Douglas R. Holberg, Ph.D. - August 23, 2021
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` U N I T E D S T A T E S P A T E N T A N D T R A D E M A R K O F F I C E
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` B E F O R E T H E P A T E N T T R I A L A N D A P P E A L B O A R D
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`X I L I N X , I N C . a n d X I L I N X A S I A P A C I F I C P T E . L T D . ,
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` P e t i t i o n e r ,
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` v .
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` A N A L O G D E V I C E S , I N C . ,
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` P a t e n t O w n e r .
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` C a s e N o . I P R 2 0 2 0 - 0 1 2 1 9
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` U . S . P a t e n t 8 , 4 8 7 , 6 5 9
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` D e p o s i t i o n o f
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` D O U G L A S R . H O L B E R G , P h . D .
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` M o n d a y , A u g u s t 2 3 , 2 0 2 1
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`R E P O R T E D B Y : J O H N W I S S E N B A C H , R D R , C R R , C B C , C C P ,
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` C L R , C S R 6 8 6 2
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`Douglas R. Holberg, Ph.D. - August 23, 2021
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`2 (Pages 2 to 5)
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` EXAMINATION BY MR. KIPNIS
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` Q. Okay. So good morning, Dr. Holberg.
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` A. Howdy.
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` Q. Nice to see you again.
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` A. It's good to be seen.
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` Q. So this is -- this is Jason Kipnis, on behalf
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`of Analog Devices.
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` Please state and spell your full name for the
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`record.
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` A. My full name is Douglas, D-O-U-G-L-A-S, Reid,
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`R-E-I-D, Holberg, H-O-L-B-E-R-G.
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` Q. And do you understand that you have taken an
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`oath to tell the truth today?
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` A. I understand that.
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` Q. And you understand that this proceeding is
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`focused on U.S. Patent Number 8,487,659?
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` A. Yes, I do.
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` Q. And would you understand that -- if I, in this
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`deposition, refer to the U.S. Patent 8,487,659 patent as
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`the '659 patent, would that be understandable to you?
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` A. That would be fine.
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`Page 2
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` INDEX OF EXAMINATIONS
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` Page
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`WITNESS:
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`DOUGLAS R. HOLBERG, Ph.D.
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` Examination by Mr. Kipnis . . . . . . . . . . . 4
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` EXHIBIT MARKED
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`Exhibit 2046 . . . . . . . . . . . . . . . . . . . 55
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` EXHIBITS REFERENCED
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`Exhibit 1001 . . . . . . . . . . . . . . . . . . . 7
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`Exhibit 1002 . . . . . . . . . . . . . . . . . . . 65
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`Exhibit 1004 . . . . . . . . . . . . . . . . . . . 70
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`Exhibit 1005 . . . . . . . . . . . . . . . . . . . 47
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`Exhibit 1018 . . . . . . . . . . . . . . . . . . . 48
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` ---o0o---
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` BE IT REMEMBERED that, pursuant to the laws
`governing the taking and use of depositions, on Monday,
`August 23, 2021, commencing at 11:00 a.m., before me,
`JOHN WISSENBACH, CSR 6862, of San Francisco, California,
`appeared through videoconference DOUGLAS R. HOLBERG,
`Ph.D., at Wimberley, Texas, called as a witness by the
`Patent Owner, who, being by me first duly sworn, was
`thereupon examined as a witness in said action.
`
` APPEARANCES OF COUNSEL VIA VIDEOCONFERENCE
`For the Petitioner:
` MORRISON & FOERSTER LLP
` BY: ALEX S. YAP, Attorney at Law
` HECTOR G. GALLEGOS, Attorney at Law
` ROSE S. LEE, Attorney at Law
` 707 Wilshire Boulevard
` Los Angeles, California 90017-3543
` (213) 892-5688 ayap@mofo.com
` (213) 892-5255 hgallegos@mofo.com
` (213) 892-5355 roselee@mofo.com
`For the Patent Owner:
` WILMERHALE LLP
` BY: JASON KIPNIS, Attorney at Law
` 2600 El Camino Real, Suite 400
` Palo Alto, California 94306
` (650) 600-5036 jason.kipnis@wilmerhale.com
`ALSO PRESENT: MIHAI MURGULESCU; MEHRAN ARJOMAND
`(realtime viewer)
`
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` Q. And you are an expert hired by Xilinx, correct?
