CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
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`INTEL CORPORATION,
`Petitioner,
`vs.
`
`Case Nos. IPR2018-01334,
`-01335, -01336
`QUALCOMM INCORPORATED, US Patent No. 8, 838,949
`Patent Owner.
`_______________________________________________________
`
` ***CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER***
`DEPOSITION OF BILL LIN, Ph.D.
`SAN DIEGO, CALIFORNIA
`NOVEMBER 1, 2019
`
`Reported By:
`PATRICIA Y. SCHULER
`CSR No. 11949
`Job No. 169787
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`QUALCOMM EXHIBIT 2008
`Intel v. Qualcomm
`IPR2018-01334
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
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`INTEL CORPORATION,
`Petitioner,
`vs.
`
`Case Nos. IPR2018-01334,
`-01335, -01336
`QUALCOMM INCORPORATED, US Patent No. 8, 838,949
`Patent Owner.
`_______________________________________________________
`
` ***CONFIDENTIAL PURSUANT TO PROTECTIVE ORDER***
`DEPOSITION OF BILL LIN, Ph.D.
`SAN DIEGO, CALIFORNIA
`NOVEMBER 1, 2019
`
`Reported By:
`PATRICIA Y. SCHULER
`CSR No. 11949
`Job No. 169787
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`QUALCOMM EXHIBIT 2008
`Intel v. Qualcomm
`IPR2018-01334
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`INTEL CORPORATION,
` Petitioner,
` vs. Case Nos. IPR2018-01334,
` -01335, -01336
`QUALCOMM INCORPORATED, US Patent No. 8, 838,949
` Patent Owner.
`_______________________________________________________
`
` Deposition of BILL LIN, Ph.D., taken on behalf
`of the Plaintiff, at 4655 Executive Drive, Fifteenth
`Floor, San Diego, California, beginning at 9:02 a.m.
`and ending at 11:43 a.m., on November 1, 2019,
`before PATRICIA Y. SCHULER, Certified Shorthand
`Reporter No. 11949.
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`APPEARANCES OF COUNSEL:
`For the Petitioner:
` WILMERHALE
` BY: JOSEPH HAAG, ESQ.
` 950 Page Mill Road
` Palo Alto, California 94304
`
` - and -
` WILMERHALE
` BY: THOMAS ANDERSON, ESQ.
` 1875 Pennsylvania Avenue, Northwest
` Washington, DC 20006
`
`For Patent Owner:
` JONES DAY
` BY: JOSHUA NIGHTINGALE, ESQ.
` Attorney at Law
` 500 Grant Street
` Pittsburgh, Pennsylvania 15219
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` I-N-D-E-X
`WITNESS: EXAMINATION
`BILL LIN, Ph.D. PAGE
`MR. NIGHTINGALE 5
`
`Page 4
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` E-X-H-I-B-I-T-S
` (NONE OFFERED)
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` SAN DIEGO, CALIFORNIA; FRIDAY, NOVEMBER 1, 2019
`9:02 a.m.
`
`BILL LIN, Ph.D.,
` having been administered an oath, was examined and
`testified as follows:
`
`EXAMINATION
`
`BY MR. NIGHTINGALE:
`Q.
`Good morning, Dr. Lin.
`A.
`Good morning.
`Q.
`Can you please state your name for the
`record?
`My name is Bill, last name is Lin.
`A.
`Is it okay if I call you Dr. Lin today?
`Q.
`Yes.
`A.
`Dr. Lin, you understand that the
`Q.
`testimony you are providing today is under oath; is
`that correct?
`A.
`Yes.
`Q.
`Is there anything that would prevent you
`from giving truthful and accurate testimony today?
`A.
`No.
`Q.
`Today we are discussing the consolidated
`IPR proceeding for U.S. 8838949. Is it all right
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`if we refer to that patent as the '949 patent?
` A. Yes.
` Q. Dr. Lin, are you being compensated for
`your work on this case?
` A. Yes.
` Q. What is your hourly rate?
` A. I don't remember exactly what the rate
`is.
` Q. Do you have a ballpark estimate?
` A. It should be around $600.
` Q. And you're being paid your hourly rate
`for all work performed in connection with this
`matter; is that right?
` A. Yes.
` Q. That would include today's testimony?
` A. Yes. I think the rate is $550. I don't
`remember exactly.
` Q. What did you do to prepare for your
`deposition today?
