Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` _______________________________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` _______________________________________
`
` XILINX, INC. And XILINX ASIA PACIFIC PTE. LTD.
` Petitioner
`
` v.
`
` ANALOG DEVICES, INC.
` Patent owner
`
` ________________________________
`
` IPR2020-01336
`
` Patent No. 7,012,463
`
` ________________________________
`
` Remote Examination of PETER KINGET
`
` Monday, June 28, 2021 - 10:02 a.m.
`
`Reported by:
`
`JESSIE WAACK, RDR, CRR, CCRR, NYRCR, NYACR,
`CCR-NJ (No. 30XI008238700) CSR-TX (No. 11958)
`CCR-WA (No. 21007264), CSR-CA (No. 14420),
`REALTIME SYSTEMS ADMINISTRATOR
`Job No.: 2633
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` _______________________________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` _______________________________________
`
` XILINX, INC. And XILINX ASIA PACIFIC PTE. LTD.
` Petitioner
`
` v.
`
` ANALOG DEVICES, INC.
` Patent owner
`
` ________________________________
`
` IPR2020-01336
`
` Patent No. 7,012,463
`
` ________________________________
`
` Remote Examination of PETER KINGET
`
` Monday, June 28, 2021 - 10:02 a.m.
`
`Reported by:
`
`JESSIE WAACK, RDR, CRR, CCRR, NYRCR, NYACR,
`CCR-NJ (No. 30XI008238700) CSR-TX (No. 11958)
`CCR-WA (No. 21007264), CSR-CA (No. 14420),
`REALTIME SYSTEMS ADMINISTRATOR
`Job No.: 2633
`
`TransPerfect Legal Solutions
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`
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`Page 2
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` REMOTE EXAMINATION of PETER KINGET,
`
`taken before JESSICA R. WAACK,Registered
`
`Professional Reporter, Registered Merit
`
`Reporter, Certified Realtime Reporter,
`
`Registered Diplomate Reporter, California
`
`Certified Realtime Reporter, New Jersey
`
`Certified Court Reporter (License No.
`
`30XI008238700); Texas Certified Shorthand
`
`Reporter (License No. 11958); Washington State
`
`Certified Court Reporter (License No. 21007264);
`
`California Certified Shorthand Reporter (License
`
`No. 14420); New York Association Certified
`
`Reporter, New York Realtime Court Reporter and
`
`Notary Public of the States of New York,
`
`Pennsylvania and Virginia, taken remotely in New
`
`York, on Monday, June 28, 2021, commencing at
`
`10:02 a.m. EDT and concluding at 5:46 p.m. EDT.
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` A P P E A R A N C E S
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` (All participants appeared remotely.)
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`Page 3
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` ON BEHALF OF THE PETITIONER:
`
` SLATER MATSIL
`
` BY: STEVEN H. SLATER, ESQ.
`
` BY: LI LI, ESQ.
`
` 17950 Preston Road, Suite 1000
`
` Dallas, Texas 75252
`
` 972-732-1001
`
` Sslater@slatermatsil.com
`
` Lli@slatermatsil.com
`
` ON BEHALF OF THE PATENT OWNER:
`
` WILMERHALE
`
` BY: BRIAN LAMBSON, ESQ.
`
` BY: JASON KIPNIS, ESQ.