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` A. That is correct.
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` Q. And you have prepared a declaration which was
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`submitted as Exhibit Number 1018; is that right?
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`Page 5
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` A. Yes, that's the exhibit number.
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` Q. And are you presently under the influence of
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`any alcohol, medication, et cetera, that would impair
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`your ability to testify accurately here today?
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` A. I'm not impaired.
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` Q. Any other reason you cannot give complete and
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`accurate testimony today?
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` A. I can't think of any other reasons.
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` Q. Okay. And so I understand you have had your
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`deposition taken previously, including by me, in the
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`past. Do you agree?
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` A. I agree.
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` Q. And like an in-person deposition, I'm going to
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`ask you questions. If there's anything about any of my
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`questions that you don't understand, could you please
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`let me know?
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` A. I will.
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` Q. And if you do answer a question, I'm going to
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`assume that you have understood it. Is that fair?
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` A. That's fair.
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` Q. And because we're not all seated in the same
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`room today, can I ask you where you are currently seated
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`this morning?
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` A. I'm in my home office in Wimberley, Texas.
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` Q. And is there anybody else in the room with you?
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`
`

`

`Douglas R. Holberg, Ph.D. - August 23, 2021
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` A. Nobody's in the room with me.
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` Q. And aside from this Zoom conference call, video
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`call, do you have any other chat or other communications
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`programs open, any computer platforms, right now in your
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`office?
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` A. My email tool was open. I just closed it.
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`Firefox browser.
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` Zoom meeting is the only thing that's open.
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` (Mr. Murgulescu joined the deposition.)
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`BY MR. KIPNIS:
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` Q. Great. And could you also please put aside
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`your cell phone if you have it handy nearby.
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` Q. Okay.
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` MR. YAP: I'm fine.
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`BY MR. KIPNIS:
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` Q. Great. Okay. So if you could please turn to
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`figure 1 of the '659 patent.
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` A. Okay. I'm there.
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` Q. You see the RESET signal shown in figure 1?
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` A. Yes. That would be the signal at the input to
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`preamplifier 123 on the left bottom.
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` Q. And would a -- well, before I ask that, so I
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`might refer to the term "POSITA." Do you understand
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`that when I use that term, "POSITA," that I'm referring
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` A. I have it on airplane mode.
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` Q. Okay. Perfect. That's -- and do you
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`understand that you are not allowed to exchange any chat
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`messages, texts, or other types of communications with
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`counsel during the examination?
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` A. Yes, I understand.
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` Q. Okay. Do you have any paper documents with
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`you?
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` A. I do.
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` Q. And what are they?
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` A. I have my second declaration, my first
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`declaration. I have the Ajit patent. I have the
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`Yoshioka paper. And I have the '659.
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`to a person of ordinary skill in the art?
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` A. Yes, I do.
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` Q. Okay. Would a POSITA expect that the RESET
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`signal shown in figure 1 could be impacted by PVT
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`variations?
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` MR. YAP: Objection; form.
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` THE WITNESS: Well, where does -- just looking
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`in this figure alone, without any other context, there's
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`no -- it's just a signal. Is it coming from -- off the
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`chip somewhere or is it coming from inside of the chip?
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`If this were coming from another block within the
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`integrated circuit, yes, I would expect it to have
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`PVT -- PVT would impact it.
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` Q. Okay. And are those clean copies?
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` A. Yes, they are.
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` Q. There's no handwritten notes or highlights on
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`them?
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` A. No handwritten notes, no highlights on them.
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` Q. Okay. Do you have any -- I think you might
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`have answered this already, but do you have any
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`electronic document files open on any electronic device?
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` A. Everything is closed except for the Zoom
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`meeting.
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` Q. Okay. So today if at any point you need a
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`break when there is not a question pending, if you just
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`BY MR. KIPNIS:
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` Q. Would you expect PVT to impact it if it was
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`coming from outside the chip?
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` MR. YAP: Objection; form.
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` THE WITNESS: Well, in general the RESET --
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`even if the RESET signal is from outside the chip -- and
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`I'm speaking kind of hypothetically here. If you had
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`chip A that had an output that's RESET and this goes
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`into chip B, then chip A is also going to have -- PVT's
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`going to impact its signals as well. So, therefore, the
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`PVT would impact RESET coming out of the other chip.
