UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`INTEL CORPORATION, )
`
`Petitioner, )
`
`)
`
`) Case Nos. IPR2018-01334,
`
`vs. ) -01335, -01336
`
`) US Patent No. 8,838,949
`
`QUALCOMM INCORPORATED, )
`
`Patent Owner. )
`
`)
`
`_________________________________)
`
`DEPOSITION OF BILL LIN, PhD
`
`San Diego, California
`
`Tuesday, May 21, 2019
`
`Reported by:
`
`ELIZABETH BORRELLI, CSR No. 7844, CCRR, CLR
`
`JOB NO. 160508
`
`TSG Reporting - Worldwide 877-702-9580
`
`QUALCOMM EXHIBIT 2001
`Intel v. Qualcomm
`IPR2018-01334
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 1
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`INTEL CORPORATION, )
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`Petitioner, )
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`)
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`) Case Nos. IPR2018-01334,
`
`vs. ) -01335, -01336
`
`) US Patent No. 8,838,949
`
`QUALCOMM INCORPORATED, )
`
`Patent Owner. )
`
`)
`
`_________________________________)
`
`DEPOSITION OF BILL LIN, PhD
`
`San Diego, California
`
`Tuesday, May 21, 2019
`
`Reported by:
`
`ELIZABETH BORRELLI, CSR No. 7844, CCRR, CLR
`
`JOB NO. 160508
`
`TSG Reporting - Worldwide 877-702-9580
`
`QUALCOMM EXHIBIT 2001
`Intel v. Qualcomm
`IPR2018-01334
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`Deposition of BILL LIN, PhD, Volume I,
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`taken on behalf of the Patent Owner, at 4655
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`Executive Drive, Suite 1500, San Diego,
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`California 92121-3134, commencing at 9:31 a.m.,
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`Tuesday, May 21, 2019, before Elizabeth
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`Borrelli, a Certified Shorthand Reporter in the
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`State of California, License No. 7844.
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`APPEARANCES OF COUNSEL:
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`For the Petitioner:
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`Page 3
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`WILMERHALE
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`BY: JOSEPH HAAG
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`Attorney at Law
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`950 Page Mill Road
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`Palo Alto, California 94304
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`-AND-
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`WILMERHALE
`
`BY: THOMAS ANDERSON
`
`Attorney at Law
`
`1875 Pennsylvania Avenue, NW
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`Washington, DC 20006
`
`For Patent Owner:
`
`JONES DAY
`
`BY: JOSEPH SAUER
`
`Attorney at Law
`
`901 Lakeside Avenue
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`Cleveland, Ohio 44114
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`
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`I N D E X
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`WITNESS
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`BILL LIN, PhD
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`By MR. SAUER
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`By MR. HAAG
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`Page 4
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`EXAMINATION
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`5
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`81
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`R E F E R E N C E D E X H I B I T S
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`EXHIBIT
`
`DESCRIPTION
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`PAGE
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`Exhibit 1002 Declaration of Bill Lin, Ph.D.
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`on Behalf of Petitioner, Trial
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`No. IPR2018-01334, 198 pages
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`Exhibit 1102 Declaration of Bill Lin, Ph.D.
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`on Behalf of Petitioner, Trial
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`No. IPR2018-01335, 197 pages
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`Exhibit 1202 Declaration of Bill Lin, Ph.D.
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`on Behalf of Petitioner, Trial
`
`No. IPR2018-01336, 187 pages
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`Exhibit 1001 United States Patent No.
`
`8,838,949, 15 pages
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`Exhibit 1009 United States Patent
`
`Application Publication No.
`
`0288019, 8 pages
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`Exhibit 1010 United States Patent No.
`
`7,356,680, 10 pages
`
`INFORMATION REQUESTED
`
`(None)
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`UNANSWERED QUESTIONS
`
`(None)
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` SAN DIEGO, CALIFORNIA; TUESDAY, MAY 21, 2019
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` 9:31 A.M.
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`Page 5
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` BILL LIN, PhD,
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` having been duly administered
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` an oath in accordance with CCP 2094,
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` was examined and testified as follows:
`
` EXAMINATION
`
`BY MR. SAUER:
`
` Q. Good morning.
