As to the formulae cited by HTC, they merely show how the ring oscillator uses the external crystal clock as a reference, not how the ring oscillator actually generates the clock signal. HTC’s own witness, Mr. Fichter, testified that the external crystal clock in the HTC phones serves merely as a reference signal. Dena confirmed that this crystal functions as a reference for the Qualcomm chips used in the HTC phones. Dr. Haroun, a corporate representative from Texas Instruments, also confirmed that the external crystal clock functions as a reference for the TI chips used in the HTC phones. Because the external crystal serves merely as a reference, if that crystal is disconnected, the ring oscilator will still be able to generate a clock signal. HTC's focus on the formulae therefore ignores the fact that differently binned chips - even if they have the same design - are set to run at different frequencies and sold at different prices.

In sum, substantial evidence supports the jury's infringement verdict.