing.
` Q. And, could you, what electric -- you
`were calculating the strength of an electric
`field?
` A. That's correct.
` Q. Which, what, where did you get the
`data for the electric field?
` A. Well, the proper question is where
`did I get the data for the doping profile,
`because once you have the doping profile, it's a
`straightforward calculation to get the electric
`field.
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 19 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 20
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
` I just assumed that a reasonable
`doping profile -- yeah, I will just put a period
`at that point.
` It was a reasonable doping profile
`for the types of technology that are under
`discussion here.
` Q. Okay. So, you didn't calculate the
`electric field for any of the prior art cited in
`your declaration?
` A. That's correct.
` Q. And, at any point in the past had
`you calculated the electric field for the doping
`profiles in the prior art cited in your
`declaration?
` A. Yes, I'm glad you asked that,
`because as you were phrasing your question, I
`realized that when I was writing the declaration,
`I did do the calculation of one of the profiles.
` And the reason that I was checking
`my numbers yesterday, was because I couldn't find
`my notes as to what the field was.
` So, I just wanted to get an order of
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 20 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 21
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`magnitude estimate.
` Q. Okay. And you couldn't find your
`notes from that prior calculation?
` A. That's correct.
` Q. Is there a reason you didn't look it
`up in your report?
` A. I don't think I wrote it in my
`report. That was just something from I -- I was
`curious.
` It wasn't something that I presented
`to the -- for the declaration.
` Q. Dr. Campbell, are you familiar with
`ways to measure the doping concentration?
` A. Yes.
` Q. Are you familiar with a technique
`called SRP?
` A. Yes. I have used it quite a bit.
` Q. What does SRP stand for?
` A. Spreading Resistance Profiling.
` Q. Okay. And could you describe for me
`how SRP works?
` A. Yes. If you want to measure the
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 21 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 22
`concentration of a dopant as a function of depth,
`you take a sample of a semiconductor wafer, you
`grind it at a very shallow angle and then you
`apply two probes that move across the top of the
`wafer and then down the bevel. You measure the
`resistance between the two probes.
` The resistance -- well, is dominated
`by current crowding near the tips of the probes
`and it's very sensitive to the local carrier
`concentration.
` So, when you measure resistance as a
`function of position and you know the bevel
`angle, you can then extract the doping
`concentration -- well, the active carrier
`concentration, to put it more accurately, as a
`function of depth.
` Q. Are you familiar with a technique
`called SCM?
` A. SCM. If you tell me what it stands
`for, I'll let you know if I've heard of it.
` Q. Scanning Capacitance Microscopy?
` A. I -- yes, I have heard it. I
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 22 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 23
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`haven't used that technique.
` Q. What do you know about SCM?
` A. Very, very little. I will plead
`ignorance on that one.
` Q. Are you familiar with a technique
`called SMIN?
` A. No, I have not.
` Q. Are you familiar with a technique
`called Simms?
` A. Yes, of course.
` Q. What is Simms?
` A. Simms is secondary IMS spectroscopy.
`This involves taking, again, a silicon wafer that
`has dopant in it, using a beam of argon or cesium
`or, I don't remember the third one.
` It blasts into the surface of a
`semiconductor and you have a mass spectrometer
`inside the vacuum system with the beam and the
`wafer, and you collect some fragment of the
`materials that are coming off.
` And by knowing -- you are measuring
`the chemical composition as a function of depth
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 23 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 24
`rather than the carrier concentration. Usually
`those two are about the same.
` But, in this case, it's a chemical
`analysis.
` MR. MATICH: Let's go to Page 27 of
`your report. Turn to Page 27, not 127.
` And actually, let's go up one page
`to Page 26.
`BY MR. MATICH:
` Q. Dr. Campbell, do you see in this
`section of your report, beginning on Page 26
`going to Page 27, you're discussing the
`background standard for determining whether or
`not something is obvious?
` A. Could we go out to the next page?
`Yes.
` Q. And you see the second bullet point
`there where you talk about any relevant factors,
`the secondary indicia indicating nonobviousness?
` A. Yes.
` Q. And you see the fourth line from the
`bottom where it says, "the taking of licenses
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 24 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`under the patent by others and the nature of
`those licenses"?
` A. Yes.
` Q. What about the nature of other, of
`licenses to the patents is relevant to
`determining, determining obviousness?
` A. Your question is more of a legal
`question than a technical question.
` So, I'm sorry, I can't answer that.
` Q. Okay. So, if I told you that
`someone had taken a license to a patent, how
`would that bear on your analysis of whether or
`not it was obvious?
` A. My understanding -- again, I am not
`a lawyer, I don't pretend to be a lawyer.
` But when you take out the license
`that means that you are able to use information
`in the patent in exchange for a fee. That's my
`understanding.
` It is not clear to me how that would
`affect obviousness.
` Q. Do you know if Greenthread has
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 25 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 26
`granted any licenses to the challenged patent?
