1. Explain the functions and the specific sequence of states used by the accused product’s memory controller (and/or microprocessor to the extent it is responsible for memory management) to store processed digital data in embedded flash memories and/or removable flash memory cards.

2. Explain the accused product’s file system (or file system functions) including specifically, the sequence of writing a first data file (example: video and/or audio clip) onto flash memory (embedded and/or removable) followed by writing a second data file (example: video and/or audio clip) onto flash memory (embedded and/or removable).

3. Identify or provide a list of all instructions/communications that are sent between the accused product’s host memory controller and the controller for the removable flash memory.

4. Provide state diagrams that explain the transfer of data from the host memory controller to removable flash memory cards or embedded flash memory.

5. If the accused product has any fixed maximum file size, explain how that limitation is implemented in the host memory controller.

6. If the accused product incorporates any third party drivers for implementing the transfer of data and/or instructions from the host memory controller to embedded flash and/or a removable flash memory card, identify the source of those drivers.

7. If the accused device uses a host memory controller that is provided by a third party, provide any product requirement document(s) (or similar documents) that define the specification to which the memory controller and/or memory controller drivers or software must be designed.

8. Explain how and when the accused product determines whether:
a) a removable flash memory is entirely inoperable;
b) a removable flash memory block is defective; and
c) multiple blocks of a removable flash memory are defective.
With respect to when the determination occurs, does it occur when the accused product is powered on; when batteries are inserted; when recorded data is passed to host controller memory buffer; when the removable flash memory is being accessed; and/or pursuant to the occurrence of some other event?

9. Explain how the accused product responds to a determination that:
a) a removable flash memory is entirely inoperable;
b) a removable flash memory block is defective; and
c) multiple blocks of a removable flash memory are defective.

10. Confirm whether the host controller is informed that the flash memory (embedded or removable) contains a defective block(s).

11. To the extent you believe the above topics collectively do not encompass wear leveling techniques, describe any such techniques implemented at the direction of the host memory controller.