`
` A. Good morning.
`
` Q. Can you state your name and address for
`
`the record, please?
`
` A. My home address?
`
` Q. Yes.
`
` A. My name is Bill. Last name is Lin, L-I-N.
`
`My address is 1005 Valleyside Lane, Encinitas,
`
`California.
`
` Q. And you understand that you're under oath
`
`this morning?
`
` A. Yes.
`
` Q. Is there any reason that you can't testify
`
`truthfully today?
`
` A. None.
`
` Q. And you've been deposed before?
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` A. I have.
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` Q. So you know the -- you know the drill.
`
`I'm going to try to ask clear questions, but if you
`
`don't understand a question, just please let me know
`
`and I'll -- I'll try to clarify.
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` We need to try not to talk over one
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`another for the sake of the court reporter.
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` And if you need to take a break at any
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`time, just let me know. The only thing I'll ask is
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`if there's a question pending that we provide your
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`answer and then we can -- we can take a break.
`
` Is that all okay?
`
` A. Okay.
`
` Q. This deposition pertains to your
`
`declaration testimony in three IPR matters; is that
`
`your understanding?
`
` A. Yes.
`
` Q. And, for the record, those three matters
`
`are IPR Case No. IPR2018-01334, IPR2018-01335, and
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`IPR2018-01336.
`
` MR. SAUER: Is one enough or do you guys
`
`want two?
`
` MR. HAAG: I think one is fine.
`
` MR. ANDERSON: One is fine.
`
` MR. HAAG: Unless you want to get rid of
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`an extra copy.
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` MR. ANDERSON: Yeah, that's what I was
`
`thinking.
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` MR. SAUER: I'm handing the witness what's
`
`been previously marked as Intel Exhibit 1002.
`
`BY MR. SAUER:
`
` Q. Dr. Lin, do you recognize this document as
`
`a copy of the declaration that you submitted in
`
`IPR2018-01334?
`
` A. Yes.
`
` Q. And your declaration relates to U.S.
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`Patent No. 8,838,949; is that correct?
`
` A. Yes.
`
` Q. Sorry, I probably should have double-sided
`
`these. They're going to be bulky.
`
` Is it okay if we refer to that as the '949
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`patent? Do you know what I'm talking about?
`
` A. Yes.
`
` Q. And in particular, this declaration
`
`relates to Claims 1 through 9, 22 and 23 of the '949
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`patent; is that right?
`
` A. Yes.
`
` Q. Can you turn to the back of the
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`declaration at page 187?
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` A. Yes.
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` Q. Is that your signature on this page?
`
` A. It is.
`
` Q. Did you write this document?
`
` A. Yes.
`
` Q. Are there any mistakes that you're aware
`
`of in this document?
`
` A. Not that I'm aware of.
`
` Q. Any opinions that you would like to
`
`change?
`
` A. None.
`
` Q. Okay. Set that one aside for the moment.
`
` MR. SAUER: There you go. Another.
`
` I'm now handing the witness what's been
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`previously marked as Intel Exhibit No. 1102.
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` THE WITNESS: Thank you.
`
`BY MR. SAUER:
`
` Q. Dr. Lin, do you recognize this document as
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`a copy of the declaration you submitted in
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`IPR2018-01335?
`
` A. Yes.
`
` Q. And this declaration addresses claims 10
`
`through 17 of the '949 patent; is that right? It
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`should be on the cover page.
`
` A. Yes.
`
` Q. And if you'll turn to page 186, is that
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`your signature on this page?
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` A. It is.
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` Q. And you wrote this document as well?
`
` A. Yes.
`
` Q. Are there any opinions you'd like to
`
`change in this document?
`
` A. No.
`
` Q. Any mistakes you would like to correct?
`
` A. None.
`
` Q. Okay. You can set that one aside. One
`
`more.
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` MR. SAUER: I'm now handing the witness --
`
` (Discussion off the record.)
`
` MR. SAUER: I'm handing the witness what's
`
`been previously marked as Intel Exhibit 1202.
`
`BY MR. SAUER:
`
` Q. Dr. Lin, is -- do you recognize this as
`
`the declaration that you submitted in IPR2018-01336?
`
` A. Yes.
