External Crystal Unecessary Per Dr. Oklobdzija
posted on
May 08, 2013 02:12AM
Excerpt from Dr. Oklobdzija's Supplemental Report......See below....Is this helpful?
However, Dr. Oklobdzija pointed out that the ALJ’s omission of Complainants’ proposed phrase “required to maintain an oscillating output” did, in fact, lead to a substantive difference: The important point is that a ring oscillator can be used as both a clock and as an oscillator, because it constantly oscillates as a direct result of having at least three inversions arranged in a loop. This configuration allows a ring oscillator to generate an oscillating clock signal that can be used to pace functions in a microprocessor chip. As I explained in my earlier declaration dated September 14, 2012, a ring oscillator generates a continuous periodic output as a direct result of the fact that it has an odd number of inversions arranged in a loop or ring. See, e.g., 9/14/12 Oklobdzija Decl., ¶ 7. Each inverter simply changes its input signal from a 0 to a 1, or from a 1 to a 0. Thus, once the oscillator is started, it will continue indefinitely as long as power is provided to the inverters. As I also explained in my earlier declaration, this automatically generates an oscillating output that can be used as a clock signal. However, a ring oscillator must have a multiple odd number of inverters ( i.e., three or more). It will not oscillate with a single inverter, and the output of a ring with an even number of inverters will not oscillate, because it will latch a signal to the same value ( e.g., either 1 or 0, but not oscillating). Id. at ¶ 7. As is clear from this example, neither a control signal nor an external crystal is necessary for a ring oscillator to generate a clock signal. Oklobdzija Supp. Report, ¶¶ 10, 11 (emphasis in original). Dr. Oklobdzija went on to explain that unlike ring oscillators, “other types of oscillators ( e.g., LC oscillators and relaxation oscillators) oscillate based on very different principles. See, e.g., 9/14/12 Oklobdzija Decl., ¶¶ 8- 11.” Oklobdzija Supp. Report, ¶ 12. This is a critical distinction, because Respondents Acer and HTC had argued in a parallel district court action in Northern California that the Talbot prior art reference disclosed a ring oscillator, even though it was clearly a relaxation oscillator. See, generally , 9/14/12 Oklobdzija Decl. Finally, Dr. Oklobdzija explained that the ALJ’s constructions of the “entire ring oscillator . . .” terms were substantively different to the extent they incorporated the term “ring osciallator.”