Thanks for the Pacer. Just read it and I'm assuming others have already posted what I am about to (posting from phone so please excuse no carriage return formatting). The following excerpt from TPL's argument is the most important IMO. --- TPL’s theory of infringement relies on the fact that integrated circuits found in the accused products are fabricated using a semiconductor manufacturing process that results in integrated circuits or chips having certain characteristics or inherent properties. Both Chandra and the Oklobdzija Declaration evidence that under such manufacturing processes, the resulting integrated circuits will exhibit common operational characteristics well known to those skilled in the art. These characteristics include variations in the processing speed of on-chip components – e.g., transistors – due to operational temperature and voltage. Further, variations in processing speeds between individual chips cut from the same wafer will occur, which is commonly referred to as process or manufacturing variation. These inherent characteristics – i.e., variations in processing speed due to temperature, voltage and manufacturing process – are well known to those skilled in the art, as clearly evidenced by citations to Chandra and the Oklobdzija Declaration made in the ICs. And, as Barco is well aware, TPL discloses as part of its infringement contentions these inherent characteristics are found in all integrated circuits, including those present in the accused products. --- IMO the worst we can fair with the NDoC is to have the ring oscillator be narrowed to being controlled by manufacturing process, voltage and temperature. Guess what, folks? The vast majority of chips operate as such. The best we can do is have the ring oscillator construed as it was in Texas. Both worst and best case scenarios are virtually identical IMO. Watch me be wrong about all of this. Tomorrow I will be discussing Talbot and the VCO with my friend. Will post about it hopefully tomorrow and I apologize for the delay for anyone who cares.