`CENTRAL DISTRICT OF CALIFORNIA
`SOUTHERN DIVISION
`_____________________________
`
`)
`
`) )
`
`SPEX TECHNOLOGIES, INC.,
`
`Plaintiff,
`
`vs.
`
`)Case Nos.
`)8:16-CV-01790 (ARGX)
`)8:16-CV-01799 (ARGX)
`)8:16-CV-01800 (ARGX)
`KINGSTON TECHNOLOGY, INC.; )8:16-CV-07349 (ARGX)
`WESTERN DIGITAL CORPORATION; )
`TOSHIBA AMERICA ELECTRONICS )
`COMPONENTS, INC.; APRICORN, )
`INC.,
`
`) )
`
`Defendants. )
`_____________________________)
`
`VIDEOTAPED DEPOSITION OF MIGUEL GOMEZ
`Los Angeles, California
`Wednesday, April 25, 2018
`Volume I
`
`Reported by:
`KATHLEEN E. BARNEY
`CSR No. 5698
`Job No. 2865214
`PAGES 1 - 309
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`WESTERN DIGITAL CORPORATION, EXHIBIT 1023
`WESTERN DIGITAL CORP. v. SPEX, TECHNOLOGIES, INC.
`IPR2018-00082
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` Q Let's go to paragraph 202 of your report.
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`Now we're talking about Element 1F, which is:
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`"A means for mediating
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`communications of data between the
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`host computing device and the target
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`05:20:17
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`means so as the communicated data must
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`first pass through a security means."
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`Correct?
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` A Yes.
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` Q And under paragraph 202, you show a picture
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`05:20:28
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`of Figure 9B.
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` A Yes.
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` Q Okay. And do you have an understanding of
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`what is shown in that figure?
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` A Yes.
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`WESTERN DIGITAL CORPORATION, EXHIBIT 1023
`WESTERN DIGITAL CORP. v. SPEX, TECHNOLOGIES, INC.
`IPR2018-00082
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` Q What is your understanding?
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` A That this is a diagram that identifies
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`various components or functional hardware that is
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`required as the structure.
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` Q And as shown on the left side of Figure 9B, 05:20:55
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`it says "PCMCIA Interface," correct?
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` A Yes.
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` Q And that's something external to what is
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`labeled as Element 910, the interface control
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`device, correct? 05:21:13
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` A That's correct.
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` Q And do you have an understanding of how
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`components that interact with a PCMCIA interface
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`normally operate, what they normally contain?
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` A Yes. 05:21:28
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` Q And the PCMCIA IO controller, the PCMCIA
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`address buffer, the PCMCIA data buffer, the
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`ready/busy register, command detector, and state
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`controller, are those all things that you would
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`expect to find in any PCMCIA compliant circuitry 05:21:47
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`that's going to interact with a PCMCIA interface?
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` MR. WANG: Objection. Vague. Incomplete
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`hypothetical.
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` THE WITNESS: So you pointed specifically to
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`the IO controller, the address buffer, the data 05:22:05
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`WESTERN DIGITAL CORPORATION, EXHIBIT 1023
`WESTERN DIGITAL CORP. v. SPEX, TECHNOLOGIES, INC.
`IPR2018-00082
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`buffer, the ready/busy register and command
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`detector --
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`BY MR. COTE:
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` Q And also the state controller.
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` A And also the state controller. 05:22:13
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` In some forms, those will be in -- did you
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`point to the configuration registers as well?
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` Q You can add that as well, sure.
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` MR. WANG: Objection. Vague. Incomplete
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`hypothetical. 05:22:27
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` THE WITNESS: Elements of each are likely to
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`exist in a -- I haven't done an analysis to
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`determine whether or not any one of these could be
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`eliminated. And the implementation of these varies
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`dramatically. But you certainly would need a data 05:22:49
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`buffer to move data in and out. And the ready/busy
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`register is very important.