` A. I read over my declaration. I read over
`some of the references. And I met with counsel.
` Q. Did you review your declarations that
`were in support of Intel's IPR petitions
`challenging the '949 patent?
` A. Yes.
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` Q. And you have reviewed your declaration in
`support of Intel's petition and reply; is that
`right?
` A. Yes.
` Q. Did you review the '949 patent?
` A. Yes.
` Q. And you said you reviewed some of the
`prior art references?
` A. Yes.
` Q. Did you review any other documents?
` A. I don't think so.
` Q. And you said that you met with counsel to
`prepare for your deposition?
` A. Yes.
` Q. Was that meeting in person?
` A. Yes.
` Q. When was that?
` A. Yesterday.
` Q. Where did you meet with counsel at?
` A. At a conference room nearby.
` Q. How long was your meeting?
` A. Just throughout the day yesterday.
` Q. Did you have any discussions with any
`individuals that are not lawyers in preparation for
`your deposition today?
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` A. No.
` Q. I am handing the witness a document that
`has been previously marked as Intel 1023.
` A. I apologize. Can I go get my glasses.
` Q. Sure.
` (Recess taken.).
`BY MR. NIGHTINGALE:
` Q. Prior to the break I handed the witness a
`document that has been previously marked as Intel
`1023.
` Dr. Lin, do you recognize this as a copy
`of your reply declaration?
` A. Yes.
` Q. In IPR 2018-01334?
` A. Yes.
` Q. And, Dr. Lin, I know you know this, but
`if we can, let's try to let me finish my question,
`and I'll let you finish your answer just for the
`benefit of the court reporter. Dr. Lin, please
`turn to Page 50 of this document.
` Is that your signature appearing on
`Page 50?
` A. Yes.
` Q. You signed it on September 27, 2019?
` A. Yes.
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` Q. When did you begin work on this reply
`declaration?
` A. I do not remember.
` Q. Can you give me a ballpark estimate?
` A. Actually, I just don't remember.
` Q. How many hours did you spend working on
`this declaration?
` A. Actually, I don't remember that either.
` Q. Can you give me a ballpark estimate?
` A. Actually, I just don't remember. It has
`been a little bit of time.
` Q. Do you think it was more than 10 hours?
` A. Probably.
` Q. Is it more than 20 hours?
` A. I just don't remember.
` Q. Please turn to Paragraph 5 on Page 2 of
`your reply declaration. This paragraph lists the
`materials that you reviewed and considered in
`preparing the declaration; is that right?
` A. Yes.
` Q. In addition to those materials listed in
`Paragraph 5, did you also review the patent and
`response filed in this proceeding?
` A. I believe so.
` Q. Are there any other materials that you
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`reviewed in preparing your reply declaration that
`are not listed in Paragraph 5?
` A. Yes. I reviewed all of the documents
`that I cite in this declaration. So we can go
`through everything I have cited and I have reviewed
`those.
` Q. I am handing the witness a document that
`has been previously marked as Intel 1001.
` Dr. Lin, do you recognize this document
`as a copy of the '949 patent?
` A. Yes.
` Q. Did you review the '949 patent in
`connection with the preparation of your reply
`declaration?
` A. Yes.
` Q. And did you review the prosecution
`history of the '949 patent in preparing your reply
`declaration?
` A. I definitely reviewed the prosecution
`history during the course of -- I have reviewed the
`prosecution history. I just don't remember exactly
`when I reviewed it.
` Q. Would you consider yourself familiar with
`the technology described in the '949 patent?
` A. Yes.
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` Q. Please turn now to Column 2, Lines 23
`through 34 of the '949 patent and take a minute to
`read that to yourself.
` A. 22 to 34?
` Q. 23 through 34 of Column 2.
` A. Okay.
` Q. This portion of the '949 patent says that
`"In the system in which the software image is
`loaded onto a target secondary processor from a
`first primary processor, one way of performing such
`loading is to allocate a temporary buffer into
`which each packet is received."
` Do you see that?
` A. Yes.
` Q. This portion of the '949 patent also says
`that "The temporary buffer would be someplace in
`system memory such as internal random access memory
`(RAM) or double data rate (DDR) memory, for
`example"; is that right?
` A. That is what is written.
` Q. So, Dr. Lin, reading these portions of
`the '949 patent is it your understanding that a
`processor would be used to allocate the temporary
`buffer in the system memory?
