UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`) )
`
`) )
`
`) )
`
`ANALOG DEVICES, INC.,
`
`Petitioner,
`
` VS.
`
`XILINX, INC. and XILINX ASIA )
`
`PACIFIC PTE. LTD.,
`
`Patent Owner.
`
`)
`
`)
`
`)
`
`)
`
` REMOTELY CONDUCTED DEPOSITION OF PAVAN KUMAR HANUMOLU, Ph.D.
`
`Appearing Remotely Via Zoom From Urbana, Illinois
`
`Thursday, July 15, 2021
`
` Reported stenographically via videoconference by:
`
` LYDIA ZINN
`
` RPR, FCRR, CSR No. 9223
`
` Job No. 4677275
`
` PAGES 1 - 100
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`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. Exhibit 1017 Page 1
`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. v. Analog Devices, Inc. IPR2020-01219
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`) )
`
`) )
`
`) )
`
`ANALOG DEVICES, INC.,
`
`Petitioner,
`
` VS.
`
`XILINX, INC. and XILINX ASIA )
`
`PACIFIC PTE. LTD.,
`
`Patent Owner.
`
`)
`
`)
`
`)
`
`)
`
` REMOTELY CONDUCTED DEPOSITION OF PAVAN KUMAR HANUMOLU, Ph.D.
`
`Appearing Remotely Via Zoom From Urbana, Illinois
`
`Thursday, July 15, 2021
`
` Reported stenographically via videoconference by:
`
` LYDIA ZINN
`
` RPR, FCRR, CSR No. 9223
`
` Job No. 4677275
`
` PAGES 1 - 100
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`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. Exhibit 1017 Page 1
`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. v. Analog Devices, Inc. IPR2020-01219
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ANALOG DEVICES, INC., )
`
` )
`
` Petitioner, )
`
` )
`
` VS. )
`
` )
`
`XILINX, INC. and XILINX ASIA )
`
`PACIFIC PTE. LTD., )
`
` )
`
` Patent Owner. )
`
` )
`
` Remotely conducted deposition of
`
`PAVAN KUMAR HANUMOLU, Ph.D., taken on behalf of Patent
`
`Owner, at Urbana, Illinois, beginning at 10:07 a.m. Central
`
`Daylight Time and ending at 3:23 p.m. on Thursday, July 15,
`
`2021, before LYDIA ZINN, Certified Shorthand Reporter No.
`
`9223.
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`Veritext Legal Solutions
`866 299-5127
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`Page 2
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`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. Exhibit 1017 Page 2
`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. v. Analog Devices, Inc. IPR2020-01219
`
`
`
`APPEARANCES (via videoconference):
`For Petitioner Analog Devices, Inc.:
` WilmerHale LLP
` 2600 El Camino Real
` Suite 400
` Palo Alto, CA 94306
` (650) 858-6000
` jason.kipnis@wilmerhale.com
` BY: JASON D. KIPNIS
`
`For Patent Owner Xilinx, Inc., and Xilinx Asia Pacific Pte.
`Ltd.:
` Morrison & Foerster LLP
` 707 Wilshire Boulevard, 60th Floor
` Los Angeles, CA 90017-3543
` (213) 892-5255
` hgallegos@mofo.com
` jnguyen@mofo.com
` ayap@mofo.com
` roselee@mofo.com
` BY: ALEX S. YAP
` ROSE S. LEE
`Also preset:
`Shuo-Wei Chen
`Mihai Murgulescu
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`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. Exhibit 1017 Page 3
`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. v. Analog Devices, Inc. IPR2020-01219
`
`
`
` I N D E X
`Thursday, July 15, 2021
`WITNESS PAGE
`PAVAN KUMAR HANUMOLU, Ph.D.
