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`Juanita R. Brooks, SBN 75934, brooks@fr.com
`Seth M. Sproul, SBN 217711, sproul@fr.com
`Frank Albert, SBN 247741, albert@fr.com
`Joanna M. Fuller, SBN 266406, jfuller@fr.com
`Robert M. Yeh, SBN 286018, ryeh@fr.com
`Fish & Richardson P.C.
`12390 El Camino Real
`San Diego, CA 92130
`Phone: 858-678-5070 / Fax: 858-678-5099
`
`Ruffin B. Cordell, DC Bar No. 445801, appearing pro hac vice, cordell@fr.com
`Lauren A. Degnan, DC Bar No. 452421, appearing pro hac vice, degnan@fr.com
`Fish & Richardson P.C.
`1000 Maine Avenue, S.W. Suite 1000
`Washington, D.C. 20024
`Phone: 202-783-5070 / Fax: 202-783-2331
`
`Mark D. Selwyn (SBN 244180), mark.selwyn@wilmerhale.com
`WILMER CUTLER PICKERING HALE AND DORR LLP
`950 Page Mill Road
`Palo Alto, CA 94304
`Phone: 650-858-6000 / Fax: 650-858-6100
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`Attorneys for Defendant/Counterclaim-Plaintiff Apple Inc.
`[Additional counsel listed in signature block on last page.]
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`QUALCOMM INCORPORATED,
`Case No. 3:17-CV-1375-DMS-MDD
`Plaintiff,
`DECLARATION OF VINCENT
`MOONEY IN SUPPORT OF THE
`OPENING CLAIM CONSTRUCTION
`BRIEF OF APPLE INC.
`Judge:
`Hon. Dana M. Sabraw
`Mag. Jdg. Hon. Mitchell D. Dembin
`
`APPLE INCORPORATED,
`Defendant.
`
`AND RELATED COUNTERCLAIMS.
`
`
`
`v.
`
`DECLARATION OF VINCENT MOONEY IN
`SUPPORT OF THE OPENING CLAIM
`CONSTRUCTION BRIEF OF APPLE INC.
`
`Case No. 3:17-CV-1375-DMS-MDD
`
`Qualcomm, Ex. 1011, Page 1
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`

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`VII. CLAIM CONSTRUCTION
`A.
`“performance domain” (’812 Patent, cl. 8; ’216 Patent, cl. 1; ’196
`Patent, cls. 1, 2, 3)
`I have been asked to provide my understanding, as one of ordinary skill
`25.
`in the art, of the disputed term “performance domain” as used in the Apple Asserted
`Patents.2 My understanding of Apple’s and Qualcomm’s proposed constructions of
`this term is set forth in the following table:
`Apple’s Proposed Construction
`performance domain: “one or more
`components that may be controlled as a
`unit or independently for performance
`configuration purposes”
`
`Qualcomm’s Proposed Construction
`performance domain: “one or more
`components that may be controlled by
`the power management unit as a unit
`for performance configuration
`purposes”
`It appears that there is no dispute that a “performance domain” includes
`26.
`one or more components, as indeed the Apple Asserted Patents teach. See, e.g., Ex.
`B at 2:31–34 (“[E]ach performance domain may include at least one component but
`may include multiple components, in various embodiments.”) (emphasis added).
`Nor do the parties dispute that the components are controlled “for performance
`configuration purposes.” See id. 4:14–16 (“A performance domain may be one or
`more components that may be controlled by the PMU 28 as a unit for performance
`configuration purposes.”). Rather, I understand the dispute centers on whether a
`“performance domain” is controlled either as a unit or independently, as Apple
`asserts, or as a unit only, as Qualcomm argues.
`To one of ordinary skill in the art reading the specifications at the
`27.
`relevant time, Apple’s proposed definition correctly captures the full meaning of the
`term performance domain. For instance, the specification tells me the following:
`
`2 For the disputed terms “performance domain,” “power management unit,” and “establish a . . .
`performance state,” I have included citations to the ’812 Patent, which shares a specification with
`the ’216 and ’196 Patents.
`
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`The components that form a performance domain may
`transition together from one performance state to another
`performance state. On the other hand, components in
`different performance domains may be independent of
`each other, at least from the standpoint of hardware, and
`may have independently-determined performance states.
`
`’812 Patent 4:20–25 (emphasis added). One of ordinary skill would understand from
`this description that components in a “performance domain” may be controlled
`either as a unit (i.e., together) or independently of each other.
