In Dr. Mihran's declaration, he argues flash memory in the patent claims is used as a replacement for RAM (which he thinks of as main memory) to process the received audio signal. He writes over 34 paragraphs using terms like primary memory, primary storage, EEPROM, NOR and NAND. None of these terms are found anywhere in the Patents-In-Suit.

Flash memory as described in the Patents-In-Suit is used to store the data after it has been processed; not during the processing of the data as the memory circuitry does. Remember Dr. Mihran testified during the Markman hearing that he believed the Flashback had DRAM based on the pictures of the inside. I believe this DRAM is the memory circuitry (24) in Fig. 1.