`(SWORN) 5
`Examination by Mr. Yap 5
`
`EXHIBITS MARKED FOR IDENTIFICATION PAGE
`EXHIBIT 1015 Low Dropout Regulators,
` Pavan Kumar Hanumolu, University
` of Illinois, Urbana-Champaign
` (40 pages) 27
`
`EXHIBIT 2044 Second Declaration of
` Pavan Kumar Hanumolu, Ph.D.
` (91 pages) 46
`
`EXHIBIT 1004 Declaration of Gerard P. Grenier,
` with Exhibit A, Yoshioka 56
`EXHIBIT 1005 U.S. Patent No. 7,268,595, "System
` and Method for Compensating for the
` Effects of Process, Voltage, and
` Temperature Variations in a
` Circuit," Ajit 71
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`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. Exhibit 1017 Page 4
`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. v. Analog Devices, Inc. IPR2020-01219
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` Urbana, Illinois
`
` Thursday, July 15, 2021, 10:07 a.m.
`
` PAVAN KUMAR HANUMOLU, Ph.D.,
`
`called as a witness by the Patent Owner, having been duly
`
`sworn, testified as follows:
`
` EXAMINATION
`
`BY MR. YAP:
`
`Q. Can you please state and spell your name for the record?
`
`A. First name, Pavan, spelt as P-a-v-a-n. Last name
`
`Hanumolu, H-a-n-u-m-o-l-u.
`
`Q. Can you give us your address for the record?
`
`A. My home address is 3901 Patriot Lane, Champaign, Illinois
`
`61822.
`
`Q. Are you currently at your home right now?
`
`A. I'm in my office.
`
`Q. Where is your office?
`
`A. Office is in the University of Illinois in the building of
`
`CSL.
`
`Q. Are you alone in your office right now?
`
`A. I am alone in my office.
`
`Q. Are you under any medication that might prevent you from
`
`giving full and complete answers today?
`
`A. No. I am not under any medication.
`
`Q. Okay. Is there any reason that would prevent you from
`
`giving full and accurate answers today?
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`A. There is no reason.
`
`Q. Do you have access to the live transcript of today's
`
`deposition on your screen?
`
`A. I do not.
`
`Q. Do you have any other windows or programs opened on your
`
`computer, on your screen right now?
`
`A. I have just my web browser open with -- with the
`
`Exhibit Share. And other than that, I don't have anything
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`open, Counsel.
`
`Q. Do you have any mobile devices with you?
`
`A. No, I don't have. I have put my phone in my bag in the
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`airplane mode.
`
`Q. Do you understand that you're not allowed to communicate
`
`with anyone regarding the substance of this deposition during
`
`the duration of my cross-examination?
`
`A. I understand that.
`
`Q. Do you understand that that applies even during breaks?
`
`A. I understand that.
`
`Q. Do you have any paper copies of your Declarations or any
`
`other papers from this proceeding?
`
`A. I have hard copies of three things: One, the '659 patent.
`
`One -- the second one is my First Declaration. And the third
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`document is my Second Declaration.
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` And I also have all in a folder on my desktop.
`
`Q. I don't think the court reporter fully got what you said
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`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. Exhibit 1017 Page 6
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`in the last sentence. You said you also have something in your
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`desktop?
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`A. No. I have a folder with all the soft copies of the
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`exhibits and such in my desktop. The hard copies were only
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`those three that I mentioned previously.
`
`Q. Do you have any handwritten notes on any of those -- well,
`
`let's start with hard copies.
`
`A. No, I don't have handwritten notes on any of those copies.
`
`Q. Any notes at all?
`
`A. No. No, there are no notes.
`
`Q. What about the soft copies you have on your computer?
`
`A. I don't have any notes on them, either.
`
`Q. Have you ever been deposed before?
`
`A. I have been deposed twice.
`
`Q. And do you have a general understanding of how a
`
`deposition works?
`
`A. I have a general understanding of how a deposition works.
`
`Q. Okay. So I'm just going to go through it really quickly,
`
`just to refresh your last recollection.
`
`A. Mm-hm.