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` But I haven't done a complete analysis to
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`know whether you could eliminate one of these and
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`still may call it a PCMCIA controller or interface. 05:23:09
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`BY MR. COTE:
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` Q Okay. But as a person of ordinary skill in
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`the art prior to 1997 -- I'm sorry.
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` As a person of ordinary skill in the art
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`prior to 1997, such a person would understand that 05:23:22
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`these elements that we just discussed would either
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`be there or substantially be there in any kind of
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`PCMCIA interface, correct?
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` MR. WANG: Objection. Vague.
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`Mischaracterizes prior testimony. 05:23:36
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` THE WITNESS: Again, I -- as I said, I would
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`have to think about whether or not you could
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`eliminate one or more of these. But generally,
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`these are the components that are in a PCMCIA
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`interface. 05:23:54
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`BY MR. COTE:
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` Q So down at the bottom of Figure 9B, there is
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`a CompactFlash interface.
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` Do you see that?
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` A Yes. 05:24:05
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` Q Okay. And do you have an understanding of
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`the circuitry that normally would interface with a
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`CompactFlash interface?
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` A Yes.
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` Q And would you expect, back in the 1997 time 05:24:17
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`frame, a CompactFlash interface circuitry to include
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`the CompactFlash IO control, CompactFlash data
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`buffer, card enabled coder and CompactFlash sector
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`counter?
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` MR. WANG: Objection. Vague. Incomplete 05:24:39
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`IPR2018-00082
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`hypothetical.
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` THE WITNESS: Again, I would have to go back
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`and do an analysis that all of those are required.
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` I think the CompactFlash sector controller
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`may be modified in various forms, and whether it 05:25:05
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`would cull that specifically, but generally these
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`are the elements that are part of CompactFlash.
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`BY MR. COTE:
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` Q Do any of the elements here that are shown
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`within figure 9B appear to be non-standard circuitry 05:25:17
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`for interfacing with either a PCMCIA or a
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`CompactFlash interface?
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` MR. WANG: Objection. Vague. Incomplete
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`hypothetical.
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` THE WITNESS: So I think the only thing that 05:25:36
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`I could point at right away is the sharing of the
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`configuration registers. That doesn't appear to be
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`standard. But, you know, it certainly could be
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`implemented that way.
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`BY MR. COTE: 05:25:48
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` Q Okay. You would have to -- would it be fair
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`to say that you would have to configure the
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`interface to the PCMCIA and also configure the
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`interface to the CompactFlash?
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` MR. WANG: Objection. Vague. Incomplete 05:26:09
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`WESTERN DIGITAL CORPORATION, EXHIBIT 1023
`WESTERN DIGITAL CORP. v. SPEX, TECHNOLOGIES, INC.
`IPR2018-00082
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`hypothetical.
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` THE WITNESS: Yes.
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`WESTERN DIGITAL CORPORATION, EXHIBIT 1023
`WESTERN DIGITAL CORP. v. SPEX, TECHNOLOGIES, INC.
`IPR2018-00082
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` I, the undersigned, a Certified Shorthand
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`Reporter of the State of California, do hereby
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`certify:
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` That the foregoing proceedings were taken
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`before me at the time and place herein set forth;
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`that any witnesses in the foregoing proceedings,
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`prior to testifying, were placed under oath; that a
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`record of the proceedings was made by me using
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`machine shorthand which was thereafter transcribed
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`under my direction; further, that the foregoing is
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`an accurate transcription thereof.
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` I further certify that I am neither
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`financially interested in the action nor a relative
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`or employee of any attorney of any of the parties.
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` IN WITNESS WHEREOF, I have this date
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`subscribed my name.
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`Dated: 5/2/2018
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` <%signature%>
`
` KATHLEEN E. BARNEY
`
` CSR No. 5698
`
`Page 309
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`Veritext Legal Solutions
`866 299-5127
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`WESTERN DIGITAL CORPORATION, EXHIBIT 1023
`WESTERN DIGITAL CORP. v. SPEX, TECHNOLOGIES, INC.
`IPR2018-00082
`
`