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`BY MR. KIPNIS:
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` Q. Okay. And just for clarification, when we
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`let me know, I'll be happy to -- to stop, and we can
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`have a break. Is that okay?
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` A. That's fine.
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` Q. And during those breaks, you understand that
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`you're not allowed to speak with your attorneys about
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`your testimony. Is that understood?
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` A. Yes, that is understood.
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` Q. Okay. Great. So could you please turn to U.S.
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`Patent Number 8,487,659, which is Exhibit 1001.
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` And do people need me to upload that in the
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`chat link, provide a link, or does everybody have a copy
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`of that?
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` A. I have a copy.
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`refer to "PVT" today, do you understand that that
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`acronym refers to process, voltage, and temperature?
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` A. Yes.
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` Q. And how might a POSITA expect PVT variations to
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`impact the RESET signal shown in figure 1?
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` MR. YAP: Objection; form, incomplete
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`hypothetical.
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` MR. KIPNIS: Counsel, I would appreciate it if
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`you don't make speaking objections. Are you familiar
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`with the Trial Practice Guide?
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` MR. YAP: That's not a speaking objection.
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` MR. KIPNIS: I believe it is. You're allowed
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`

`

`Douglas R. Holberg, Ph.D. - August 23, 2021
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`Page 10
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`4 (Pages 10 to 13)
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`to object to form. And the Trial Practice Guide lists
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`other objections of that type as being -- coaching the
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`witness.
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` MR. YAP: I believe --
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` MR. KIPNIS: I'd appreciate you limit your
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`objections to form objections or objections for
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`attorney-client privilege.
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` MR. YAP: Counsel, if you look at the Trial
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`Practice Guide, it actually explicitly states what
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`objections are not -- not acceptable, and it also lists
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`some objections that are objection -- that are
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`acceptable. So it doesn't include the complete list of
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` THE WITNESS: Okay. So let me --
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` MR. YAP: Incomplete hypothetical.
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` THE WITNESS: -- look at -- let me look at my
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`declaration here.
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` If I -- if I said something about that, I
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`certainly want to answer your question. But I don't
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`believe I did. But I'm going to -- I'm going to check.
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` Well, in the patent, in figure 5, it's
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`illustrating the way that the circuit in figure 4
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`operates as a result of some PVT changes.
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`BY MR. KIPNIS:
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` Q. Does figure 5 show any variation in the input
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`objections that are acceptable, but it did list certain
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`objections that are definitely not objectionable; for
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`example, "Objection, vague." But we shall -- why don't
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`you just do your deposition, and we shall just keep it
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`there.
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` THE WITNESS: If there was a question hanging,
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`I've already forgotten it.
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`BY MR. KIPNIS:
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` Q. Yeah. So Dr. Holberg -- let me see if I can
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`read it back.
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` How might a POSITA expect PVT variations to
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`impact the RESET signal shown in figure 1?
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` MR. YAP: Same objections.
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`RESET signal shown in figure 1 based on PVT variations?
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` A. It does not --
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` MR. YAP: Objection; form.
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` THE WITNESS: It does not appear to.
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`BY MR. KIPNIS:
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` Q. So did you consider, when comparing your
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`declarations, how PVT variations may impact that input
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`RESET signal?
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` MR. YAP: Objection; form.
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` THE WITNESS: There's nothing in my declaration
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`that talks about the PVT variations of -- of the RESET
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`signal directly as shown in figures 5 and figure -- in
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`all the figures, in fact. But if it were on the chip
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` THE WITNESS: I don't -- you know, I don't
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`think I covered that in my declaration, the source, the
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`RESET source, and how it might vary.
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` So unless you can point me to some place where
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`I alluded to it --
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`BY MR. KIPNIS:
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` Q. I don't know that -- whether you did or did
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`not. I'm asking the question today, though, if, in your
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`mind, a POSITA would -- how a POSITA would expect PVT
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`variations to impact the RESET signal.
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` MR. YAP: Same objections.
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` THE WITNESS: I wouldn't have a -- I wouldn't
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`along with the other stuff, it would vary -- have PVT
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`variations as well.
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`BY MR. KIPNIS:
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` Q. And how might those PVT variations impact the
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`RESET signal?
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` MR. YAP: Objection; form.