`
` 1875 Pennsylvania Avenue, NW
`
` Washington, DC 20006
`
` 202-663-6190
`
` Brian.lambson@wilmerhale.com
`
` Jason.kipnis@wilmerhale.com
`
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`Page 4
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` A L S O P R E S E N T
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` MIHAI MURGULESCU, with Analog Devices
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` SHIRLEY FUNG, with Analog Devices
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` LINDSAY McGUINNESS, with Analog Devices
`
` --o0o--
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`Page 5
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` INDEX TO EXAMINATION
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` WITNESS: PETER KINGET
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` EXAMINATION PAGE
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` BY MR. SLATER 7
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` -o0o-
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` INFORMATION REQUESTED
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` None
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` WITNESS INSTRUCTED NOT TO ANSWER
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` None
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` INDEX TO PREVIOUSLY MARKED EXHIBITS
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` WITNESS: PETER KINGET
`
` Monday, June 28, 2021
`
` MARKED DESCRIPTION PAGE
`
` Exhibit 1005 Excerpts from the Johns and
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` Martin "Analog Integrated
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` Circuit Design" book 138
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` Exhibit 1007 Oliaei patent 6,697,001 55
`
` Exhibit 2002 Declaration of Peter Kinget 17
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` ** A copy of the previously marked
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` exhibits is included **
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` --o0o--
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` ******
`
` REMOTE PROCEEDINGS
`
` June 28, 2021, 10:02 a.m.
`
` New York, New York
`
` *****
`
` PETER KINGET,
`
` called as a witness herein,
`
` having been first duly sworn on
`
` oath, was examined and testified
`
` as follows:
`
` *****
`
` EXAMINATION
`
` BY MR. SLATER:
`
` Q. Good morning, Dr. Kinget.
`
` A. Good morning.
`
` Q. How are you today?
`
` A. I'm good. How are you?
`
` Q. I'm good. Thank you.
`
` My name is Steve Slater. I'm an
`
` attorney representing Xilinx in this case,
`
` and Xilinx is the petitioner.
`
` So let me just start off with
`
` some introductories, make sure we're on the
`
` same page and have a common basis.
`
` Dr. Kinget, have you given a
`
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` deposition virtually before?
`
` A. No.
`
` Q. Okay. First time.
`
` What about giving a deposition in
`
` live testimony?
`
` A. I have done that before.
`
` Q. Okay. About how many times have
`
` you given your deposition?
`
` A. A handful of times. A couple of
`
` times. I don't know an exact amount.
`
` Q. So five to ten times perhaps?
`
` A. Yeah. Closer to five, I think.
`
` Q. Okay. Have you ever had the
`
` opportunity to testify live in court
`
` before?
`
` A. No, I have not.
`
` Q. Well, we did have a couple
`
` preliminaries, as you know, before starting
`
` the deposition. And just to emphasize some
`
` of those for the benefit of the court
`
` reporter, it's important that we give each
`
` other space, if you will, that we don't
`
` talk over each other.
`
` So if you would, please allow me
`
` to finish my questions before answering,
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` and I will endeavor to do the same and
`
` allow you to finish your answers before I
`
` ask the next question. And if I don't, you
`
` can be sure and let me know about that,
`
` okay?
`
` A. That sounds good.
`
` Q. And likewise, although, you know,
`
` we have this video feed, I can see you
`
` responding to me. For the record, when you
`
` answer my questions, it's important that
`
` you do so verbally. And we need to have
`
` answers such as yes or no and not, you
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` know, vocations that aren't clearly
`
` articulated.
`
` A. Yes, I know.
`
` Q. I will -- at certain points your
`
` attorney might object to some of the
`
` questions I ask, and in that case, you
`
` know, he will make his objection for the
`
` record, but I would ask that unless you are
`
` specifically instructed by the attorney not
`
` to answer my question, that once he's made
`
` his objection for the record, you go ahead
`
` and answer the question.
`
` Can you agree to that?
`
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` A. Understood, yes.
`
` Q. Okay. Great. When you've given
`
` your deposition previously, was that with
`
` respect to an inter partes review
`
` proceeding such as the one that we are
`
` involved in today?
`
` A. As far as I can recall right now,
`
` I don't think so.
`
` Q. Okay. Were any of your prior
`
` deposition experiences relating to a patent
`
` infringement lawsuit?
`
` A. Yes.
`
` Q. Okay. Were they, as far as you
`
` recall, all related to patent infringement
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` lawsuits?
`
` A. Yes.
`
` Q. And in your prior -- strike that.
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` When you have given a deposition
`
` previously, was that in a capacity as an
`
` expert witness?
`
` A. Yes.