` A. I was told that somebody, Intel, had
`a license.
` This is very early on. And so, I
`think that's what they told me.
` Q. And did you take that into
`consideration in your analysis?
` A. No.
` MR. MATICH: Could we go to Page 56
`of your report?
`BY MR. MATICH:
` Q. Dr. Campbell, do you see Page 56 of
`your report here?
` A. Yes.
` Q. Do you see it has got Figure 16 from
`the Nishizawa reference?
` A. Yes.
` Q. And the Nishizawa reference is one
`of the prior art references that you analyzed in
`your report?
` A. Yes.
` MR. MATICH: And actually, just so
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 26 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 27
`we're on the same page, could we pull up Tab 4
`and mark it as Exhibit 2?
` (Exhibit 2 marked for
` identification.)
`BY MR. MATICH:
` Q. Dr. Campbell, this Exhibit 2, which
`is Patent Number 5,384,476 is the Nishizawa
`reference?
` A. Yes.
` MR. MATICH: Okay. We can go back
`to the -- your report, please. Page 56, please.
`BY MR. MATICH:
` Q. And Dr. Campbell, this -- is it
`correct that Figure 16 of Nishizawa is on page,
`is reproduced on Page 56 of your report?
` A. I know that we used that figure. I
`don't recall the page number.
` But, yes, we used this figure.
` Q. Okay. But --
` A. So, I'm sorry. I'm sorry, this is
`my declaration. Yes, I'm sorry. Yes, we used
`the Nishizawa figure.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 27 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 28
` Q. So, I'm going to ask the question
`again just to make sure we have a clear
`understanding.
` On page, Figure 16 from Nishizawa,
`is reproduced on Page 56 of your report?
` A. Again, it's not showing the page
`number, but you told the tech to put up 56.
` So, I will assume that is 56.
` Yes, copied from Nishizawa.
` Q. All right. The -- I'll direct you
`to the bottom right-hand corner of the, your
`report. And it says MPS EX1003-56/152?
` A. Unfortunately, that does not show up
`on my screen.
` Q. Oh, okay. We will -- is there a way
`you can adjust your screen to be able to see the
`rest?
` A. Okay, yes. Somebody put it up for
`me. Yes, I can see that now.
` MR. MATICH: Thank you, Danny.
` Danny is the tech.
`BY MR. MATICH:
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 28 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 29
` Q. If you need to see something else,
`you can ask him to scroll or move things around
`or zoom in on something.
` A. Okay.
` Q. Okay. So, having looked at the page
`numbers, do we agree that Figure 16 of Nishizawa
`is what's on the screen right now, on Page 56 of
`your report?
` A. That's correct.
` Q. And Figure 16 depicts a transistor?
` A. It actually depicts a DRAM, of which
`there is a transistor inside this picture.
` But, this -- the total picture is a
`DRAM.
` Q. Okay. But, the, you see what's
`marked as 12 and 13, the N plus regions, those
`are the source and drain of a transistor?
` A. That is correct.
` Q. Okay. Where is the active region of
`this transistor?
` A. The active region is the region
`depicted in blue, the source and drain and
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 29 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 30
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`channel.
` Now, I have a little bit of a caveat
`here, is that I would normally include the active
`area only to the junction of the source and
`drain.
` And this particular figure shows
`that it goes slightly below the source and drain
`junction.
` Q. Okay.
` A. Otherwise, it's fine.
` Q. And by "slightly below," you mean
`that small blue sliver below the source and
`drain?
` A. Correct.
` Q. Okay. And the P plus 33 structure,
`that's below the active region?
` A. That is correct.
` MR. MATICH: Thank you. We can --
`could we go to Page 56 -- oh, we are already on
`Page 56, okay.
`BY MR. MATICH:
` Q. You see in the text it says,
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 30 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. Greenthread, LLC
`
`Stephen A. Campbell, Ph.D.
`
`Page 31
`"Nishizawa discloses that if the electrons were
`allowed to flow to the circuit rather than down
`to the substrate, the circuit would not function
`correctly"?
` A. Yes.
` Q. What, could you expand on what you
`mean by that sentence?
` A. If you read that in the context that
`Nishizawa wrote it, it refers to the formation of
`excess minority carriers that might diffuse from
`the substrate and then be collected by the source
`and drain.
` Q. So, the electrons are coming,
`Nishizawa is concerned with electrons coming up
`from the substrate?
` A. That is correct.
` Q. Were there any other problems
`Nishizawa was trying to solve?
` A. So, this was causing error. I'm
`trying to remember if they also talked about
`latch up.
` Their primary focus in Nishizawa was
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
`www.DigitalEvidenceGroup.com
`
`Digital Evidence Group C'rt 2024
`
`202-232-0646
`
`Greenthread Ex. 2085, p. 31 of 68
`Semiconductor v. Greenthread
`
`
`
`10/17/2024
`
`Monolithic Power Systems Inc. v. G
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