`28. Other discussions in the Apple Asserted Patents also support Apple’s
`definition. For example, the Apple Asserted Patents illustrate that components can
`be controlled independently from other components in the same performance
`domain via separate voltage supplies:
`
`In some embodiments, the performance state may include
`multiple instances of a performance characteristic. For
`example, if the processor is powered off in the sleep state
`and other components are in the same performance
`domain, the voltage for the processor may be set
`separately from the voltage for the other components that
`remain active. Similarly, any other performance
`characteristics that apply to more than one component in a
`performance domain and that may be independent
`controlled for such components may be represented by
`multiple instances in the performance state.
`
`Id. at 5:19–28.3 The Apple Asserted Patents illustrate this idea with an example
`involving a processor in the sleep state and an L2 cache in retention mode both in
`the same performance domain. See id. 5:36–43. Because the Apple Asserted Patents
`demonstrate specific instances in which components within a “performance domain”
`
`3 Although not a disputed term, the Apple Asserted Patents define “component” to include, among
`other things, processors. ’812 Patent 6:23–24.
`
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`are controlled either as a unit or independently, Qualcomm’s definition that excludes
`independently controlled components is unreasonably narrow.
`29.
`The parties also dispute whether a “performance domain” must be
`controlled by the power management unit.4 In my opinion, as one of ordinary skill
`in the art,, Qualcomm’s proposal unnecessarily limits the definition a person having
`ordinary skill in the art would give “performance domain.” While power
`management unit control of the components is possible, it is not necessary according
`to my understanding, as one of ordinary skill in the art, of the patent specification.
`See, e.g., id. at Abstract (“The PMU may control the transition of the performance
`domains.”). The Apple Asserted Patents very explicitly tell me that “…performance
`domain[] transition may be hardware controlled by the PMU 28, or may be software
`controlled using the valid indications in the performance configuration registers.” Id.
`at 8:57–60. Qualcomm’s definition that requires exclusive power management unit
`control of performance domains is therefore inconsistent with my understanding, as
`one of ordinary skill in the art, of the plain language of the Apple Asserted Patents.
`Thus, in my opinion, as one of ordinary skill in the art, a “performance
`30.
`domain” is “one or more components that may be controlled as a unit or
`independently for performance configuration purposes.”
`B.
`“power management unit” (’812 Patent, cl. 8; ’216, cls. 1, 2; ’196,
`cl. 1)
`I have been asked to provide my understanding, as one of ordinary skill
`31.
`in the art, of the disputed term “power management unit” as used in the Apple
`Asserted Patents. My understanding of Apple’s and Qualcomm’s proposed
`constructions of this term is set forth in the following table:
`
`4 I understand that Qualcomm proposes a definition for the term power management unit. I offer
`my opinion as to the appropriate definition of that term below.
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`Qualcomm’s Proposed Construction
`power management unit: “a circuit
`that manages power consumption by
`automatically transitioning in hardware
`the performance states of a plurality
`
`Apple’s Proposed Construction
`power management unit: plain and
`ordinary meaning. To the extent the
`Court finds that further construction is
`necessary, “hardware and/or software
`that causes a performance domain to
`transition to a performance state”
`32. Based on my reading of the Asserted Apple Patents as one of skill in
`the art, a “[power management unit] may be configured to establish a corresponding
`performance state for each performance domain, and may be configured to control
`transitions between performance states in each performance domain.” Id. at 4:16-20.
`The power management unit achieves these transitions using either hardware or
`software. For example the patent discloses hardware that is programmable—
`implying a combination of hardware and software: “a power management unit
`(PMU) may automatically transition (in hardware) the performance states of one or
`more performance domains in a system.” Id. at Abstract (emphasis added); see also
`id. at 2:34–39 (“The power management unit may be programmable with
`performance state identifiers for each performance domain, and for each hardware-
`managed transition (e.g. into the sleep state, out of the sleep state, or both into and
`out of the sleep state, in various embodiments).”) (emphasis added); APL-
`QC1375_00205332 (responding to Office Action rejecting claims as being non-
`statutory for being implemented only in software and listing “power management
`unit” as “express recitation of hardware”).
`33.
`The patent also discloses software-managed state transitions by
`software running on hardware: “[t]he target performance states to which the
`performance domains are to transition may be programmable in the PMU by
`software, and software may signal the PMU that a processor in the system is to enter
`the sleep state.” Id. (emphasis added); see also id. at 8:37–41 (“Alternatively,
`software may use processor instruction execution mechanisms to cause the
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`processor to enter the sleep state, and the PMU 28 may be configured to perform
`other performance domain state transitions.”) (emphasis added); id. at 11:31–35
`(“[T]he PMU driver 70 may prepare the corresponding hardware components for
`the performance state change (e.g. communicating the new performance
`characteristics-block 88), and may invoke the transition (block 90).”) (emphasis
`added). The reference to PMU driver tells one of skill in the art that the power
`management unit of the claims is a combination of hardware and software.