`
` Q. And I ask, you know, the term
`
` "expert witness" as opposed to perhaps
`
` being deposed as a fact witness such as an
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` inventor of a patent, for instance?
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` A. So, no, I was deposed as an
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` expert witness in the prior cases.
`
` Q. Okay. When you have been deposed
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` as an expert witness, were you testifying
`
` on behalf of the patent owner in all of
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` those prior depositions?
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` A. As far as I recall, I think that
`
` I've testified on both the side -- on both
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` sides.
`
` Q. Going back to preliminaries. Do
`
` you have any other applications running on
`
` your computer besides this web browser for
`
` the Zoom meeting?
`
` A. So I have the Zoom -- it's
`
` actually not in the browser, but it's an
`
` application Zoom that is running on my
`
` computer.
`
` And then I received in the chat
`
` from the court reporter [sic] a link that I
`
` opened, and so I have -- I'm not seeing it
`
` now, but on another desktop or behind this
`
` screen there is a browser window open which
`
` has that document that was shared with me.
`
` Those are the only two things open.
`
` Q. Okay. And were there tabs open
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` A. No. I see my calendar is also
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` open, but I'll close that for you.
`
` Q. Dr. Kinget, what about paper
`
` documents? Do you have any paper documents
`
` with you?
`
` A. So I have a printed copy of my
`
` declaration.
`
` Q. Okay.
`
` A. Well, and this is part of it.
`
` This is the exhibit part of it, so it's
`
` basically one. I have a printed copy of
`
` the '463 patent. I have a printed copy of
`
` the Oliaei patent.
`
` And I have a copy of the chapter
`
` by Vittoz, also one of the references. And
`
` I have a copy of the paper by Gerfers,
`
` which is also one of the references.
`
` Q. Okay. Any other --
`
` A. And I have --
`
` Q. Sorry?
`
` A. Sorry. And I have some empty
`
` paper and a pen. I assume that's fine.
`
` Q. Sure. The document that you just
`
` identified to me, and thank you for that,
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` do any of those documents have annotations
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` or notes on them?
`
` A. No. These documents are clean,
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` printed copies with no annotations
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` whatsoever.
`
` Q. Okay. Great. One thing that's a
`
` little bit different in IPR proceedings
`
` compared to district court proceedings is
`
` in these proceedings, the rules are a
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` little bit more strict about communications
`
` with a witness during the deposition.
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` So whereas in a district court
`
` proceeding during a break it may be
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` appropriate for the witness and the
`
` attorneys to discuss how things are going,
`
` the testimony, et cetera, in a proceeding
`
` such as this one, those communications
`
` would be considered inappropriate.
`
` So I just want to make sure
`
` you're aware of that. And I'm sure Brian
`
` or some of the other attorneys have already
`
` discussed that with you.
`
` A. Yes, we have discussed that. I'm
`
` aware.
`
` Q. Okay. Great. Another ground
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` rule, and I'm also sure you're aware of, is
`
` if my question at any point during the
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` proceeding is unclear, please just let me
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` know and ask for a clarification.
`
` A. I will do that.
`
` Q. Sometimes you might think I'm
`
` asking you an incredibly artful question to
`
` distract you when probably I'm just
`
` probably asking a very poor question, and
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` it needs to be reworded.
`
` So the -- and you are aware, are
`
` you not, that we are here to ask you
`
` questions about the declaration that I
`
` believe you alluded to earlier.
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` And just to make sure we're clear
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` on that, this is -- the declaration you
`
` showed me earlier is a declaration that you
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` prepared regarding the inter partes review
`
` that has been instituted against U.S.
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` Patent 7,012,463, correct?
`
` A. That is correct.
`
` Q. And I believe that was around
`
` April of twenty -- 29 that you prepared
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` that declaration, correct?
`
` A. So the declaration was submitted
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` on April 29, as it says -- of 2021 as it
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` says on page 67.
`
` Q. When I refer to the patent as the
`
` '463 or the '463 patent, you'll understand
`
` that I'm talking about 7,012,463, right?
