Re: NDoC Pacer: Declaration in Opposition to ACER/HTC MSJ
posted on
Sep 06, 2013 12:46AM
Well, if anyone cares on the eve of the ITC initial determination what this case boils down to definitively, without speculation, you should read on. It comes down to the range in which the VCO operates in a phase locked loop (PLL). Yes, we've spoken about this before. The range is called the "dead band" where the PLL is not controlling the VCO and the VCO is running freely. We've talked about that also, not the specific term but the principle. The issue now becomes whether or not the variation in the dead band is statistically significant enough to proove infringment. The big companies argue the range is de minimis, or so insignificant that there is no variation due to process, temperature and voltage. We argue the variation is statistically significant due to the dead band range. Taking into consideration the easiest way to govern the spead of a chip is to use a ring oscillator that self governs because it is made on the same silicon and due to the dead band operational range, I'm hoping our argument is enough. Why not just grant the MSJ against us? So much easier to avoid the political pressure and we are small fish who really don't have the resources to fight these monstrous legal firms. Tomorrow we will hopefully know at the ITC. Lastly, reading the expert witnesses for the big companies, especially Dr. Wolfe, is extremely annoying as they are extremely avoidant. Hopefully the ALJ will see through their obfuscation.