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Message: DECLARATION OF THOMAS GAFFORD (Expert for the defense)

If you read on from line 22 through 25, Gafford in 25 uses an example. In Despains supplemental doc. at 168 he refutes Gaffords claims as follows.

168. Defendants make statements about
Magar in their 336 Brief that are inaccurate<?XML:NAMESPACE PREFIX = O />



 

and misleading. Specifically, Defendants
claim that the crystal in Magar "serves as a reference



 

signal for the clock generator to lock onto.
See Gafford Decl. ¶ 25." Defendants' 336 Brief at 7



 

(emphasis added). Yet, a "reference
signal" and the concept of "locking" are specific technical



 

terms with specific meanings, and have
nothing at all to do with the clock generator and external



 

crystal of Magar. For example, in my
original declaration, I explained how a DLL delay-"locks"



 

an internal clock signal onto an external
"reference signal" using offsetting delay. Despain ¶ 51.



 

This locking typically involves the use of
a comparator, which is a circuit element that receives



 

two different inputs (like a reference
signal and a second signal), determines the difference



 

between their values, and outputs that
difference as a signal. This output signal of the



 

comparator can be used to do different
things, like to determine an offsetting delay in



 

conjunction with a DLL. The output signal
of the comparator can also be used in conjunction



 

with a feedback loop to adjust the second
signal until it is close in value in frequency or phase



 

(e.g.) to the reference signal,
thereby frequency- or phase-locking the two signals. The key point



 

is that none of this functionality is
taught in Magar. Tellingly, Mr. Gafford agrees, as he never



 

describes Magar as teaching a reference
signal or locking functionality, contrary to Defendants'



 

cite of his declaration for this
proposition. Instead, Mr. Gafford merely notes that the external



 

crystal of Magar "controls" the
frequency of the clock generator, and is therefore the "dominant



 

influence" on the frequency of the
clock generator. Gafford ¶ 25.



 

169. Defendants similarly claim that the
applicants distinguished over prior art chips in



 

which an off-chip crystal is used as a
"reference signal" for the on-chip clock circuitry.



 

Defendants' 336 Brief at 12-13 (emphasis
added). They quote applicants' attorney's statements



 

referring to the Edwards patent, discussed
above, as well as two additional references, Palmer



 

and Pohlman et al. See Amd. <?XML:NAMESPACE PREFIX = ST1 />7/3/97 at 4, Ex. 8. But as described above,
Edwards does not teach



 

an oscillator of any kind, and the
applicants' attorney described the teachings of the other two



 

 



 

- 4 -



 

references as "systems [that] operate
at a frequency determined by the external crystal," i.e.,



 

conventional crystal oscillators. Id.; Defendants' 336 Brief at 12. Because these references



 

disclose traditional crystal oscillators,
they are no different in this regard than Magar, and in no



 

way teach a reference signal, second
signal, comparator, or delay / frequency / phase locking



 

functionality.

http://www.agoracom.com/ir/patriot/message/548931

 

 

 

 

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