`
` A. Yes.
`
` Q. Likewise, when I refer to your
`
` declaration, you will understand that we're
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` referring to this declaration that you
`
` submitted in April 29 of 2021, correct?
`
` A. Yes.
`
` Q. Dr. Kinget, how much time did you
`
` spend in preparing for your deposition
`
` today?
`
` A. Several hours. Two afternoons to
`
` get ready for the deposition.
`
` Q. Did you meet with any of the
`
` lawyers representing Analog Devices?
`
` A. Yes, we did.
`
` Q. Do you recall who you met with?
`
` A. So we all met -- well, we all met
`
` virtually, but I met with Brian Lambson. I
`
` met with Jason Kipnis, Peter Dichiara. So
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` those are all attorneys with WilmerHale.
`
` And also with Lindsay McGuinness
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` from Analog Devices, Shirley Fung from
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` Analog Devices, and Mihai -- I'll do my
`
` best -- I apologize, but I'll do my best,
`
` Murgulescu is hopefully good pronunciation
`
` of the last name of Mihai also from Analog
`
` Devices.
`
` Q. Did you review any documents in
`
` preparation for your testimony today?
`
` A. So I mainly reviewed the
`
` declaration, and as part of that also
`
` looked briefly at some of the references,
`
` you know, that I just also showed to you
`
` that I have printed out here. But the main
`
` focus was on, you know, the declaration
`
` itself.
`
` Q. So you mentioned the references.
`
` Would that include Oliaei, Vittoz and
`
` Gerfers?
`
` A. Yes. But, again, I just
`
` mainly -- when they were referenced in the
`
` declaration, I might have just
`
` cross-checked. But I mainly focused on the
`
` declaration for my preparation today.
`
` Q. Okay. I'm going to send out a
`
` link on this chat.
`
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` A. Okay.
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` Q. Give me just one minute.
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` And Dr. Kinget the link sent
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` out --
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` A. So should I --
`
` Q. Are you able to open it?
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` A. I'm asking, I'm supposed to open
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` it, right?
`
` Q. Yes, please.
`
` A. Okay.
`
` Q. And when you have that document
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` open, if you would please just let me know.
`
` A. Yes. I have it open and looking
`
` at the first page, this looks to be my
`
` declaration.
`
` Q. That was my hope that was your
`
` declaration. And I'm providing this mostly
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` just to make sure that, again, we have a
`
` clear record and we're all on the same
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` page.
`
` In the documents that I sent out,
`
` you'll notice on the first page in the
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` lower right-hand corner, it has a notation
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` "Analog 2002."
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` Do you see that, sir?
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` A. Yes.
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` Q. And I'll be referring to this
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` document as Exhibit 2002 or as your
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` declaration. And I'll represent to you
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` that this was the document that was
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` submitted to the board in this proceeding.
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` I will ask you questions about
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` this document. If the document you have
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` there printed in front of you corresponds
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` to this one, then just feel free to use
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` that one.
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` But I just wanted to make sure
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` for the record that when I ask you
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` questions about the declaration, I'll be
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` referring to this document, Analog
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` Exhibit 2002 as it was submitted to the
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` Patent Office.
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` A. Okay.
`
` MR. LAMBSON: Steve, as we
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` discussed, I'm not able to open the
`
` Dropbox links because of my firm's
`
` firewall, but I'll be following along
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` in a local copy.
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` MR. SLATER: Okay. Yeah, that's
`
` fine, Brian. I'd be happy to email you
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` this link, but I don't know if that's
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` going to work either if your firewall
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` is just blocking Dropbox.
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` MR. LAMBSON: Yeah, I think
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` that's okay for now. No need.
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` MR. SLATER: Okay.
`
` BY MR. SLATER:
`
` Q. Dr. Kinget, if you would, please,
`
` take a look at paragraph No. 8 of your
`
` declaration that has a table there.
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` A. Yeah. I assume this is okay.