`
`Q. So I am going to be asking you questions. And you're
`
`going to be answering them under oath. Do you understand this?
`
`A. Yes, I do.
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`Q. And you should give your attorney some time to make
`
`objections. Then you should answer my questions. Do you
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`understand that?
`
`A. I understand that.
`
`Q. How did you prepare for today's deposition?
`
`A. By preparing for today's Declaration I have -- deposition,
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`I have reviewed my Declarations, and -- Declarations, and the
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`exhibits that were -- and that I cited -- the references that I
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`cited in the Declarations.
`
` In addition, I have also spoken with Mr. Kipnis and
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`Mr. Peter Dichiara. And I have also spoken briefly with
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`Mr. Mihai Mergulescu of Analog Devices.
`
` So these are the things that I did in preparation for this
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`deposition.
`
`Q. Okay. How long did you spend preparing for today's
`
`deposition -- today's deposition?
`
`A. I have been preparing for today's Declaration [sic]
`
`since -- since beginning Saturday evening or so, Sunday, and
`
`till -- till yesterday.
`
` So that would be the last three, four days.
`
`Q. How many hours in total?
`
`A. I would say maybe a very rough estimate would be -- I
`
`don't know -- between 25-50 hours.
`
`Q. 25 to 50 hours. Is that correct?
`
`A. I said 25 to 50, maybe.
`
`Q. Okay. Is it closer to 25 or is it closer to 50?
`
`A. I'm not able to calculate exact hours, Counsel, but
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`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. Exhibit 1017 Page 8
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`somewhere in that range.
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`Q. So when did you meet with ADI's attorney in preparation
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`for the deposition? You mentioned Sunday. You have been
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`starting.
`
`A. Yes.
`
`Q. Let me ask the question -- re-ask the question again.
`
` So when did you start your first meeting with ADI's
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`attorney in preparation for this deposition?
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`A. I don't know the title of Mr. Mihai Mergulescu. I don't
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`know if he's an attorney, but he's the person that attended the
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`call. So when I'm referring to the ADI person, I'm really
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`referring to Mr. Mihai Mergulescu, but I don't know the title.
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` I believe the first time I spoke with him was on -- was
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`either Monday or Tuesday. I believe -- yes. Monday or
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`Tuesday. I don't have exact recollection, but it should be one
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`of those two days for sure.
`
`Q. No problem.
`
` Was the meeting with Mr. Mergulescu just with him, or are
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`there other people in the meeting, too?
`
`A. I was actually on the call with Mr. Kipnis, and during
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`that conversation, Mr. Mihai Mergalescu joined. So it was
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`always in the presence of Mr. Kipnis.
`
`Q. Okay. So have you ever had any conversation with
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`Mr. Mergulescu outside the presence of anyone else, other
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`than -- go ahead.
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`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. Exhibit 1017 Page 9
`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. v. Analog Devices, Inc. IPR2020-01219
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`A. In -- no. No. I don't -- I don't recall. No. It was
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`always -- the call was between me and Mr. Kipnis, and Mr. Mihai
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`Mergulescu had joined that call. So it was always -- always in
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`the presence of Mr. Kipnis.
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`Q. Well, how many times have you met with counsel and
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`Mr. Mergulescu?
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`A. In preparation for this deposition, I have met Mr. Kipnis
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`three times.
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` And I'm trying to recall during those times if -- if all
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`the three times did Mr. Mergalescu joined on that. But at
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`least on two occasions I believe he joined us, by my best
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`memory.
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` So with Mr. Kipnis, three or four times, three times --
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`three or four times.
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` And with Mr. Mihai, maybe -- my recollection is two times,
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`but somewhere in that range.
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`Q. Anyone else?
`
`A. Ah --
`
`Q. Have you met with anyone else?
`
`A. I have briefly -- in preparation for this deposition, I
`
`have briefly talked to Mr. Peter Dichiara of WilmerHale.
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`And -- and -- and that's it. That's -- that's my memory. Yes,
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`that is it.