`34. As a result, it is my opinion that one of ordinary skill in the art at the
`relevant time would not have understood “power management unit” to mean “a
`circuit that manages power consumption by automatically transitioning in hardware
`the performance states of a plurality performance domains” for several reasons.
`First, while the “[power management unit] may include circuitry,” id. 5:44, defining
`“power management unit” as “a circuit” contradicts the disclosures in the patent that
`I call out above as such a definition excludes the combined hardware / software
`characteristics of a power management unit described in the specification.
`Second, power management unit initiated transitions occur in the
`35.
`system on a chip when the criteria described in the claims are satisfied. One of skill
`in the art understands these criteria. Qualcomm’s additional criteria – “automatic-
`ally transitioning” – creates ambiguity for a person of ordinary skill in the art that
`does not exist in the plain reading of the claims and the patent. For instance, in
`some embodiments contemplated by the Apple Asserted Patents, “the [power
`management unit] 28 may be configured to automatically transition one or more of
`the performance domains 14A-14F.” Id. at 4:2–4. However, in other embodiments,
`“the closely linked performance domains may transition to different performance
`states in response to the corresponding processor entering the sleep state.” Id. at
`8:52–55 (emphasis added).
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`Finally, Qualcomm’s suggested definition would require a transition in
`36.
`“a plurality of performance domains.” However, as one of ordinary skill in the art,
`that is not my understanding of the patent’s disclosure. Rather, the patent tells me
`that the power management unit may alter the “the performance states of one or
`more performance domains in a system.” Id. at Abstract (emphasis added); see also
`id. 11:1–2 (“[C]hanges in the performance state of one or more performance
`domains may be desirable.”).
`Thus, in my opinion as one of ordinary skill in the art, Apple’s
`37.
`definition of “power management unit,” which is “hardware and/or software that
`causes a performance domain to transition to a performance state” best captures the
`plain and ordinary meaning of the term as discussed in the specification.
`“establish a . . . performance state” (’812 Patent, cl. 8; ’216 Patent,
`C.
`cl. 1; ’196 Patent, cl. 1)
`I have been asked to provide my understanding, as one of ordinary skill
`38.
`in the art, of the disputed term “establish a . . . performance state” as used in the
`Apple Asserted Patents. My understanding of Apple’s and Qualcomm’s proposed
`constructions of this term is set forth in the following table:
`Apple’s Proposed Construction
`Qualcomm’s Proposed Construction
`establish a . . . performance state: “to
`establish a . . . performance state:
`plain and ordinary meaning. To the
`cause the performance domain to apply
`extent the Court finds that further
`the performance state to that domain”
`construction is necessary, “set the . . .
`one or more performance
`characteristics to the appropriate values
`for the performance state”
`39.
`In my opinion, as one of ordinary skill in the art, Apple’s alternative
`construction most closely aligns with the understanding of the term by one of skill in
`the art reading the patent. First, the patents tell me that “[t]he performance state
`may include any combination of performance characteristics for the components in
`a corresponding performance domain.” Id. at 4:31–33 (emphasis added).
`
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`40. One of skill in the art would have understood that transitioning a
`performance domain to a particular performance state requires the components to be
`set to the appropriate values for that performance state. See, e.g., id. 5:34–36 (“The
`performance characteristics of the component may be changed to reflect reduced
`operation while the processor is in the sleep state.”). The patent lists examples of
`these “performance characteristic[s]” including “any configurable setting for a
`component that affects the performance of that component,” such as “operating
`frequency of the clock signal,” “supply voltage,” and/or “data width.” Id. at 4:21–
`62; see also id. 4:59–62 (“Any parameter that may be changed and that may affect
`performance may be a performance characteristic in various embodiments”). These
`performance characteristics must be set to the appropriate value to achieve the
`corresponding performance state. In one embodiment, for example,
`
`the performance state may include multiple instances of a
`performance characteristic. For example, if the processor
`is powered off in the sleep state and other components are
`in the same performance domain, the voltage for the
`processor may be set separately from the voltage for the
`other components that remain active. Similarly, any other
`performance characteristics that apply to more than one
`component in a performance domain and that may be
`independent controlled for such components may be
`represented by multiple instances in the performance
`state.
`
`Id. at 5:19–28 (emphasis added).