`
` Q. And this declaration relates to claims 18
`
`through 21, correct?
`
` A. Correct.
`
` Q. Of the '949 patent?
`
` A. Correct.
`
` Q. And on page 177, this is your signature?
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` A. Yes, it is.
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` Q. And you wrote this document as well?
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`Page 10
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` A. Yes.
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` Q. Any corrections?
`
` A. None.
`
` Q. Any opinions you would like to change?
`
` A. None.
`
` Q. Okay. You can set that aside. I'm sorry,
`
`let's actually turn to page 179.
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` A. 179?
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` Q. Yes, sir.
`
` A. Okay.
`
` Q. Do you recognize the document starting at
`
`page 179 as a copy of your CV?
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` A. Yes.
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` Q. Is this a current copy?
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` A. Miss -- current, yes.
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` Q. At the bottom of page 179, it refers to --
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`under the heading "Publications" --
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` A. Yes.
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` Q. -- it indicates you've published over 170
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`journal articles and conference papers, correct?
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` A. Correct.
`
` Q. Do you have a version of your CV that
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`lists those?
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` A. I don't, not with me, certainly.
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` Q. Do you have one that's not with you --
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` A. I don't have --
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` Q. -- in existence?
`
` A. I don't have one that lists exhaustively.
`
` Q. Okay. Do you have one that lists some?
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` A. Yes, or I -- I could put together one.
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` Q. If there's a -- one already put together,
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`if you could --
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` A. I don't have --
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` Q. -- I would ask --
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` A. -- one put together.
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` Q. Okay. That's fine. I'm not asking you to
`
`create something, just if you had one, another
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`version that listed those, that's all.
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` A. I do not have.
`
` Q. Based on your current recollection, are
`
`any of your published journal articles or conference
`
`papers relevant to the technology that's described
`
`in the '949 patent?
`
` A. I do a lot of work on mobile processors,
`
`and so mobile processors that incorporate CPUs
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`inside --
`
` Q. Uh-huh.
`
` A. -- and DSP processors inside and modem
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`processors inside, I've dealt with the design of
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`such processors that have this kind of software
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`running on these processors.
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` Q. And you've written articles on those?
`
` A. Yes.
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` Q. And you think they might be relevant to
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`the '949 patent, some of those articles?
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` A. Yes.
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` Q. On page 180, the next page, you list five
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`patents where you were an inventor.
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` Is this a current list?
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` A. Yes.
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` Q. Based on your current recollection, are
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`any of these patents relevant to the technology
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`described in the '949 patent?
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` MR. HAAG: Objection. Form.
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` THE WITNESS: At least one of which is
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`relevant. There's a patent on a design environment
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`and a design method for hardware software code
`
`design.
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`BY MR. SAUER:
`
` Q. That's --
`
` [Reporter requests clarification.]
`
` THE WITNESS: Code design.
`
`BY MR. SAUER:
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` Q. That's the fourth patent in the list?
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` A. Correct.
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` Q. Okay. Thank you. You can set that aside
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`for the moment.
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` MR. SAUER: I'm now handing the
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`document -- I'm now handing the witness what's been
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`previously marked as Intel Exhibit 1001, which is a
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`copy of U.S. Patent No. 8,838,949.
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`BY MR. SAUER:
`
` Q. Is that correct?
`
` A. Correct.
`
` My apologies, can I grab my glasses from
`
`my backpack?
`
` Q. Sure.
`
` A. Please continue.
`
` Q. Do you recognize this as a copy of the
`
`'949 patent?
`
` A. Yes.
`
` Q. Did you review the '949 patent in
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`connection with the preparation of your
`
`declarations?
`
` A. I have.
`
` Q. And did you review the prosecution history
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`of the '949 patent?
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` A. I've reviewed it recently.
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` Q. Would you consider yourself familiar with
`
`the technology described in the '949 patent?
`
` A. Yes.
`
` Q. If you can flip to Figure 3, are you
`
`familiar with the operational flow diagram shown in
`
`Figure 3 of the '949 patent?
`
` A. Yes.
`
` Q. If you could turn to column 4, at about --
`
`starting at line 10, would you agree that Figure 3
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`ab shows operational flow for loading an executable
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`image from a primary processor to a secondary
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`processer?