`
`Q. What is your understanding of Mr. Mergulescu's role at
`
`ADI?
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`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. Exhibit 1017 Page 10
`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. v. Analog Devices, Inc. IPR2020-01219
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`A. I don't know Mr. Mergalescu. He just attends our call and
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`participates in our conversations. But -- but other than that,
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`I don't -- I don't know him, Counsel, so I don't know what he
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`does at Analog Devices.
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`Q. So how many hours do you estimate you have spent meeting
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`with counsel and anyone from Analog Devices in preparation for
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`today's deposition?
`
`A. I believe I have answered that question previously. In
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`preparation for this deposition, I have met Mr. Kipnis and the
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`other people I had mentioned previously. And I have started my
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`preparation for this deposition late Saturday evening, Saturday
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`evening till yesterday.
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` And as I mentioned, I don't have an exact number of hours
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`I may have spent, but, like I said earlier, the ball park, 25
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`to 50 hours, is the best estimate I could -- I could -- I could
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`get to.
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`Q. So you're saying you have met with counsel and ADI
`
`employees in preparation for your deposition between 25 to
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`50 hours?
`
` MR. KIPNIS: Objection. Form.
`
` THE WITNESS: I'm -- I'm not saying that.
`
` If I misunderstood your question, let me repeat.
`
` In preparation for my own preparation for a deposition, I
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`have -- I have spent that many hours.
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` But I have only met with Mr. Kipnis, and the --
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`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. Exhibit 1017 Page 11
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`Mr. Dichiara, and Mr. Mihai Mergulescu for -- for far less
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`time. If I have to estimate that, then I can take all that, I
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`would say in the range of ten hours.
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`BY MR. YAP:
`
`Q. When did you first learn about the ADI versus Xilinx
`
`matter?
`
`A. It was sometime last year. Exactly when, I don't recall,
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`Counsel. It was sometime -- sometime last year, maybe early
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`last year, but last year being 2020.
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` But I don't recall exactly the instance where I -- where I
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`learned. I don't remember the exact instance where I learned
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`about this case.
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`Q. You mentioned early last year. Is it January last year?
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`A. I don't recall. "Early" being the first part of 2020, but
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`I'm trying to recall, but I don't recall exactly the instance
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`when I learned about this case.
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`Q. Who contacted you?
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`A. To -- to the best of my recollection, with regards to this
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`particular case, I'm relying on my memory here. To the best of
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`my recollection, it must have been Stephanie -- Stephanie --
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`I'm trying to recall her last name. Stephanie Neely, I
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`believe, was the person who -- from WilmerHale that contacted
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`me about this case.
`
`Q. Before this case, have you worked with attorneys from
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`WilmerHale before?
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`Xilinx, Inc. and Xilinx Asia Pacific Pte. Ltd. Exhibit 1017 Page 12
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`A. I have not worked with WilmerHale attorneys in -- in the
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`past definitely eight, nine years, maybe even ten years.
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` But I have some vague recollection of working with someone
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`prior to that, but I have absolutely no memory of exactly who
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`that is, or under what context I had worked with them, but in
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`the past, I would say, eight, nine, ten years, I haven't. I
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`haven't worked with anyone at Wilmer. I haven't worked with
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`attorneys at WilmerHale.
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`Q. So during the time that you worked with attorneys at
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`WilmerHale before this case, is it about a litigation, or is it
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`for s personal matter?
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`A. I mean, I only very vaguely remember the first more than,
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`I would say, ten years, to the best of my memory. But it was
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`not a personal matter. But I don't recall exactly in which
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`context or what they had asked me to do.
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` But it was a very -- I don't remember doing any IPRs or
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`any of this, for sure.
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` It might have been a conversation, and they may have asked
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`me an opinion, but I don't -- I don't have a very good memory,
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`Counsel. This was many, many years ago.
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`Q. You -- were you a professor during that time?
