The counter argument for that could be - since the crystal clock is not on the same substrate in this case, it's varying due to the PVT is not closely related to the varying of ring oscillator.

By talking about "de minimus", the defendant layers were imply that it is the quantity that matters, not the quality. Their persuasion is that the infringment is too small (too short in term of time) so the court should ignor it. I hope our lawyers can use precedent cases decisions to make it in our favor.

In addition to "dead zone" in between the frequency control by the PLL/crystal clock arrangement, I have been wondering another instance that maybe harder for defendant lawyers. If we just think about the power on moment when the power is supplied to both the PLL (with ring oscillator) and crystal clock. I don't think the PLL has a way to hold on the voltage for the ring oscillator until the slower crystal clock (100 times slower) send the control signal. If this is true, then the ring oscillator will be running as if this is in a "dead zone" moment; the clock rate will be varying purely by PVT. Secondly, from what I have read so far, to control of the clocking rate of oscillator, the PLL/crystal clock arrangement is running in a passive fashion - it will change the voltage supplied to ring oscillator when the ring oscillator is running out of either the lower freqency boundary or the upper boundary. So at the startup, the ring oscillator has to oscillate first so that its freqency can be sensed by PLL/crystal clock arrangement. And the time needed for this should be at lease 99 times the cycle time of the crystal clock. If this is true, can defendant lawyers still bring the "de minimus" argument?

I'm not a EE. Just got very curious about all these legal fiasco of PTSC.