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` A. It's an exemplary loading process.
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` Q. Exemplary loading process --
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` A. Yes.
`
` Q. -- for loading an executable image from a
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`primary processor to a secondary processor?
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` A. Yes, Figure 3 is an illustration of an
`
`operation flow for an exemplary loading process for
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`loading an executable image from a primary processor
`
`to a secondary processer.
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` Q. According to your understanding, what's an
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`executable image?
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` A. An executable image is an image that you
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`can execute.
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` Q. On a processor?
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` A. Yes.
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` Q. Turning back to Figure 3, Figure 3 shows a
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`primary processor and a secondary processor,
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`correct?
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` A. Yes.
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` Q. And both the primary processor and the
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`secondary processor in Figure 3 include what's been
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`labeled as a hardware transport mechanism, correct?
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` A. Yes.
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` Q. Specifically, the hardware transport
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`mechanism in the primary processor is labeled 308
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`and the hardware transport mechanism in the
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`secondary processor is labeled 309; is that right?
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` A. Yes.
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` Q. What's a -- what's a hardware transport
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`mechanism, according to your understanding?
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` A. I think it just means a transport
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`mechanism that's implemented in hard- -- that's --
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` [Reporter requests clarification.]
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` THE WITNESS: It's just a transport
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`mechanism that's supported by hardware.
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`BY MR. SAUER:
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` Q. Supported by hardware how?
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` A. Just depends on the specific example.
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` Q. Is that a term that you've heard of
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`outside of the '949 patent?
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` A. I think transport mechanism is -- I've
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`heard outside of the '949 patent.
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` Q. But not hardware transport mechanism?
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` A. I don't recall specifically.
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` Q. Okay. Underneath the words "hardware
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`transport mechanism" in both the primary and
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`secondary processors, Figure 3 includes boxes that
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`are labeled "hardware buffer"; is that right?
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` A. Yes.
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` Q. Is it your understanding that the boxes
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`labeled "hardware buffer" are part of the hardware
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`transport mechanisms?
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` A. I think, as we discussed earlier, Figure 3
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`is an exemplary. It's an exemplary loading
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`process --
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` Q. Uh-huh.
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` A. -- for loading an executable image, so
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`it's shown here inside the -- it's shown here inside
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`a box.
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` Q. My question is, in -- in Figure 3 --
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` A. Yes.
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` Q. -- the -- the box is labeled "hardware
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`buffer."
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` They're part of the hardware transport
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`mechanism; is that correct? Is that what it's
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`intend to show, in your recollection?
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` If you'd like, if you can refer to
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`column 8, starting at line 24 to line 30, if that
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`refreshes your memory...
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` A. So there's no specific mention of hardware
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`buffer in this passage.
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` Q. Okay. What is a hardware buffer,
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`according to your understanding?
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` A. I think it's -- hardware buffer is
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`anything that can store data that's in hardware.
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` Q. And the primary and secondary processor
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`shown in Figure 3 each also include a box called
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`"system memory," correct?
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` A. Yes.
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` Q. Would you agree that system memory is
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`separate from the hardware buffer in this figure?
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` MR. HAAG: Objection to form.
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` THE WITNESS: In Figure 3, system memory
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`for the primary processor is labeled distinct from
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`the hardware transport mechanism, and the system
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`memory labeled --
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` [Reporter requests clarification.]
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` THE WITNESS: Memory labeled in the
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`mechanism.
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`BY MR. SAUER:
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` Q. The hardware buffer is not part of the
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`system memory in this figure, correct?
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` A. They're labeled -- they're labeled
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`differently.
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` Q. And separately, correct?
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` A. Yeah, they're labeled differently.
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` Q. In Figure 3, the hardware buffer in the
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`secondary processor also includes a box that's
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`labeled "Controller 304."
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` Do you see that?
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` A. Yes.
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` Q. And if you turn to column 8, line 62, it
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`refers to the controller 304 as the scatter loader
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`controller 304.
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` Do you see that?
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` A. Yes.
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` Q. And then in column 9, starting at line 35,
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`it tells us that the scatter loader controller
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`receives the image segments and scatters them to
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`different locations in the system memory, correct?