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`A. Yes. I was a professor at that time. I was a professor
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`at Oregon State University. And that's how I am timing it,
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`because it's definitely not after I moved to the University of
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`Illinois. It was at that time. So beyond that I don't recall
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`anything else.
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`Q. And you got your Ph.D. from Oregon State. Right?
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`A. Yeah. I received a Ph.D. degree from Oregon State.
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`Q. Who was your advisor there?
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`A. My advisor was Dr. Un-Ku Moon.
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`Q. Do you understand that Dr. Moon is also consulting for ADI
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`in this matter, in this litigation?
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`A. I have heard his name mentioned by some of the attorneys,
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`and that's the length to which I know his involvement.
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`Q. Have you spoken to Dr. Moon about this proceeding or the
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`corresponding litigation between ADI and Xilinx?
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`A. No, I haven't spoken with him.
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`Q. Do you have any legal training?
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`A. I did not go to law school, so I don't have any -- yeah.
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`I don't have any legal training.
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`Q. Prior to this -- let's start with this proceeding. Prior
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`to this proceeding, have you ever worked on a patent dispute?
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`A. Like I said earlier, that -- I haven't worked on any
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`patent dispute prior to this case, other than that one thing I
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`mentioned previously where I have some vague recollection.
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`If -- if reading a patent would constitute to participating in
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`a patent dispute, I don't know.
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` But -- but that's the extent to which I have -- I have
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`participated. I have not participated in any other disputes.
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`Q. You submitted two Declarations in this proceeding. Is
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`that correct?
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`A. I have submitted two Declarations from the '615, with
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`regards to the '615 patent. Yes. That is correct.
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`Q. Did you draw up your First Declaration, which is -- I
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`believe it was submitted as Exhibit 2001, by Patent Owner?
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`A. Sorry. Counsel, can you please repeat the question?
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`Q. Did draw up your First Declaration, which was submitted as
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`Exhibit 2001 by Patent Owner?
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`A. Exhibit 2001. Yeah. I'm trying to connect that. So in
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`preparation of the Declaration, I have -- I have talked to the
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`attorneys at WilmerHale, during which I have presented my --
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`presented my analysis.
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` And -- and -- and the attorney at WilmerHale had put a
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`rough draft summarizing my analysis. And I have that draft and
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`edited it significantly; edited it. And that became my First
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`Declaration.
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`Q. Do you know who provided you with a rough draft?
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`A. Yeah. I have been working with Mr. Kipnis, and I believe
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`it is him who provided -- who -- in collaboration with him, the
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`first -- our first draft was -- First Declaration was drafted.
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`Q. Who else did you work with in -- to prepare your First
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`Declaration?
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`A. In preparing for the First Declaration -- in preparation
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`of the First Declaration, I -- we had many conversations, Zoom
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`calls or Webex calls, during which Mr. Kipnis and Mr. Peter
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`Dichiara have certainly participated; but in some instances,
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`maybe other attorneys may have joined the calls. But -- but my
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`memory is mostly Mr. Dichiara and Mr. Kipnis that I had worked
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`with in preparation of my First Declaration.
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`Q. So how long have you spent preparing your First
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`Declaration?
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`A. Yeah. I remember I spent significant -- a significant
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`amount of time. Yes. I mean, I remember spending a lot of
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`time on it.
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`Q. How much is a lot of time?
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`A. Maybe -- I don't -- I don't have an exact number, Counsel,
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`but somewhere -- I mean, this would be very -- this is -- I'm
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`trying to recollect the time for the First Declaration. Right?
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` So I don't know. I mean, in the ballpark of maybe -- I
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`don't know. This -- this -- this is a hard question because
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`I'm trying to recall exactly how many hours; but to the best of
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`my memory, I would say maybe 30 to 50 hours.
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` You know, that's -- that's the best I can recall at this
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`time. But -- yeah.
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`Q. Is it closer to 30 or closer to 50?
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`A. Counsel, I don't -- I mean, that's the best estimate I can
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`come with.
