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Message: 123Mark's concerns are valid
We do know who the Respondents called to rebut Dr. O and at least the Texas Instruments' expert Baher Haroun if Dr. Haroun testified to the paper he wrote that reinforces our theory, Dr. O's theory, and the public documentation of Dr. Haroun. The Respondents called Dr. Subramanian, who gave the introduction to the Markman for the Respondents, and another Dr. for, I believe, Samsung if required. Technically speaking, the ring oscillator, at times, does not rely on the external crystal, and if you follow through with that logic it would infringe on the 336. The other side of the argument would be, I guess, since the ring oscillator is sometimes controlled, then the system can't function without the control and therefore it is an all or nothing proposition where the Judge will find in favor of the Big Companies. If he finds in favor of TPL/PTSC, then the Judge is finding the addtional structure (D) that Jim O argued as persausive. Otherwise, the "Entire ..." construction along with the system not being able to function without the external crystal, as far as I know and could be mistaken on this point, will torpedo the 336. Only Judge Gildea knows how he will rule. I believe final post hearing briefs are due at the end of June or July, can't recall.
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