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` THE WITNESS: It depends on where -- where it's
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`sourced from, what circuit. And since there's no
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`circuit provided, I can't offer an answer.
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`BY MR. KIPNIS:
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` Q. Okay. Can we please turn to the Yoshioka
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`reference, which was labeled Exhibit 1004. I believe
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`you have that handy.
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`be able to give you an answer there, because I'd -- I'd
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`have to consider where the RESET's coming from. It's --
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`it's way too big of a hypothetical.
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`BY MR. KIPNIS:
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` Q. So you haven't considered, in preparing your
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`declaration, how PVT variations might impact that RESET
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`signal?
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` MR. YAP: Objection; mischaracterizes the
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`witness's testimony.
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` THE WITNESS: Well --
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` MR. KIPNIS: Counsel, I'd appreciate if you
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`stick to form objections, that are allowed under the
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`Trial Practice Guide.
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` A. I do.
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` Q. And do I need, for anybody else's benefit, to
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`upload a copy of that exhibit?
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` Okay. I'm assuming no.
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` Does Yoshioka state that PVT variations can
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`impact the internal clock generator circuit?
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` MR. YAP: Objection; form.
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` THE WITNESS: Well, I did address this in my
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`declaration at least in some form. Hold on.
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` So in paragraph 59, it says, "The Board was
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`correct when it found that 'Patent Owner and Dr.'" --
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`let's see.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`

`

`Douglas R. Holberg, Ph.D. - August 23, 2021
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`Page 14
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`5 (Pages 14 to 17)
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` "The Board was correct when it found that
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`'Patent Owner and Dr. Hanumolu do not persuasively
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`explain why the delay controller," which is part of the
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`clock generator, by the way, "would be affected by
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`variations in PVT conditions, but the comparator would
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`not.'"
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` So here I'm going to extract, from that, the
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`clock -- clock generator is affected by PVT variations.
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`BY MR. KIPNIS:
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` Q. Does Yoshioka describe the impact of PVT
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`variations on the comparator?
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` MR. YAP: Objection; form, document speaks for
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` MR. KIPNIS: -- (audio dropout) "to a single
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`word or term." Your objection was that the document
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`speaks for itself. Not only is that more than one word,
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`but it suggests an answer to the witness. This is
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`completely improper, and I ask that you limit your
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`objections to the guidance in the Trial Practice Guide.
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` MR. YAP: I disagree with you, and I -- and,
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`again, I state that the examples given in the Trial
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`Practice Guide are basically objections, are basically
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`examples. But you may continue.
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` THE WITNESS: So in paragraph 60 -- I'll read
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`from my declaration. I think it covers your answer.
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`itself.
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` MR. KIPNIS: Counsel, the Trial Practice Guide
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`is pretty darn clear that "Objections should be limited
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`to a single word or term" and you should "not
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`make...statements" or objections "that suggest an answer
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`to" the "witness." And that's a direct quote. I would
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`appreciate if you limit your objections to the guidance
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`provided in the Trial Practice Guide.
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` MR. YAP: Counsel, I disagree. I do agree that
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`the Trial Practice Guide states that, and I quote,
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`"Objections should be limited to a single word or term,"
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`and "Examples" -- and I'm -- "Examples of objections
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`that would be properly stated are," and those are
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` "A POSITA would recognize that comparator delay
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`indisputably will change with PVT. Indeed, ADI and
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`Dr. Hanumolu relies on this fact in ADI's attempt to
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`swear behind Yoshioka....showing how comparator
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`performance and regenerative time constant tau vary with
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`PVT and stating" that "the comparator will have more
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`delay with small input differences, and less delay with
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`larger" voltage -- "input voltages."
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` Continuing, "ADI and Dr. Hanumolu's assertion
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`that Td only reflects the impact of PVT on the delay
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`controller is incorrect. Td itself is a function of PVT
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`effects on the comparator, e.g.," comparator -- "on
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`comparator speed. 'Figure 3 shows the internal clock
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`Page 15
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`examples: "'Objection, form'; 'Objection, hearsay';
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`'Objection, relevance'; and 'Objection foundation.'"
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`Those are examples.
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` Objections -- objections that are "not...proper
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`are: 'Objection, I'" do not "'understand the
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`question'...'Objection, look at the document before you
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`answer.'" Objection, the party -- "Objecting party must
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`give a clear and concise explanation."