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` A. Yes.
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`scatter loading?
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` A. Yes.
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` Q. What -- what does scatter loading mean,
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`according to your understanding?
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` A. Scatter loading is loading data into
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`locations in memory that's not -- not necessarily
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`contiguous.
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` Q. Can it be contiguous?
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` A. Scatter loading is scatter loading data in
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`accordance to some -- some specification of where it
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`should be placed.
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` Q. You just defined it using -- scatter
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`loading using scatter loading.
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` So my question is -- let's go back here.
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` You said scattering loading is loading
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`data into locations in memory that's not necessarily
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`contiguous, correct?
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` A. Correct.
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` Q. My question is, could it be contiguous?
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` A. Scatter loading is usually defined as
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`scatter loading data in accordance to some
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`specification of locations, and those locations
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`don't have to be contiguous.
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` Q. So it could be contiguous or not
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`contiguous?
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` A. Yes.
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` Q. Okay. Let's look back at your
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`declaration, Intel 1,002, which is your declaration
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`for IPR2018-01334.
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` A. Yes.
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` Q. If you can turn to page 34.
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` MR. HAAG: I'm sorry.
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`BY MR. SAUER:
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` Q. Okay.
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` A. Yes.
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` Q. Beginning on page 34, your declaration
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`includes a section on claim construction, correct?
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` A. Yes.
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` Q. And at paragraph 75, you state, "I have
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`applied the broadest reasonable interpretation
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`standard for the claim terms of the challenged
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`claims," correct?
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` A. Correct.
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` Q. Do you understand that the broadest
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`reasonable interpretation standard is broader than
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`the Phillips standard that you use in district court
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`proceedings?
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` A. Yes.
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` Q. And then on the next page, 35, in
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`paragraph 77 --
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` A. Yes.
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` Q. -- you state, "As used in the '949
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`patent" -- I'm sorry, this is under the heading "A,
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`Image Header" in paragraph 77. You state, "As used
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`in the '949 patent, a person of ordinary skill would
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`have understood the term 'image header' to mean a
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`header associated with the entire image that
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`specifies where the data segments are to be placed
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`in the system memory under either the BRE or
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`Phillips standard," correct?
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` A. Under either the BRI or Phillips standard,
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`correct.
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` Q. Thank you.
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` Is that your opinion?
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` A. Yes.
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` Q. You also state that the person of skill in
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`the order would have understood 'image header' to
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`have this meaning under either the BRI or Phillips
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`standard, correct?
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` A. I'm sorry, which -- where are you
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`referring to?
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` Q. The same -- the same sentence. You say
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`"under either the BRI or Phillips standard."
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` So you -- you're saying that -- hold on
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`just a second. Yeah, the person of skill in the art
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`would have understood "image header" to have this
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`meaning under either BRI or Phillips, correct?
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` A. Correct.
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` Q. And that's still your an opinion?
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` A. Yes.
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` Q. Is it your opinion that the proposed
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`meaning of "image header" that you have here is the
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`broadest reasonable interpretation in view of the
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`specification and the claims of the '949 patent?
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` A. Yes. This is the -- this is the meaning
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`that I've adopted.
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` Q. And then at the end of paragraph 77, you
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`state, on page 36, "In the related ITC case, the
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`parties, including the patent owner, agree to this
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`construction for this term," correct?
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` A. Correct.
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` Q. And you understand that in the related ITC
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`case, the claim construction was based on the
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`Phillips standard, correct?
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` A. Yes.
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` Q. But it's your opinion that the same
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`construction of "image header" also satisfies the
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`broadest reasonable interpretation standard in the
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`IPR, correct?
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` A. Yes. That's what I've adopted.
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` Q. Okay. Outside of the context of the '949
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`patent, have you ever come across the term "image
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`header"?
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` A. So I'm nor sure if I have or have not, but
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`I have -- I've given examples of other binary image
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`formats where the header meets the requirement for
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`the image header.
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` Q. But you just can't recall if any of those
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`documents used the term "image header"?
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` A. Not -- not right now.
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` Q. Or if you've heard of the term outside of
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`the '949 patent?
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` A. I don't remember.
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` Q. What about the term "header," have you
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`heard of the term "header" outside of the context of
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`'949 patent?