` A. Well, I think this portion of the '949
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`simply states that -- it just simply states that a
`temporary buffer is allocated. It doesn't say who
`does the allocation. It doesn't say it is
`allocated in system memory.
` Q. Would it be possible for a processor to
`allocate the temporary buffer in the system memory?
` A. It doesn't say here one way or the other.
` Q. I am asking you would it be possible for
`a processor to perform that allocation?
` A. Yes. The allocation of a temporary
`buffer could be done by any number of entities.
` Q. Would a processor be one of those
`entities?
` A. Here it doesn't say what does the
`allocation, and to the extent a process can
`allocate, it doesn't say which processor does the
`allocation.
` Q. And I understand it does not explicitly
`say that the processor allocates the temporary
`buffer. But I am asking you based on your personal
`knowledge and understanding of the technology,
`would it be possible for a processor to allocate
`the temporary buffer in the system memory?
` A. It would be possible for a processor to
`allocate the temporary buffer, but it doesn't say
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`what does the allocation.
` Q. Dr. Lin, if we assume that a processor
`allocates the temporary buffer in the system
`memory, is the system memory addressable by that
`processor?
` A. Well, I disagree with your question. So
`here it doesn't say that it's -- the temporary
`buffer is being allocated in the system memory.
` Q. I understand that, but previously didn't
`you agree with me that it would be possible for a
`processor to allocate the temporary buffer in the
`system memory?
` A. No. I simply said that it's possible for
`a processor to allocate a temporary buffer.
` Q. So you disagree that in the context of
`the '949 patent it is not possible for a processor
`to allocate the temporary buffer in the system
`memory?
` A. I think in my declaration I have -- I
`gave my opinion in terms of what I think a system
`memory is.
` Q. So you previously -- you testified
`earlier today that it would be possible for a
`process to allocate the temporary buffer; is that
`right?
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` A. It is possible.
` Q. If a processor allocates the temporary
`buffer in the system memory, is the system memory
`addressable by the processor?
` A. I did not say that the processor
`allocates a temporary buffer in system memory.
` Q. The '949 patent says that the temporary
`buffer would be someplace in system memory, right?
` A. But not in the lines stated here.
` Q. Take a look at Column 2, Lines 31 through
`34. That says, "The temporary buffer would be
`someplace in the system memory such as internal
`random access memory (RAM) or double data rate
`(DDR) memory, for example."
` Did I read that right?
` A. Yes.
` Q. Dr. Lin, if a processor allocates the
`temporary buffer in the system memory, is the
`system memory addressable by the processor?
` A. The system memory is addressable by the
`processor.
` Q. Column 2, Lines 29 through 30 of the '949
`patent state that "From the temporary buffer some
`of the processing may be done over the payload"; is
`that right?
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` A. That is what is stated.
` Q. Is it your understanding that the
`processing of the payload could be done by a
`processor?
` A. I don't believe it says who does the
`processing. It just says some of the processing
`may be done over the payload.
` Q. Would it be possible for a processor to
`be used to process the payload?
` A. Yeah. Again, here it doesn't say who
`does the processing, so it could be any number of
`entities.
` Q. Could a processor be one of those
`entities?
` A. It doesn't say, so it doesn't exclude it
`from that possibility.
` Q. I am asking you, though, based on your
`personal knowledge, would it be possible for a
`processor to process the payload?
` A. I guess it can be, yes.
` Q. If a processor processes the payload in
`the temporary buffer, is the temporary buffer
`addressable by the processor?
` A. The temporary buffer is addressable by
`the processor.
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` Q. Column 2, Lines 29 through 31 of the '949
`patent state that from the temporary buffer some of
`the processing may be done over the payload and
`then the payload would get copied over to the final
`destination.
` Do you see that?
` A. Yes.
` Q. Looking at this portion of the '949
`patent, is it your understanding that a processor
`would be used to copy the payload from the
`temporary buffer to the final destination?
` A. So, again, as I said earlier, I don't
`think in this passage it specifies who does the
`processing and who does the copying.
` Q. Would it be possible to use a processor
`to copy the payload from the temporary buffer to
`the final destination?
` MR. HAAG: Objection; form.
` THE WITNESS: Yes.
`BY MR. NIGHTINGALE:
` Q. If a processor copies the payload from
`the temporary buffer to the final destination, is
`the temporary buffer addressable by the processor?