`
` I'm actually going -- you'll see me look
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` down to the paper copy in front of me. I'm
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` going to assume that the two documents are
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` exactly the same, and so...
`
` Q. I think we're all under that
`
` assumption.
`
` A. Okay.
`
` Q. As long as you're looking off the
`
` paper copy, as long as that copy is what
`
` was submitted to the Patent Office, I think
`
` we're fine.
`
` And, you know, if during the
`
` course of what I'm asking doesn't quite
`
` sync up with what you're reading, we'll see
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` if there's a discrepancy there.
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` A. Thank you.
`
` Q. No, I understand. I'm kind of a
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` fan of paper myself. We went paperless in
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` this office many years ago, but I haven't
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` quite adapted to it.
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` Dr. Kinget, this paragraph 8
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` states that you reviewed references in
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` exhibits cited in your deposition, and
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` you've identified six documents there; is
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` that correct?
`
` A. So, yes, I'm looking at the table
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` on page 5. There are six documents that
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` have been numbered as an exhibit.
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` Q. Yes. So I misspoke actually.
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` You're correct six documents that are
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` numbered in the exhibit, and then there's a
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` seventh document identified as well,
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` correct?
`
` A. Yes. So the first document,
`
` petition, doesn't have an exhibit number.
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` Then if you look there are seven -- there
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` are seven other documents in the table.
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` Q. Yes, sir. Thank you for that
`
` clarification.
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` Did you rely upon these documents
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` in forming the opinions that you expressed
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` in your declaration?
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` MR. LAMBSON: Objection. Form.
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` THE WITNESS: So I used these
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` documents -- as these references and
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` exhibits during my analysis so that I
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` could form my opinions. But they
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` are -- so of course my expertise is --
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` let me maybe rephrase. But of course I
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` also used my expertise.
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` BY MR. SLATER:
`
` Q. Sure. I'm interested in whether
`
` you relied upon any other documents in your
`
` analysis for the declaration.
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` MR. LAMBSON: Objection. Form.
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` THE WITNESS: So these are the
`
` key documents that are also referenced
`
` in this declaration. In fact, there is
`
` one other -- there are a couple of
`
` references to 1013 for which I've seen
`
` the excerpts.
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` But, again, in order to write
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` this declaration, develop the opinions,
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` I mainly refer to these references and
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` exhibits.
`
` BY MR. SLATER:
`
` Q. You said there are a couple
`
` references to 1013. Can you clarify what
`
` you meant by that?
`
` A. So if you go to page 49, this is
`
` just one example. The second line I have a
`
` quote from Exhibit 1013.
`
` Q. Do you recall what Exhibit 1013
`
` is?
`
` A. It's a book by Allen and Holberg.
`
` I think it's called "CMOS Analog Circuit
`
` Design."
`
` Q. I see.
`
` A. And can I add to that?
`
` Q. Yes, sir, of course.
`
` A. So if you actually go to page 7
`
` again as one example, also the book by
`
` Johns and Martin "Analog Integrated Circuit
`
` Design," and has been referenced there.
`
` Q. Are you done, sir?
`
` A. Let me add maybe if you'll allow
`
` that -- go to page 62. In order to run the
`
` circuit simulations that I've included in
`
` my declaration, I also went online to
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` download a file with transistor parameters
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` which is actually quoted -- I mean, there
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` is a link provided in paragraph 97 on
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` page 62 of my declaration.
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` So as far as I, you know, can
`
` recall right now, those are the main
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` references used.
`
` Q. So you reference the Johns and
`
` Martin article or Johns and Martin
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` textbook, I think. And I was curious. The
`
` reason I ask about that, I was curious why
`
` that reference wasn't listed in
`
` paragraph 8, if you recall?
`
` A. No, I don't recall specifically.
`
` I can only notice that it is also
`
` referenced in the '463 patent, the textbook
`
` by Johns and Martin.
`
` And we -- you know, the '463
`
` patent is referenced. So there's no
`
` specific reason as far as I can tell why
`
` it's not in this particular table on
`
` page 5.