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` A. Yes.
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` Q. What's a heading, according to your
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`understanding?
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` A. I think "header" depends on the -- the
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`usage. Usually, it refers to something that's at
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`the head the -- of something.
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` Q. Would you agree that an image header
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`within the context of the '949 patent is something
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`more specific than a header?
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` A. So the -- the -- the meaning of "image
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`header" that I've adopted and both parties have
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`agreed to is what we just read.
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` Q. And would you agree that that's more
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`specific than your understanding of the term
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`"header"?
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` A. I think so, yes.
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` Q. Flipping back to page 35, in paragraph 77,
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`in your interpretation of image header again, in
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`your definition you refer to the placement of data
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`segments and system memory?
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` A. Yes.
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` Q. Do you have an understanding of the
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`meaning of the term "system memory"?
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` A. Yes.
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` Q. What's the term "system memory" mean to
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`you?
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` A. I think system memory is -- is the place
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`where you load and run programs or where programs
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`can be loaded and executed.
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` Q. Does it have, the term "system memory," a
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`different meaning within the context of the '949
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`patent?
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` A. I think that is the meaning in the context
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`of the '949 patent.
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` Q. Would you consider a memory that stores an
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`operating system for execution by a processor to be
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`a system memory?
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` A. Can you repeat that question?
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` Q. Would you consider a memory that stores an
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`operating system for execution by a processor to be
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`a system memory?
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` MR. HAAG: Objection to form.
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` THE WITNESS: So a system memory would be
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`a portion of the memory where programs could be
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`loaded and executed. So are you asking me the
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`portion of the memory where the operating system is
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`actually running?
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`BY MR. SAUER:
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` Q. Well, let's start with that.
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` Would the portion of the memory where the
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`operation system is actually running, would you
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`consider that to be a system memory?
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` A. Where it's actually --
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` MR. HAAG: Object to the form.
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` You can go ahead and answer.
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` THE WITNESS: So I think of a system
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`memory as the -- a portion of the memory where
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`programs can be loaded and executed.
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` Q. Okay. And those programs would include an
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`operating system, as an example?
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` A. The actual place where the operating
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`system is actually loaded and running, I guess -- I
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`guess I could agree with that.
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` Q. All right. Let's skip, then, to page 50.
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`Sorry, that's a bit cumbersome.
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` Are you there?
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` A. Page 50, yes.
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` Q. On page 50, towards the bottom of page 50,
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`there's a headline titled "Reference to Bauer and
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`Svensson Combined," do you see that?
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` A. Yes.
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` Q. And under this heading, you state, at
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`paragraph 101, "Bauer is so closely interrelated
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`with Svensson that, for ease of reference, the
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`declaration uses Bauer and Svensson combined to
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`illustrate what Bauer alone or Bauer in combination
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`with Svensson teaches a person of ordinary skill is
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`in the art"; is that right?
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` A. Yes.
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` Q. I want to make sure I understand what this
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`means.
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` So at places in your declaration where you
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`state that Bauer and Svensson combined discloses
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`some particular claim limitation, this means that
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`the limitation is either disclosed by Bauer alone or
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`it's disclosed by the combination of Bauer and
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`Svensson; is that what you mean there?
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` MR. HAAG: Objection.
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` THE WITNESS: I think it's -- I think
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`everywhere, I -- I was careful in -- in the wording,
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`so I think we can go to whichever passage that you
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`want to talk about specifically and I can --
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`BY MR. SAUER:
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` Q. I'm -- I'm going to go to the -- some
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`specific passages and see.
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` I'm just trying to understand what this
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`means. It appears from this paragraph that you're
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`treat being Bauer and Svensson combined as a -- as a
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`single reference; is that correct?
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` A. Well, I think it says what it says, which
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`is they're very closely related, and, for ease of
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`reference, I have used Bauer and Svensson combined
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`to illustrate what Bauer alone or Bauer or in
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`combination with Svensson -- with Svensson teaches.
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` Q. So -- so how -- how are we to know when
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`you say "Bauer and Svensson combined," if you're
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`referring to either Bauer alone or the combination
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` A. I think we have to look to the specific
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`paragraphs and I can -- I can explain what I meant
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`in each case.