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` "'Objection, look at the document before you
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`answer.'"
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` And because -- if I don't make an objection,
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`and then objection is waived. And I believe my
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`generator, which includes the comparator'" -- and this
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`is a quote from -- from Yoshioka. "'Figure 3 shows the
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`internal clock generator, which includes the comparator
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`in its loop,'" closed quote, and then open quote:
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`"'This loop,'" paren, "'that generates phi_c'" -- that's
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`P-H-I, underscore C or the Greek character phi, for the
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`court reporter -- "'is dependent on the PVT conditions,
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`so its frequency is controlled during the conversion.'"
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` "Internal clock phi_c period =Tc1+Tc2+" 2d --
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`"2Td."
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` "To" remain -- "To maintain the number of phi_c
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`cycles N at 10, when Td changes in response to PVT, so
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`must Tc1 and Tc2, the delays through the comparator."
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`objections are proper.
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` MR. KIPNIS: That is clearly incorrect. Those
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`are examples given in the Trial Practice Guide.
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` MR. YAP: Precisely.
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` MR. KIPNIS: Not -- it's not a --
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` MR. YAP: Those are examples of how --
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` MR. KIPNIS: It's not a complete list. The
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`Trial Practice Guide --
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` MR. YAP: That --
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` MR. KIPNIS: -- unequivocally says that you
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`"must not make objections...that suggest an answer to"
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`the "witness." It also says they "should be" --
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` MR. YAP: How --
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` "Yoshioka's adaptive delay device is thus
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`responding to PVT effect on other components," for --
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`"e.g., the comparator."
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`BY MR. KIPNIS:
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` Q. So Dr. Holberg, does Yoshioka describe how PVT
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`variations impact the delay through the comparator;
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`not -- not whether --
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` MR. YAP: Objection; form.
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`BY MR. KIPNIS:
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` Q. -- they impact. I'm asking how they impact the
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`delay through the comparator.
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` MR. YAP: Objection; form.
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`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`

`

`Douglas R. Holberg, Ph.D. - August 23, 2021
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`Page 18
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`6 (Pages 18 to 21)
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` THE WITNESS: Do you mean "how" like plus or
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`minus time or how -- what do you mean?
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`BY MR. KIPNIS:
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` Q. Well, let's take that apart. So does Yoshioka
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`explain how, say, an increase in voltage may impact the
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`delay through the comparator?
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` MR. YAP: Objection; form.
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` THE WITNESS: Oh, another place, to supplement
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`my last answer, in -- on page 411, under the -- under
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`paragraph C, "Comparator and Internal Clock
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`Generator" -- I don't think I quoted this -- it says,
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`"The frequency of phi_c depends on the comparator
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`its frequency is controlled during the conversion.'"
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`And the comparator is in that loop.
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`BY MR. KIPNIS:
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` Q. How does that statement explain how an increase
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`in temperature impacts whether the delay through the
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`comparator is increased or decreased?
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` A. It's --
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` MR. YAP: Same objection.
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` THE WITNESS: It's -- it says it's subject to
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`the PVT conditions. And that can be process, voltage,
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`and temperature. That means process going from fast to
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`slow, slow to fast, or somewhere in between; voltage
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`response delay and Td."
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` So that brings the -- the delay feeds into it.
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`So the -- the frequency depends on the comparator delay.
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`BY MR. KIPNIS:
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` Q. I don't believe it answered my question. Let
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`me refer you --
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` A. No, I'm still working on your answer.
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` Q. Oh, okay. Okay.
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` A. So under -- on that same page, 411, Roman
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`numeral III, "Digital Calibration," subparagraph A,
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`which is entitled "Comparator Offset Cancellation," that
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`paragraph bleeds into the next page, 412, where it says,
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`"Another dynamic offset" cancellation "technique," in
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`going from high to low, low to high, or somewhere in
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`between; and temperature going high to low, low to high,
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`or in between. It really doesn't matter which direction
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`as long as you're correcting for it.
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`BY MR. KIPNIS:
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` Q. Would you agree that that statement that you
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`read from Yoshioka explains that PVT conditions may have
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`an impact on the performance of the comparator? Let's
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`stop there. Would you agree with that statement?
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` MR. YAP: Objection.
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` THE WITNESS: That's not what it --
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` MR. YAP: Form.
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` THE WITNESS: -- says.