` A. So, again, it does not say here whether a
`processor is used to do the copying and which
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`processor is being used. But whatever entity that
`does the copying would have to be -- would be able
`to address that temporary buffer.
` Q. Column 2, Lines 31 through 34 of the '949
`patent state that "The temporary buffer would be
`someplace in the system memory such as in internal
`random access memory (RAM) or double data rate
`(DDR) memory, for example."
` Do you see that?
` A. Yes.
` Q. Random access memory is a type of
`physical storage medium; is that right?
` A. Yes.
` Q. Random access memory is hardware; is that
`correct?
` A. Yes.
` Q. If the temporary buffer is someplace in
`the system memory that is a random access memory,
`then the system memory is implemented in hardware;
`is that right?
` I'll go ahead and repeat my question
`because I'm not sure if the transcript accurately
`reflects it.
` If the temporary buffer is someplace in
`system memory that is random access memory then the
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`temporary buffer is implemented in hardware; is
`that correct?
` A. So I want to go back and clarify one
`thing. So the system memory is a Clayton term and
`so whether a temporary buffer is in the system
`memory or not, it depends on whether it is in the
`part of the memory that is considered to be system
`memory.
` Q. So let's take a step back. You agree
`with me that Column two, lines 31 through 34 of the
`'949 patent state that "The temporary buffer would
`be someplace in the system memory such as in
`internal random access memory (RAM)or double data
`rate(DDR) memory, for example," right?
` A. That is what is stated.
` Q. You told me that random access memory is
`hardware?
` A. Yes.
` Q. So my question is, if the temporary
`buffer is someplace in the system memory that is
`random access memory, then the temporary buffer is
`implemented in hardware; is that correct?
` A. Whether the temporary buffer is in the
`system memory or not depends on whether it is in
`the part of the memory that is used to implement
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`the system memory.
` Q. I'm not sure if I got an answer to my
`question.
` The '949 patent states that the temporary
`buffer would be someplace in system memory; is that
`right?
` A. So if it were to be someplace in system
`memory...
` Q. My question was, the '949 patent states
`that the temporary buffer would be someplace in
`system memory; is that correct?
` A. That is what is written there.
` Q. System memory in the '949 patent can be
`internal random access memory.
` Do you agree with me?
` A. That is what it stated there.
` Q. You told me that random access memory is
`hardware?
` A. Yes.
` Q. Let me ask my question again.
` As stated in the '949 patent that the
`temporary buffer is someplace in system memory and
`the system memory is random access memory, my
`question is, is the temporary buffer implemented in
`hardware?
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` MR. HAAG: Objection; form.
` THE WITNESS: So I can agree that if a
`temporary buffer is implemented using random access
`memory, that it is in hardware.
`BY MR. NIGHTINGALE:
` Q. Double data rate memory is a type of
`physical storage medium; is that right?
` A. Yes.
` Q. Double data rate memory is hardware; is
`that right?
` A. Yes.
` Q. In the '949 patent, if the temporary
`buffer is someplace in system memory that is double
`data rate memory, then the temporary buffer is
`implemented in hardware; is that right?
` A. So if the temporary buffer is implemented
`double data rate memory I can agree that it is
`implemented in hardware.
` MR. HAAG: Can we just take a short break
`when you get to a good point.
` THE WITNESS: Can we take a break now?
` MR. NIGHTINGALE: Let's take a break,
`yeah.
` (Recess taken.)
`///
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`BY MR. NIGHTINGALE:
` Q. Dr. Lin, can you take a minute to read
`Column 2, Lines 29 through 34 of the '949 patent?
` A. Yes.
` Q. That portion of the '949 patent states
`that "The temporary buffer would be someplace in
`the system memory, and from the temporary buffer,
`the payload would get copied over to the final
`destination"; is that right?
` A. That is what is stated.
` Q. The '949 patent says that "A portion of
`system memory can function as a temporary buffer in
`copying data to a final destination"; is that
`right?
` A. It says that the temporary buffer could
`be someplace in system memory, yes.
` Q. And the temporary buffer is used in
`copying data to a final destination?
` A. Yes.
` Q. Please turn back to your reply
`declaration. Take a look at Page 2, Paragraph 9.
` A. Yes.
` Q. In Paragraphs 9 through 14 of your reply
`declaration, you discuss the construction of the
`claim term "system memory"; is that right?
