168. Defendants make statements about
Magar in their 336 Brief that are inaccurate<?XML:NAMESPACE PREFIX = O />

and misleading. Specifically, Defendants
claim that the crystal in Magar "serves as a reference

signal for the clock generator to lock onto.
See Gafford Decl. ¶ 25." Defendants' 336 Brief at 7

(emphasis added). Yet, a "reference
signal" and the concept of "locking" are specific technical

terms with specific meanings, and have
nothing at all to do with the clock generator and external

crystal of Magar. For example, in my
original declaration, I explained how a DLL delay-"locks"

an internal clock signal onto an external
"reference signal" using offsetting delay. Despain ¶ 51.