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`reference 8, "controls the clock skew, which results in
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`a less of a response penalty; however, the timing
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`control is sensitive to PVT variations."
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` Q. Are you still working on the answer, or --
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` A. Yeah. I'm still working on it.
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` Q. Okay.
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` A. The -- Yoshioka -- as I read in the quote in my
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`declaration, Yoshioka -- and I'll repeat it. The loop,
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`which includes the comparator, "'This loop...is
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`dependent on the PVT conditions, so its frequency is
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`controlled during the conversion.'"
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` And so the loop, which includes the comparator
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`and the clock generator, determines the frequency phi_c,
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` MR. YAP: Same objection.
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` THE WITNESS: It says, "'This loop...is
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`dependent on the PVT conditions, so its frequency is
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`controlled during the conversion.'"
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`BY MR. KIPNIS:
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` Q. And how does that statement convey whether an
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`increase in temperature will increase or decrease the
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`delay through the comparator?
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` MR. YAP: Objection; form.
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` THE WITNESS: It's part of the loop.
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`BY MR. KIPNIS:
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` Q. Does that statement say that an increase in
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`and they depend on PVT.
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` And so your question is -- you asked me does
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`the comparator -- does Yoshioka say what the comparator
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`does when the voltage goes up. I don't know if you said
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`up or down. I don't see Yoshioka giving that level of
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`detail.
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` Q. Thank you. Does Yoshioka explain how an
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`increase in temperature may impact the delay through the
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`comparator?
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` MR. YAP: Objection; form.
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` THE WITNESS: Yes, he does. He says, "'This
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`loop is dependent on the'" PV -- "'PVT conditions, so
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`temperature will increase the delay through the
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`comparator?
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` MR. YAP: Same objection.
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` THE WITNESS: The statement says, "'This
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`loop...is dependent on the PVT conditions, so its
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`frequency is controlled during the conversion.'"
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`BY MR. KIPNIS:
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` Q. That's not an answer to my question,
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`Dr. Holberg. Let me ask it again.
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` Does that loop convey that an increase in
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`temperature will increase the delay through the
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`comparator?
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` MR. YAP: Same objection.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`

`

`Douglas R. Holberg, Ph.D. - August 23, 2021
`
`Page 22
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`7 (Pages 22 to 25)
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` THE WITNESS: The loop is comprised of all the
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`components I recited earlier. The internal clock period
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`is -- is "Tc1+Tc2+" 2D. The Tc1 and Tc2 are the
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`comparator delays. The -- the control loop adjusts Td
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`to maintain a -- to control the frequency. If the
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`comparator delay goes up as a function of temperature
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`going up, it will adjust accordingly. If the comparator
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`delay goes down as a result of temperature going up, it
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`will adjust accordingly. Yoshioka's internal clock
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`generator is -- you know, adjusts regardless of which
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`direction the comparator goes as a function of
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`temperature. So -- so there.
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`BY MR. KIPNIS:
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` Q. Does Yoshioka say how the comparator delay
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`changes if the voltage goes down?
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` MR. YAP: Same objection.
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` THE WITNESS: It does -- I read this statement
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`the -- from Yoshioka a while ago about "The internal
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`clock control adjusted suitable Td to the variation in
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`the supply voltage." It doesn't call out the comparator
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`specifically there, but the comparator is in that loop.
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` MR. YAP: So, Counsel, it's been about an hour,
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`so if you're more or less done with this module or at a
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`good point, maybe you can take a break.
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`BY MR. KIPNIS:
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` Q. Dr. Holberg, I'm asking a very simple yes-or-no
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`question. Does Yoshioka state anywhere whether an
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`increase in temperature will result in an increase in
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`delay through the comparator?
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` MR. YAP: Objection; form.
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` THE WITNESS: Well, you know, we both have the
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`same document. I'm pretty sure I know the answer, but I
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`think I'm going to read back through it and make sure.
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` So a couple things to note here, and then I'll
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`get to the -- to the final answer. Under the paragraph
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`C, "Internal Clock Control," one of the things -- and
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`I'm not sure that I point out in my declaration -- is
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` MR. KIPNIS: A few more questions.
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` MR. YAP: No problem.
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`BY MR. KIPNIS:
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` Q. So that statement, Dr. Holberg, that you just
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`read from Yoshioka, does it say anything about how the
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`comparator delay changes when the voltage goes down?