`
` Q. Okay. That's fine.
`
` And likewise, with regard to the
`
` Allen textbook, as an example,
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` Exhibit 1013, is there any particular
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` reason why it wasn't listed in the table?
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` A. Not as far as I know. Also the
`
` language in paragraph 8 says that it just
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` including, it's not claiming that this will
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` be an exclusive list in any way.
`
` Q. Sure. Understood. And that's
`
` why I'm asking these questions, just to
`
` clarify.
`
` We want to make sure that we have
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` an accurate record for the board so that
`
` they can evaluate all of the factual bases
`
` for your opinions.
`
` And this is why I am asking, are
`
` there any other documents that you -- let
`
` me start with, are there any other
`
` documents that you reviewed in preparing
`
` this declaration?
`
` A. Not as far as I can remember.
`
` Q. So it follows that there's no
`
` other document that you relied upon in
`
` preparing this declaration?
`
` MR. LAMBSON: Objection. Form.
`
` THE WITNESS: So as far as I
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` know, I think -- I provided accurate
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` references and quotes throughout the
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` declaration to the documents from which
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` information was taken or relied -- or
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` quoted.
`
` BY MR. SLATER:
`
` Q. Right. And I appreciate that.
`
` And my question is really directed towards
`
` whether there were other documents that you
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` had read even if you did not quote them in
`
` your declaration.
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` MR. LAMBSON: Objection. Form.
`
` THE WITNESS: Again, as far as I
`
` recall, these are the key references
`
` that I used to form my opinions, do my
`
` analysis and write the declaration.
`
` BY MR. SLATER:
`
` Q. Okay. Great.
`
` If you do happen to think of any
`
` others, you know, during the course of
`
` today, just let me know.
`
` A. Okay.
`
` Q. Going back to preliminaries. I
`
` probably should have asked, Dr. Kinget,
`
` where are you testifying from this morning?
`
` A. I am currently at home in Summit,
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` New Jersey.
`
` Q. Is there anyone there with you?
`
` A. So one of my children is in the
`
` basement downstairs, as far as I know.
`
` Q. Okay. Fair. But no one in the
`
` room with you?
`
` A. So let me -- one of my children
`
` with one of his friends is in the basement
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` downstairs, as far as I know. But in this
`
` room, there is nobody else.
`
` Q. Well, if at any time during
`
` today's proceedings you need to take a
`
` break and go and check on them, just let me
`
` know.
`
` A. I will.
`
` Q. And because I do sometimes tend
`
` to shorthand things a little bit, more than
`
` I should, I do want to clarify that during
`
` the course of today's questioning, when I
`
` ask you questions about a POSITA,
`
` P-O-S-I-T-A, do you understand what a --
`
` the term POSITA means?
`
` A. Yes. On page 5 in the
`
` declaration we also -- or I also refer to
`
` the person of ordinary skill in the art,
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` which I think is the abbreviation for
`
` POSITA. I tend to say "POSITA."
`
` Q. Absolutely I'll allow that.
`
` When we're talking about what a
`
` POSITA would know -- strike that question.
`
` On page 5 of your declaration at
`
` paragraph 9, you did reference the POSITA,
`
` and you said, "I have applied that level of
`
` skill for the purposes of this
`
` declaration."
`
` Last sentence of paragraph 9.
`
` Did I read that correctly?
`
` A. Yes. That's correct.
`
` Q. When you applied the POSITA level
`
` of skill for your declaration, you did so
`
` based upon what a POSITA would have known
`
` at the time of the invention of the '463
`
` patent, correct?
`
` MR. LAMBSON: Objection.
`
` THE WITNESS: So as I wrote in my
`
` declaration, I have applied the
`
` proposed level of education and
`
` experience of the POSITA at the time of
`
` the alleged invention of the '463
`
` patent.
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` BY MR. SLATER:
`
` Q. Great.
`
` When I ask you questions today
`
` about the understanding of a POSITA,
`
` regardless of whether I put a time frame on
`
` it, will you apply that same standard as in
`
` paragraph 9?
