selective interface circuit for data transmission a helpful way to think about single ended and differential interfaces your honour's in the contrast between them is a bicycle in a race car single ended like a bicycle is slow but cheap differential like a race car is fast but expensive and essence samsung argues that combining a bicycle in a race car women obvious because one can do it with the proper question is whether a skilled carson would be motivated to do so and the answer is no samsung's three motivation theories are cost performance and versatility if you look at cost they argue that the prior failed to show that using a slip of the interface would be cheaper than using the cheaper simpler bicycle the single ended without such evidence the board cannot rely on cost as a motivation to use the more expensive variety of needs versus the cost of multiple different circuits to serve the variety of me so the fact that one is cheaper than the other doesn't account for the fact that you may need lots of single it's well actually your honor if  look at you mean a and that united your patent you need is one of the prior primary references the column one that samsung relies on for that cost her miss speaks to the fact that the main cost issue relates to the amount of pins that are used to connect the sensor to the processor who equate the cost in that and the number of pins it goes up the bigger the chip area the higher the cost that is sam sloan's motivation theory on cost but all the evidence points to is using the cheaper bicycle using the single end interface which both parties agree provides the minimal amount of pins seems on its own reading says that you can transmit data using a single pin and you who are single and interface and it was samsung's burn to right yes your honor but the but the idea of this pin count issue on cost is true is intrinsically true for all sensors and so there's no discussion in the secondary references of rowing to shiva that any sort of increasing cost made it and sears showed how to do that so that you had the choice between the single do and that that would be the motivation to combine so that you would have the ability to do the things that what's what's wrong with what i said so both the board and samsung their motivation there is focused solely on the design needs of the media in sears every single site to motivation refers to motivations coming it's wrong as it is a technical matter again this is why speculation on the board is so harmful here because there's nothing in the evidence that shows that the type that's abating a factual finding before right where you know you are but the yes your honor you're correct but if we look at what's actually in the art you mean it in sears already provide systems that operate there's nothing in the teachings that show that the addition of the secondary references interfaces provides a net benefit and those are those are the image sensor and that's what the second a reference is teach ok so what the board said if i understand correctly is that it would have been obvious to combine one of those two approaches with the primary references in order to offer this fast money from samsung experts to support that conclusion even if you submitted alternative evidence how do how do we get around the fact that the board made that specific finding of fact the reason is ar that there is a tension between the benefits of saving on cost on one on the one hand versus the benefits of versatility on the other but samsung but this show is why versatility cannot be a motivation because sa economically to use these more expensive selective interface circuits there is no just occasion for using the these based on personality that's assuming that that things like increased compatibility versus versatility and throughput are not intrinsically valuable if they might also increase cost to some extent i mean sometimes if you get better performance you don't mind if there's an increase in  unwanted cost and complexity to the system that's exactly what's going on here have no hope it's not what's going on here it's not wanted versatility it won't get so and that brings me to the what i freely did to your honor in dressing the actual merits  versatility that you needed desires is moving i'm migrating all of these different functionalities for video processing and putting those onto a single chip that sort of versatility doesn't relate at all to interface circuits are on or for how the data gets from the  interest fear of the two nine zero parent there's nothing in the record either from make it as arguments by dr baker or the actual references that shows that there is a desire or market pressure to have these dr baker did in his analysis will look at each one of these motivations in a in a in a in a nutshell in talks about the need to balance these but doesn't explain how this balance would provide a net benefit over the prior versatility came from this combination so cost isn't the only factor so why why is that testimony so wrong that we should have to say that  performance provided by you by including the sort of double doubling up of a single and interface as well as a as a differential interface there's nothing that shows that the printer references cannot use a simply a purely single it interface so mr dr baker's of some analysis of balancing is fundamentally flawed from the onset and there's nothing that accepts that with any sort of cost analysis that compares the single we pleased the court the board here found four separate combinations render claim ten obvious this court only needs to find one of those combinations supported by substantial evidence to affirm the board's decision i want to take a step back for a moment because it's important to put claim one into perspective to correct something that counsel stated at the beginning of his argument he stated that it was the inventors of the two ninety patent that first came up with and recognized the benefits of a selectable combined interface interface with a single ended and differential signal path that's incorrect row shiba disclose exactly that that's what claim one of the three ninety patent is all about a combined selectable single ended and differential interface the board found that claim and they did not appeal claim one that forgot to ask about that reference to jurisdictional questions but nobody's appealed claim one right that's that's correct it was in their notice is not before it was painted interface a claim one and simply use it to connect an image sensor and image processor that's it if you look at our brief on page fifteen we show that the vast majority of the limitations of claim ten overlap identically with claim one the only new limitations are sensor and a process