<His past testimony does have a direct correlation to Barco's SJ motion.>

But is it really needed? I thought we just said what Moore said, and in more detail.

<It Is Highly Impractical To Establish Infringement Via The Reverse Engineering Method Suggested By Barco. Barco’s Motion posits that Defendants should have reverse engineered the various microprocessors2 at issue, without disclosing that it is highly impractical to delid a microprocessor and work down through multiple layers of differing materials on the chip to find ten to twenty transistors arranged as a ring oscillator, amidst the millions, or even as many as a billion, transistors on the chip. Declaration of Vojin Oklobdzija in Support of Defendants’ Opposition to Barco’s Motion for Summary Judgment (“Oklobdzija Decl.”), 61-64 (filed concurrently). Even with a road map from the chip designers it would be very difficult to find such a relatively small feature on the chip.>

Opty