`
` A. Yes. As far as I've been
`
` instructed, that's the -- that's what I
`
` should do in terms of -- with regards to
`
` the POSITA.
`
` Q. Okay. Good.
`
` And, again, just looking for some
`
` common ground rules, because my questions
`
` do tend to sometimes be inartful. So I'm
`
` trying to cover that in advance.
`
` Dr. Kinget, concerning your
`
` previous and current experience, you're
`
` currently a professor; is that correct?
`
` A. That is correct.
`
` Q. At Columbia University?
`
` A. Yes.
`
` Q. Do you have any current courses
`
` that you are teaching?
`
` A. So we are in the summer semester
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` right now. I'm not teaching in the summer
`
` semester.
`
` Q. Do you plan to teach courses in
`
` the fall?
`
` A. In the fall I am scheduled to
`
` teach a course called Analog Circuit
`
` Design. It's a 4000 level course in the
`
` electrical engineering department.
`
` Q. 4000 level, is that -- what does
`
` "4000 level" mean?
`
` A. These are courses that are
`
` typically taken by senior undergraduate
`
` students and starting graduate students,
`
` master students or master PhD students.
`
` Q. So in that course, would you
`
` teach theory of circuit design for analog
`
` circuits?
`
` A. We cover a subset of the broad
`
` field of analog circuit design in that
`
` course.
`
` Q. Would that subset include, for
`
` instance, designing switch capacitor
`
` circuits?
`
` A. The familiar course I will teach
`
` coming fall might mentions -- well,
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` probably -- well, mentions which capacitor
`
` circuits, but they're not taught in great
`
` detail in that course.
`
` Q. Would the typical course load for
`
` a graduate student pursuing a master's
`
` electrical engineering at Columbia
`
` University include course work on switch
`
` capacitor semiconductor design?
`
` A. So just to be very accurate,
`
` master's students have a lot of liberty in
`
` choosing their program. These programs
`
` have a credit requirement, but we do --
`
` students choose certain -- discover maybe
`
` tracks or, you know, focus areas for their
`
` program.
`
` So if they choose the focus area
`
` in integrated circuit design and they
`
` follow the advice of the faculty advisors
`
` in terms of which are good courses to take
`
` in order to take a master's program in that
`
` direction, it does include courses that
`
` cover switch capacitor circuits in some
`
` more detail.
`
` Q. If a student was following the
`
` advice of the faculty advisors, would they
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` likely learn about common load feedback
`
` circuits in the program at Columbia
`
` University?
`
` A. Yes, they would.
`
` Q. And would they likely learn about
`
` charge injection effects in a common load
`
` feedback -- switch capacitor common load
`
` feedback circuit?
`
` A. So our courses are taught by
`
` various different faculty or instructors at
`
` different times. And so the syllabus and
`
` the material covered has some variations.
`
` So maybe sometimes, but maybe
`
` sometimes they wouldn't teach. So maybe
`
` sometimes they would teach this particular
`
` topic of charge injection and switch
`
` capacitor circuits, maybe sometimes there
`
` is less time to teach the topic. But I
`
` would assume that they would be aware of
`
` charge injections in switch capacitor
`
` circuits.
`
` Q. Would you assume that they would
`
` be aware of techniques to ameliorate the
`
` effect of charge injection switch capacitor
`
` circuits?
`
`TransPerfect Legal Solutions
`212-400-8845 - Depo@TransPerfect.com
`
`
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` A. Yeah, again, I think that they
`
` will be aware of techniques to address
`
` charge injection in switch capacitor
`
` circuits.
`
` Q. Would that likewise have been
`
` true in the 2002-2003 time frame?
`
` A. So I joined Columbia in 2002. I
`
` mainly taught undergraduate courses at the
`
` time, which this is a more advanced topic
`
` that would not occur in those courses
`
` typically.
`
` But generally master students
`
` with a strong -- with a strong focus or
`
` with a focus on analog circuit design
`
` dur
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