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`Q. You have submitted invoices for your work towards the
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`First Declaration?
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`A. I have submitted invoices for my work done towards the
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`First Declaration.
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`Q. Would those invoices refresh your recollection as to how
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`much time you have spent preparing your First Declaration?
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`A. Maybe, yes. I think I have to provide those invoices in
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`some detail, so I would -- I would believe that looking at the
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`invoices may give an indication of how much time I may have
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`spent.
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`Q. And you still have those invoices?
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`A. The invoices that I submitted with regards to the '659
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`work?
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`Q. Yes.
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`A. I believe so. I have them.
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`Q. Now, did you draft your Second Declaration, which was
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`submitted by Patent Owner as Exhibit 2044?
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`A. Exhibit 2044?
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`Q. Yes.
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`A. Yes. The procedure was similar to the way the First
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`Declaration was drafted, wherein there were -- there were many,
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`many discussions regarding the references and the arguments.
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`And -- and those were summarized as a rough draft by
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`Mr. Kipnis. And -- and then I have edited it. That's how the
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`Second Declaration came -- came -- was put together.
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`Q. Just so I'm clear, do you mind describing to me again the
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`process by which you prepared a Second Declaration?
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`A. Yes. I believe the first step was I was asked to -- I was
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`provided the board's decision. And I reviewed it. And that
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`was, if I recall correctly, the first step.
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` And after that, we have had conversations regarding the
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`petition, Dr. Holberg's Declaration, and the decision given by
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`the board, and maybe the references associated with all of
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`this.
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` This -- this is -- this is the material we discussed
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`during the conversations, during which I have presented my --
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`my views; my analysis on -- on the references that were in
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`question. And -- and based on that analysis, the Declaration
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`was -- the rough draft of the Declaration was put together and
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`given to me. And I worked on it to finalize it.
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`Q. What do you mean by "I worked on it to finalize it"?
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`A. I -- it was in a draft form, so I maybe would have
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`rewritten some portions of it to reflect my -- to explain
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`things more clearly my way. And that's what I meant.
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`Q. So are you saying that you were just basically putting the
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`draft Declaration into your own voice? Is that fair?
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` MR. KIPNIS: Objection to form.
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`BY MR. YAP:
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`Q. You may answer.
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`A. Yeah. What I was saying is I worked on the draft
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`Declaration and made changes to it to add more detail, for
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`instance, to my analysis. That would be one example.
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` But there might be others. And that's what I mean by
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`working on the draft Declaration.
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`Q. What are others?
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`A. Maybe -- I don't -- I mean, others could include maybe
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`some typographical errors; I mean, things like that.
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` I mean, I reviewed it thoroughly so all of the changes
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`that I have made fall into the category of explaining things
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`better, maybe rearranging some of the text, and fixing the
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`typos, and -- and such.
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`Q. So who did you work with to prepare a Second Declaration?
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`A. I have -- again, in preparation for this Declaration, I
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`have talked to attorneys at WilmerHale, primarily with
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`Mr. Kipnis and Mr. Dichiara. But during those calls, I don't
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`recall if others were present, but these are the two gentlemen
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`that I worked mostly with.
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`Q. So how many hours do you estimate you have spent working
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`on the draft, drafting your Second Declaration?
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`A. Well, I'm having the same difficulty I had previously.
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`But to the best of my memory, I spent more time on this. So I
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`don't know, Counsel, it's somewhere in the 40- to 60-hour
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`range. That would be -- that would be my best estimate, but
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`I -- I don't have -- I don't have a good memory to recall the
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`exact number of hours.
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`Q. What timing? Like -- strike that.
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` When did you start working on this draft of your Second
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`Declaration?
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`A. I don't recall the date; but I can tell you what triggered
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`this. I was -- I was -- I was given the decision from the
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`board. And subsequently I started working -- working on that,
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`which eventually resulted in -- in my Second Declaration, but I
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`don't --
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` Sitting here I don't recall exactly the dates, Counsel.