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` A. Yes.
` Q. In Paragraph 14 you state: "Therefore,
`if the word construes the term, it should be
`defined to mean memory where an executable software
`image can be loaded and executed."
` Do you see that?
` A. Yes.
` Q. The term you're referring to is "system
`memory," right?
` A. Yes.
` Q. Sitting here today, do you still believe
`that system memory should be construed as memory
`where an executable software image can be loaded
`and executed?
` A. Yes.
` Q. Turn back to the '949 patent, please.
`And look again at Column 2, Lines 23 through 34.
`We've discussed this portion already.
` A. Yes.
` Q. This portion of the '949 patent mentions
`temporary buffer multiple times.
` Do you see that?
` A. Yes.
` Q. Does the temporary buffer described in
`this portion of the '949 patent meet your
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`construction of system memory?
` A. So my construction is, is system memory
`is memory where an executable software image can be
`loaded and executed. And so if the portion of
`memory, if a portion of the memory is -- can be
`used for loading and executing -- executable
`software images, then that portion of the memory is
`considered part of the system memory. And a
`temporary buffer could be allocated in that part of
`the system memory.
` Q. Column 2, Lines 23 through 34 of the '949
`patent mentions temporary buffer, correct?
` A. Yes.
` Q. Is the temporary buffer memory where an
`executable software imagine can be loaded and
`executed?
` A. So I think the proper construction of the
`term "system memory" is memory where executable
`software image can be loaded and executed. If you
`have a portion of memory is that is reserved
`specifically for some purpose but you cannot use it
`for loading or executing executable software, then
`that portion of the memory is not system memory.
` So the proper construction of the term
`"system memory" should be memory where executable
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`software can be loaded and executed. So whether a
`portion of memory is considered system memory or
`not depends on whether it can be used to load
`executable software images.
` Q. Can a temporary buffer described in this
`portion of the '949 patent be used to load and
`execute executable software images?
` A. Can you repeat the question?
` Q. Can the temporary buffer described in the
`this portion of the '949 patent be used to load and
`execute executable software images?
` A. So system memory is a portion of memory
`where executable software images can be loaded and
`executed. Portion of the memory that is reserved
`for entirely -- reserved for purposes where it
`cannot be used to load and execute executable
`software images, that portion memory is not system
`memory.
` So if there is a portion of memory that
`allows for executable software images to be loaded
`and executed and that's where the temporary buffer
`is temporarily allocated, then it is allocated as
`part of system memory. But if it is allocated in
`other parts of memory where you cannot load and
`execute executable software images, then it is not
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`being allocated in system memory.
` Q. Can you turn to Figure 3 of the '949
`patent. Are you familiar with the operational flow
`diagram shown in Figure 3?
` A. Yes.
` Q. Figure 3 shows a secondary processor 302;
`is that right?
` A. Yes.
` Q. The secondary processor 302 includes a
`CPU; is that right?
` A. Yes, as shown in Figure 3.
` Q. In Figure 3 the secondary processor 302
`also includes system memory 305; is that right?
` A. Yes.
` Q. If an executable software image is loaded
`into the system memory 305 and executed from the
`system memory 305, then would be consider the
`system memory 305 to meet your construction of
`system memory?
` MR. HAAG: Objection to form.
` THE WITNESS: Can you repeat the
`question?
`BY MR. NIGHTINGALE:
` Q. If an executable software image is loaded
`into the system memory 305 and executed from the
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`system memory 305, would you consider the system
`memory 305 to meet your construction of system
`memory?
` A. Yes.
` Q. In that scenario where an executable
`software image is loaded into the system memory 305
`and executed from the system memory 305, is it your
`understanding that the software image would be
`executed by the CPU of the secondary processor 302?
` MR. HAAG: Objection to form.
` THE WITNESS: Can you repeat the question
`one more time?
`BY MR. NIGHTINGALE:
` Q. In my scenario where an executable
`software image is loaded into the system memory 305
`and executed from the system memory 305, is it your
`understanding that the software image would be
`executed by the CPU of the secondary processor 302?
` A. Yes.
` Q. Is the system memory 305 addressable by
`the CPU of the secondary processor?
` A. Yes.
` Q. If you have the architecture shown in
`Figure 3 of the '949 patent but an executable
`software imagine is never loaded into the system
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`memory 305, does the system memory 305 meet your
`construction of the term system memory?
