BY MR. JAMESON:
Q The question is, did you have an understanding as to what
the product was that is referenced at figure 3 on the column 3
of the '774 patent?
A Yes, I did.
Q Okay.
And at the time that that was written, what was your
understanding as to what the product was?
A Well, it's actually --
MR. KEVILLE: Your Honor, now I make the same
objection again.
THE COURT: All right. I'm going to overrule the
objection. This witness can testify as to what he thought the
product would be. That is not necessarily what the product
turned out to be. It is not necessarily what the product is.
This is simply his knowledge at the time that this patent came
into effect. That's all.
THE WITNESS: If you look at figure 3 on page 5, that
is the product.
BY MR. JAMESON:
Q And what product do you believe that this --
A That's the Flashback. I mean, if you look at -- pop the
lid off of one today and look at it, that's it.
Exhibit 1, Mr. Norris.
A Yes.
Q And let me know when you're there.
A I'm there.
Q Do you see the reference to CODEC 42 and DSP 41?
A Yes.
Q At the time that this application was filed, did you have
an understanding as to what a DSP was?
A Yes.
Q And what was your understanding as to what a DSP was?
A It's a digital signal processor.
Q And did you have an understanding as to what a CODEC was?
A Oh, yes.
Q And what was a CODEC?
A A CODEC can be used for a lot of things. In the case of
this, as you can see, it is positioned directly after the
microphone picks up the analog signal of a speaker, and it
converts it from analog to digital to then be sent into the
digital signal processor.
Q Now, in the course of the signal being processed from
analog to digital, did you have an understanding as to whether
the CODEC and/or the DSP, the digital signal processor, whether
or not it used any form of memory?
A Yes. You can't have a digital signal processor without
some RAM to perform the functions.
Q And can you explain why that is your understanding?
A Well, the processor is composed of a bunch of physical
components. Mostly transistors, diode resistors, capacitors,
and they're arranged in such a way to accept memory.
Theyinclude memory. And the memory's like a blank slate. And what
you want to accomplish through using a DSP is written into it;
that is, into RAM, and stored to perform those functions that
are specific to whatever the product might be.
Very quickly, let me just add, the CODEC converted the
analog to digital in this case. The DSP we primarily used for
compressing that digital information to save space.
Q And in figure 2, there is a reference to microprocessor 21.
A Yes.
Q What was your understanding as to the function or role of a
microprocessor in figure 2 at the time that this document --
A Microprocessor in this case performed virtually all the
higher functions. It was sort of the brain in the sense that
it controlled what the buttons did, what the lights did, when
you were recording or playing back, which direction data was
flowing back and forth through the DSP. As you look at the
arrows and you notice they go in both directions on the CODEC
and DSP. It also includes RAM.
Q And why, why does a microprocessor -- at least what is your
understanding as to why a microprocessor would need to rely on
the RAM?
A Well, again, your -- it needs to remember what its
functions are and what they're needed to be carry out -- it has
Q And let's turn to that, Mr. Norris. I see that at the top
right-hand corner of figure 2, there is a reference to program
ROM.
A Right.
Q And what was your understanding at the time that this was
created as to the purpose of program ROM?
A Well, ROM and RAM are a little different in that because of
the device uses batteries, and when you change the batteries,
the RAM goes dead. You need some permanent memory that tells
this device, when it fires back up, you know, what it does, how
it's to act.
Q And if you will turn back a page, Mr. Norris, to figure 1.
At the time that figure 1 was created, what was your
understanding as to what figure 1 was showing?
A It's really another way of expressing what we talked about
in figure 2. Pretty much the same thing.