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`Q. So the board's -- strike that.
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` So I can represent to you that the board's decision came
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`down on January 25th, 2021. Does that help you, in terms of
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`the timing, as to when you started working on this, your
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`Declaration?
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`A. I'm not able to time myself, Counsel, so I don't recall.
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`There were so many things going on at that time, I don't
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`exactly recall when I started on this.
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`Q. What was going on during that time?
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`A. I was teaching a class here. And there is a big
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`conference at the time and a few other things that's going on
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`in my life.
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` So -- so the time lines and the dates that I can ascribe
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`to each and every event that took place during that time -- I
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`am not able to do that now.
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`Q. The conference that you were talking about -- when was
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`that on?
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`A. That was in sometime in February.
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`Q. Were you already working on the draft of your Declaration
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`during that time?
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`A. I don't recall. During that conference? I don't -- I
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`don't recall.
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`Q. Have you received any compensation from ADI for the work
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`that you have done -- for any work that you have done?
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` Actually, let me strike that.
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` Have you received any compensation from ADI?
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`A. In relation to this case, like I have said, for the work I
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`am doing on '659 and other related -- other -- other patents
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`involved in this case, I have regularly -- "regularly" being
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`whenever I did some work on a monthly basis some months --
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`yeah, roughly on a monthly basis, I have submitted invoices.
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` So I got -- those invoices were paid, at least in that
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`context that -- that I got paid.
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`Q. So other than the ADI-Xilinx matters, which includes the
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`litigation and some of the IPRs that you're on, have you
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`received any other compensation or money from ADI?
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`A. I haven't. To the best of my memory, no, I haven't
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`received any money from my personal matters -- I haven't
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`received money from my personal thing from ADI.
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`Q. So what about nonpersonal? Have you received any
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`compensation from ADI?
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`A. I haven't received any compensation from ADI.
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` My understanding of compensation is getting paid in return
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`to -- in return for doing something.
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` So with that meaning I did not get -- I did not get
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`compensated by ADI outside of this case.
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`Q. So have you kept -- have you ever gotten paid by ADI by
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`not doing anything?
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`A. No. No. I have not gotten paid by ADI for not doing
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`anything.
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`Q. So has ADI funded any of your work at universities that
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`you have been on the faculty?
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`A. ADI has provided an unrestricted gift to the University of
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`Illinois that -- and then the University of Illinois would let
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`me use that for my research activities. So in that sense, ADI
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`has provided.
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`Q. How much have you received from ADI through that source
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`over the years?
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`A. ADI has been providing unrestricted gifts to the
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`University of Illinois for the past -- I don't exactly remember
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`how many years. I would say four or five years or somewhere in
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`that range.
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` And so that's -- that's the duration for which I have
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`been -- Analog Devices has been giving these -- these
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`unrestricted gifts to the University of Illinois.
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` And during this time, I would say -- yeah -- it would
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`be -- I'm trying to back calculate. It would be somewhere in
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`the 300-350 range, depending on how many years it goes back.
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` During this time, that's -- that's the -- that's the total
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`funding or the amount of unrestricted gift that was given to
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`the University of Illinois.
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` And during this time, I also received funding from other
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`agencies and companies. And I would say considering all these
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`factors, I would have -- this would be, to the best of my
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`memory and a rough estimate. I spent maybe, in terms of yearly
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`expenses in my group, maybe less than 5 percent of the research
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`activities, roughly speaking, were using the funds that were --
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`that were -- that were provided by ADI to the University of
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`Illinois and to the University of Illinois system that we use.
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`Q. So to be clear, when you say "300 to 350," you meant
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`350,000 to -- or 300,000 to 350,000? Or is it 300 million to
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`350 million? What's -- what's the number? Can you --
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`A. I did not use the units then. Okay. So over the past
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`four, five, six years, the total amount of irrevocable gift --
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