`41. One of ordinary skill in the art at the relevant time would not have
`understood “establish a . . . performance state” to mean “to cause the performance
`domain to apply the performance state to that domain.” First, one of skill in the art
`would not think that a “performance domain” establishes performance states. Based
`on my review of the joint claim construction statement, under either parties’
`
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`construction, a “performance domain” merely refers to a set of one or more
`components. In my opinion, interpretation of “performance domain” as a set
`comports with the understanding of one of ordinary skill in the art. As a result, such
`a person would not understand that performance domains “apply” their performance
`states as Qualcomm’s definition requires.
`Thus, it is my opinion, as one of ordinary skill in the art, that the term
`42.
`“establish a . . . performance state” is best defined as “set the . . . one or more
`performance characteristics to the appropriate values for the performance state.”
`D.
`“a prior performance state at which the processor was operating
`prior to entering the sleep state” (’812 Patent, cl. 8)
`I have been asked to provide my understanding, as one of ordinary skill
`43.
`in the art, of the disputed term “a prior performance state at which the processor was
`operating prior to entering the sleep state” as used in the Apple Asserted Patents.
`My understanding of Apple’s and Qualcomm’s proposed constructions of this term
`is set forth in the following table:
`Apple’s Proposed Construction
`a prior performance state at
`which the processor was
`operating prior to entering the
`sleep state: “the performance state
`at which the processor was last
`operating before the transition to
`the sleep state began”
`44.
`It is my opinion, as one of ordinary skill in the art, that in the context of
`the ’812 Patent specification, “a prior performance state at which the processor was
`operating prior to entering the sleep state” as recited in claim 8 meant to one of skill
`in the art at the relevant time “the performance state at which the processor was last
`operating before the transition to the sleep state began.”
`For context, the entirety of claim 8 is below:
`45.
`
`Qualcomm’s Proposed Construction
`a prior performance state at which
`the processor was operating prior to
`entering the sleep state: Plain and
`ordinary meaning
`
`An apparatus comprising:
`
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`processor was last operating before the transition to the sleep state began” correctly
`captures the meaning of the term to one of skill in the art.
`49.
`I hereby declare that all statements made of my own knowledge are
`true and that all statements made on information and belief are believed to be true. I
`further declare that these statements were made with the knowledge that willful false
`statements and the like so made are punishable by fine or imprisonment, or both,
`under Section 1001 of the Title 18 of the United States Code.
`
`Dated: July 20, 2018
`
`Vincent J. Mooney
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a true and correct copy of the above and
`foregoing document was served on July 20, 2018, via electronic mail pursuant to
`Fed. R. Civ. P. 5(b) to all counsel of record in this action:
`
`Karen P. Hewitt / kphewitt@jonesday.com
`Randall E. Kay / rekay@jonesday.com
`JONES DAY
`4655 Executive Drive, Suite 1500
`San Diego, California 92121
`Telephone: (858) 314-1200
`Facsimile: (858) 345-3178
`Service email: Qualcomm-JonesDay-SDCal1375@jonesday.com
`
`David A. Nelson / davenelson@quinnemanuel.com
`QUINN EMANUEL URQUHART &
`SULLIVAN LLP
`500 West Madison St., Suite 2450
`Chicago, Illinois 60661
`Telephone: (312) 705-7400
`Facsimile: (312) 705-7401
`Service email: qe-qualcomm-sdcal-1375@quinnemanuel.com
`
`Evan R. Chesler / echesler@cravath.com
`CRAVATH, SWAINE & MOORE LLP
`Worldwide Plaza, 825 Eighth Avenue
`New York, NY 10019
`Telephone: (212) 474-1000
`Facsimile: (212) 474-3700
`Service email: service-csm-qc-itc@cravath.com
`
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`Mark D. Selwyn
`Wilmer Cutler Pickering Hale and Dorr LLP
`950 Page Mill Road
`Palo Alto, CA 94304
`Telephone: (650) 858-6000
`Facsimile: (650) 858-6100
`
`William F. Lee
`Joseph J. Mueller
`Timothy Syrett
`Wilmer Cutler Pickering Hale and Dorr LLP
`60 State Street
`Boston, MA 02109
`Telephone: (617) 526-6000
`Facsimile: (617) 526-5000
`
`Nina S. Tallon
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Avenue NW
`Washington, DC 20006
`Telephone: (202) 663-6000
`Facsimile: (202) 663-6363
`
`Service email: WHQualcomm-AppleSDCal1375ServiceList@wilmerhale.com
`
`Executed on July 20, 2018, at San Diego, California.
`
`/s/ Elizabeth Wilton
`Elizabeth Wilton
`
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`Qualcomm, Ex. 1011, Page 12
`
`