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` Q. Okay. Okay. We're going to do that.
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`Let's turn, then, to page 54.
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` Okay. Are you there?
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` A. Yes.
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` Q. On page 54, under the heading little i --
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` A. Uh-huh.
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` Q. -- you address an element of claim 1
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`requiring a secondary processor comprising a system
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`memory and hardware buffer, correct?
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` A. Yes.
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` Q. And then, at the beginning of
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`paragraph 110, you conclude that Bauer and Svensson
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`combined discloses a secondary processor
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`compromising a system memory and hardware buffer,
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`correct?
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` A. Yes.
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` Q. Excuse me. And at the end of
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`paragraph 110 you state, "The secondary processor
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`comprises a DSP CPU 204 coupled to system memory
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`(DSP XRAM 210), and a separate hardware buffer
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`(intermediate storage area (INT. Store Area) within
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`the DSP SARAM and DARAM memory 208)," correct?
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` A. Correct.
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` Q. And then after that statement, you cite to
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`both Exhibit 2000 -- or, excuse me, Exhibit 1009,
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`which is Bauer, and also to Exhibit 1010, which is
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`Svensson, correct?
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` A. Correct.
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` Q. So does "Bauer and Svensson combined" in
`
`this paragraph mean that Bauer alone or the
`
`combination of Bauer of Svensson teaches this?
`
` A. I think you'll see that Figure 2 of Bauer
`
`and Figure 1 of Svensson are identical.
`
` Q. Uh-huh.
`
` A. And I think -- so, from that perspective,
`
`Bauer alone already discloses this Figure 2 and the
`
`elements of this Figure 2.
`
` Q. So I'm not sure if that answered my
`
`question.
`
` So are you relying, then, on Bauer alone
`
`for this system element?
`
` A. I think I provide a support from both
`
`references to this paragraph.
`
` Q. But you don't specify what disclosure is
`
`missing from Bauer, correct?
`
` A. Can I please have the Bauer and Svensson
`
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`reference?
`
` Q. Sure. Here you go.
`
` MR. SAUER: I'm first handing the witness
`
`what's been previously marked as Intel Exhibit 1009.
`
`BY MR. SAUER:
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` Q. Sir, do you recognize that as a copy of
`
`the Bauer reference?
`
` A. Yes.
`
` Q. Okay. There you go.
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` MR. SAUER: I'm now handing the witness
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`what's been previously marked as Intel Exhibit 1010.
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`BY MR. SAUER:
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` Q. Do you recognize that as Svensson?
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` A. Yes, I do.
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` Q. And just for the record, the question was,
`
`in paragraphs -- in paragraph 110 of your
`
`declaration, you don't specify what disclosure is
`
`missing from Bauer, correct?
`
` MR. HAAG: Objection to form.
`
` THE WITNESS: So I believe the support
`
`I've cited from both Bauer and Svensson, the
`
`paragraphs are essentially identical.
`
`BY MR. SAUER:
`
` Q. So, then, is "Bauer and Svensson combined"
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`here referring to what Bauer alone or a combination
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`of Bauer and Svensson? You can't really tell, can
`
`you?
`
` A. No -- I'm sorry, I don't mean "no" to your
`
`answer. I think the -- in places where I provide
`
`support that are identical, then Bauer alone is
`
`sufficient, but I clearly cite the support from
`
`these references.
`
` Q. Okay. But you've said here the disclosure
`
`is the same. That's just what you testified.
`
` Here's what you said: "So I believe the
`
`support I've cited from both Bauer and Svensson, the
`
`paragraphs are essentially identical," correct?
`
` A. I think the support I've cited for the
`
`figures, the figures are identical and the
`
`description are identical, but I think more broadly,
`
`when explaining about the architecture elements,
`
`I -- I generally rely on both references.
`
` Q. But there's no way to tell from this
`
`whether you're referring to Bauer and Svensson
`
`combined or Bauer alone?
`
` MR. HAAG: Objection to form.
`
` THE WITNESS: I think you can tell by --
`
`by support that I've provided. And so generally,
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`I've relied on both references --
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`BY MR. SAUER:
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` Q. Uh-huh.
`
` A. -- and to extent that sup
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