` A. If nothing ever gets loaded and executed
`in 305, then it doesn't meet my definition of
`system memory.
` Q. Just to make sure I understand your
`answer, if an executable software image is never
`loaded into the system memory 305, does the system
`memory 305 meet your construction of the terms
`system memory?
` MR. HAAG: Objection to form.
` THE WITNESS: Well, so my definition my
`construction of the system memory is the memory --
`is a memory where software images are loaded and
`executed. So if a memory is never used for that
`purpose, then it is not system memory.
`BY MR. NIGHTINGALE:
` Q. If you have the architecture of Figure 3
`of the '949 patent and nonexecutable data is loaded
`into the system memory 305, does the system memory
`305 meet your construction of the term "system
`memory"?
` A. If a portion of memory -- if a memory or
`portion of the memory is never used to load and
`execute executable software images, then it is not
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`a system memory according to my construction.
` Q. Take a look at your reply declaration
`again. Please turn to Page 2 -- excuse me, Page 5
`of Paragraph 14.
` A. Okay.
` Q. In that paragraph you state: "Therefore,
`if the word construes the term, it should be
`defined to mean memory where an executable software
`image can be loaded and executed."
` Do you see that?
` A. Yes.
` Q. And the term you are referring to there
`is "system memory," right?
` A. Yes.
` Q. Does your construction of system memory
`read on memory where an executable software image
`is loaded and executed?
` A. So a memory or portion of memory that is
`used for loading and executing executable software
`image, then, yes, it is part of the system memory.
` Q. Would your construction of system memory
`read on memory where an executable software image
`is physically capable of being loaded and executed?
` A. Can you repeat the question?
` Q. Would your construction of system memory
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`read on memory where an executable software image
`is physically capable of being loaded and executed?
` MR. HAAG: Objection to form.
` THE WITNESS: So for the portion of
`memory that is set aside or designated so that it
`will never be used to load or execute programs,
`then that portion of the memory is not part of the
`system memory. If a portion of memory is intended
`to -- is intended to load and execute executable
`software images and is being used to load and
`software images, then it is part of the system
`memory.
`BY MR. NIGHTINGALE:
` Q. Please turn pack to Figure 3 of the '949
`patent. This figure shows a hardware transport
`mechanism 309; is that right?
` A. Yes.
` Q. Figure 3 also shows the scatter loader
`controller 304; is that right?
` A. Yes.
` Q. In Figure 3 of the '949 patent, the
`scatter loader controller 304 is a box labeled
`"hardware transport mechanism"; is that right?
` MR. HAAG: Objection to form.
` THE WITNESS: So '949 refers to Figure 3
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`as an exemplar, as an example. The claims actually
`don't -- the claims don't necessarily have to be
`implemented the way Figure 3 describes things.
`BY MR. NIGHTINGALE:
` Q. Let me ask my question again. In Figure
`3 of the '949 patent, a scatter loader controller
`304 in a box labeled "hardware transport
`mechanism"; is that right?
` MR. HAAG: Objection.
` THE WITNESS: So in Figure 3, the
`controller is shown inside a box labeled as
`"hardware buffer," and there is text above it that
`says "hardware transport mechanism," that's what is
`shown in Figure 3.
`BY MR. NIGHTINGALE:
` Q. I didn't ask if the controller 304 was in
`a box labeled hardware buffer. Let me repeat my
`question again. In Figure 3 of the '949 patent,
`the scatter loader controller 304 is in the box
`labeled "hardware transport mechanism"; is that
`right?
` A. The controller 304 is inside a box
`labeled "hardware transport mechanism," yes.
` Q. Please turn to now Column 8, Lines 60
`through 62 of the '949 patent.
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` A. Column 8?
` Q. Column 8, Lines 60 through 62 of the '949
`patent.
` A. 60 to 62, okay.
` Q. That portion says, "Secondary processor
`302 includes a hardware transport mechanism 309
`(e.g., a USB controller that includes the scatter
`loader controller 304.)"
` Do you see that?
` A. Yes.
` Q. The '949 patent says that the hardware
`transport mechanism 309 includes the scatter loader
`controller 304; is that right?
` A. That is what is stated here.
` Q. Dr. Lin, do you agree that in the
`embodiment of the Figure 3 of the '949 patent, the
`scatter ladder controller 304 is a component of the
`hardware transport mechanism 309?
` A. So I s
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