the board found it would be obvious with four separate combinations to take the row interfaces and use them in either the unita were sears imaging systems and that is what's at issue here is whether or not there was a motivation to make those four separate combination combination to deal with sears says we want a system that has high throughput minimal cost what dr baker said and what the board it's high throughput because it has a differential interface so that the quote that i referred back to that the board said is that dr baker talked about this combination i think it was and as having the dr baker said it's the best combination of throughput versatility and cost so he didn't necessarily say it was going to overall make the cost less but he was  you get the benefits without a lot of cost base as i read it that's that's correct there's a balancing here of all of these factors versatility was something that was specifically called out by the you need a rest would you agree with your friend on the other side that it doesn't necessarily have an absolute reduction we believe it does because you're getting a highly versatile interface because it's compatible with both single ended and differential but you're getting a lower cost interface because you're combining those single ended and differential interfaces into one circuit otherwise if you had separate interfaces a separate single ended separate differential you would have at least three possibly four or five pins by combining them you're down to two you're down to two which saves one count it saves cost is saves package size it changed chip size which are all item on a circuit or on a chip if you have to have three four or five pins the chip has to be bigger the package size has to be bigger by eliminating a pin it doesn't sound like a lot but it is significant because the chip the up pin takes up so much sides within the chip so going from three to two allows you to shrink that chip shrink the package size and save pos save manufacturing cost that was the the beauty of roan to sheeba by combining the single lead in differential in a women aiding minimizing the pin count you also got the versatility and high performance that you need or want you need a says give me high performance give me versatility your meter says we want to be able to communicate singleminded signals we want to be able to communicate differential signals if you have separate single ended separate differential interfaces that's going to cost money it's going to be bigger it's going to be more pins if you just have a single added like council was suggesting you're not going to get high performance single and it is a bicycle it's a low differential is fast it's like a a jet engine by having both the bicycle and the jenin in the same circuit you're getting versatility you're getting performance while at the same time you're getting a cheaper smaller less pin interface that's the balancing that dr baker did and i could direct your attention to a p x thirty eight thirty seven paragraph one want a circuit that has a reduced number of pins but at the same time it wants high bursa to woody and high performance what he says and what the board agreed with is up by balancing all these various needs that would be a one and combining them at the pins and you're increasing compatibility because you're going to be able to use single handed signals as well as differential signals which your response to your friends argument on the other side that there was  double ration for example a p p x seventy nine which is the petition the last paragraph your honour's about halfway down a procedure also would have understood that even though the industry in april ninety nine was strength not core differential interfaces the industry also placed importance on the option for single  interface to shore compatibility with existing devices that use single letter interfaces the industry demands to support both single ended and differential interfaces while minimizing  substitution would have been obvious to try and would have been a simple design choice driven by market demands that would lead to predictable results would a reasonable expectation of success so the record in these are just two examples of where dr baker and samsung pointed to market pressures pointed to design needs i could point you to others locations a p x nine  one nine zero two five have similar statements about market demand in industry demands and market pressures and finally i believe also in a p p s thirty eight forty one there's additional discussion there so i just pointed you to a few but there are others within the record which show in support that one other statement that was made by my colleague here that i have to address more more thoroughly was this notion of only a single entered interface could have been used and that would have been a lower  cost and again certainly back to my point earlier just using a single in an interface wilks at cost in isolation without considering all the other desires and demands that you need to end series we're looking for you can't just look at cost alone as judge malley pointed out our expert our petition talks about looking at all of these factors looking at it holistically balancing all of them and when you look at them as a whole just using a purely single ended interface would not meet any of the other goals it's not the ideal interface to be used for you need it and sears is no motivation to use yours my friend focuses on performance and throughput from sears so that's where i'd like to start our discussion here there is no performance gain from using ac it's like an interface circuit over using standard circuits because a differential interface provides the same performance as a single as a as a dual use interface so the premise that there was a trend in the art toward higher performance doesn't get us to a motivation if there's a higher for higher performance  use a standard off the shelf interface the differential interface so that it's an idea that there are market trends and the art does not support samsung's position the two nine zero patent like many inventions novel because it's counter intuitive counter to tip to use a selectable interface and these sort of see my sensors because the prior art focused on when you needed performance you used a differential interface but those have higher costs than a single end interface the two nine zero mentors are the first to recognize that this counter intuitive combination of a c must sensor with a slight to interface provides a justifiable benefit all the evidence that the the board seems on point to look at these naked ideas of cost performance and versatility they don't look at them together and actually show that the added benefit