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` MR. YAP: Same objection.
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` THE WITNESS: As I said -- and I'll read the
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`sentence again, and then I'll -- I'll -- I'll say
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`something.
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` "The" -- the sentence says, "The internal clock
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`control adjusted suitable" -- let me read it again. I
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`think I missed a word.
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`Page 23
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`the following sentence: "The Td controller works in the
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`background, as shown in Figure 4, because the voltage
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`and temperature conditions are not constant during
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`operation."
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` And another -- in the -- the "Experimental
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`Results" section, page 415, left column, it's talking
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`about the experimental results with relationship to
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`supply voltage. It says, "The internal clock control
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`adjusted suitable Td to the variation in the supply
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`voltage." So clearly something in that loop is changing
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`as a function of supply voltage. And then is there one
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`other thing?
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` "The internal clock control adjusted suitable
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`Td to the variation in the supply voltage."
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` So, no, that sentence does not include the word
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`"comparator."
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`BY MR. KIPNIS:
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` Q. Does Yoshioka describe how a given process
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`variation may increase or decrease the comparator delay?
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` MR. YAP: Objection; form.
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` THE WITNESS: Yoshioka -- and I'm being -- I'm
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`repeating myself -- states that the "loop," which "is
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`dependent" upon "PVT conditions," and the loop includes
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`a comparator. So it's implicit there, but Yoshioka
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`never says which direction the comparator goes for a
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` But nowhere -- and then the other -- the other
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`place is in the right column on page 415. It says, "The
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`internal clock is controlled in the background to
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`compensate for PVT variations."
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` So -- but nowhere does Yoshioka say if the
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`temperature goes up, the comparator delay goes down or
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`up. It doesn't say when the voltage goes up the
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`comparator delay goes down or up.
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`BY MR. KIPNIS:
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` Q. And does Yoshioka say how the comparator delay
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`changes if the temperature goes down?
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` MR. YAP: Objection; form.
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` THE WITNESS: No.
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`given process corner.
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` MR. KIPNIS: Thank you. We can do a break.
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` (Recess taken.)
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`BY MR. KIPNIS:
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` Q. Dr. Holberg, does Yoshioka describe how PVT
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`variations may impact the delay through the CDAC?
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` MR. YAP: Objection; form.
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` THE WITNESS: Well, I don't see anywhere in
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`Yoshioka where he describes the settling time of CDAC as
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`a function of temperature.
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`BY MR. KIPNIS:
`
` Q. Does Yoshioka refer to the settling time of
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`

`

`Douglas R. Holberg, Ph.D. - August 23, 2021
`
`Page 26
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`8 (Pages 26 to 29)
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`Page 28
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`CDAC as a function of process or voltage?
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` MR. YAP: Objection; form.
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` THE WITNESS: So in the abstract, I'll read the
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`first sentence and then provide an additional
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`commentary.
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` "This 10-bit 50-megasamples per second SAR
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`analog-to-digital converter, ADC, features on-chip
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`digital calibration techniques, comparator offset
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`cancellation, a capacitor digital-to-analog converter,
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`CDAC, linearity calibration, and internal clock control
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`to compensation for PVT variations."
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` So the calibration of the CDAC is to compensate
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` A. Oh, okay. I get your point. I thought you
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`were --
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` MR. YAP: Objection; form.
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` THE WITNESS: I thought you were talk --
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`speaking of some specific delay that was -- you know,
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`like the Td, for example, in the delay controller.
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` Okay. So -- okay. Now that I'm -- now that
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`I'm calibrated to your question, you're asking me does
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`Yoshioka tell me how much the delay -- any delay
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`variations in the -- in the Digital Calibration Circuit
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`as a function of PVT?
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`BY MR. KIPNIS:
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`for PVT variations. Then that would be process,
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`voltage, and temperature variations. But I -- in my
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`read here, I don't see specifically where Yoshioka calls
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`out the -- the CDAC increases or decrease of settling
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`time as a function of voltage.
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` Oh, you said process. Well, I said voltage the
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`last time, so now we're in process. He doesn't say
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`which direction it goes as a function of process. But
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`it's calibrated to address process voltage and
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`temperature variations.
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`BY MR. KIPNIS:
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` Q. Does Yoshioka describe how PVT variations would
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`