Thank you for posting these documents.

From TI's own tech paper (Baher Haroun is a co-author) -

26.10 A PVT Tolerant 0.18MHz to 600MHz

Self-Calibrated Digital PLL in 90nm

CMOS Process

Jerry (Heng-Chih) Lin, Baher Haroun, Tim Foo, Jin-Sheng Wang,

Bob Helmick, Scott Randall, Terry Mayhugh, Chris Barr, Jeff Kirkpatrick

Texas Instruments, Dallas, TX

From our lawyer's declaration -

3. Following the close of fact discovery in both the ITC and district court actions,

Defendants independently discovered in March 2013 that current TI employee, Baher Haroun, was

involved in the development of TI’s OMAP processor.

I certify under penalty of perjury under the laws of the United States of America that the

foregoing is true and correct. Executed on September 17, 2013 in Menlo Park, California.

/s/ Philip W. Marsh

Philip W. Marsh

Things are getting more interesting day by day now. I'm not a EE, but the variation in voltage and temperature can be huge in real world situation (indicated by TI paper). It's rediculous for defendant lawyers to bring the "de minimus" argument against us.