The Barco Projector RLM R6+ and SM R12+ contain a Texas Instruments DDP1011 microprocessor.12 The DDP1011 microprocessor is part of the Texas Instruments DLP line of processors, and as with the DDP3020 microprocessor, the DDP1011 microprocessor also has an on-chip ring oscillator variable speed clock. Oklobdzija Decl., 31. Additionally, TPL’s Infringement Contentions included a service manual for a BenQ LDP 6100 projector, which uses a DDP1000 microprocessor. Id., Ex. 15. The DDP1000 is within the DLP line of processors, and the BenQ manual includes several schematics of the DDP1000 chip. Id. It is customary that products in the same family have the same numbering designation where the newer product has a higher number. Id. In this case, Dr. Oklobdzija has strong reason to believe that the DDP1011 has the same structure as the DDP1000 except for possibly minor functional enhancements unrelated to clock generation. Id. The schematic of the DDP1000 chip in the BenQ manual shows the presence of the oscillator by the pin G4 labeled “crystalen,” whose purpose is to enable the external crystal oscillator to create a reference signal. Id., 32. This reference is normally used as one of the inputs to a PLL, as explained above, which would contain a VCO most commonly implemented using a variable speed on-chip ring oscillator. Id., 32-33. 11 This will be further confirmed by discovery from non-party Texas Instruments. Mar Decl., 10, 11. 12 See, e.g., Product Report for RLM R6+, 3, 4, 8 (Barco Mot., Ex. K); Product Report for SLM R12+, 3, 4, 8 (Barco Mot., Ex. H).

: Texas Instruments, AMCC, LSI Corporation, STMicroelectronics, and Xilinx. Oklobdzija Decl., ¶13. each of the six microprocessors at issue here. Defendants have undertaken that task by first seeking discovery from Barco, and now moving to targeted subpoenas for documents, and eventually depositions, from the chip suppliers themselves. Mar Decl., ¶¶ 3–8, 10–12.

d. TPL Has Subpoenaed Third-Party Chip Suppliers TPL is also awaiting documents subpoenaed from chip suppliers that are essential to adjudicating the Motion. The subpoenas require Applied Micro Circuits, LSI Corporation, Texas Instruments and Xilinx to produce documents relevant to the operation of the accused products. Each company provides chips used in Barco’s products, and the subpoenas require the production of, for example, (1) “block