Apple Inc. v. Samsung Electronics Co. Ltd. et al

Filing 1001

Declaration of Woodward Yang, Ph.D. in Support of #1005 Samsung's Opposition to Apple's Motion for Summary Judgment of Non-Infringement of U.S. Patent No. 7,362,867 and Invalidity of U.S. Patent Nos. 7,456,893 and 7,577,460 filed by Samsung Electronics America, Inc.. (Maroulis, Victoria) (Filed on 5/31/2012) Modified on 6/4/2012 linking entry to document #1005 (dhm, COURT STAFF).

1 QUINN EMANUEL URQUHART & SULLIVAN, LLP
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
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
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
Kevin P.B. Johnson (Bar No. 177129)

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
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
Michael T. Zeller (Bar No. 196417)
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 Telephone: [phone]
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
Attorneys for SAMSUNG ELECTRONICS CO., LTD.,
 SAMSUNG ELECTRONICS AMERICA, INC., and
SAMSUNG TELECOMMUNICATIONS AMERICA, LLC



UNITED STATES DISTRICT COURT





NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION
APPLE INC., a California corporation,
Plaintiff,


vs.



SAMSUNG ELECTRONICS CO., LTD., a
 Korean business entity; SAMSUNG
 ELECTRONICS AMERICA, INC., a New
York corporation; SAMSUNG
 TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company,

Defendants.


CASE NO. 11-cv-01846-LHK
DECLARATION OF WOODWARD
YANG, PH.D. IN SUPPORT OF
SAMSUNG’S OPPOSITION TO APPLE’S
MOTION FOR SUMMARY JUDGMENT
OF NON-INFRINGEMENT OF U.S.
PATENT NO. 7,362,867 AND
INVALIDITY OF U.S. PATENT NOS.
7,456,893 AND 7,577,460



, PH.

Case No. 11-cv-01846-LHK
DECLARATION OF WOODWARD YANG, PH.D.

DECLARATION OF WOODWARD YANG, PH.D.

1
2

I, Woodward Yang, declare:

3

1.

I have personal knowledge of the facts set forth herein, and am competent to testify

4 to the same.
5

2.

I submit this declaration in support of Samsung's Opposition to Apple's Motion for

6 Summary Judgment of Non-Infringement of U.S. Patent No. 7,362,867 ("the '867 patent") and
7 Invalidity of U.S. Patent Nos. 7,456,893 ("the '893 patent") and 7,577,460 ("the '460 patent"). If
8 asked at hearings or trial, I am prepared to testify regarding the matters I discuss in this
9 declaration.
10 I.

BACKGROUND

11

3.

I am presently the Gordon McKay Professor of Electrical Engineering and

12 Computer Science in the School of Engineering and Applied Science at Harvard University, where
13 I have taught and pursued research endeavors since 1990. I have taught classes related generally
14 to the design and analysis of microelectronic circuits and Very Large Scale Integration ("VLSI")
15 systems: the process of creating integrated circuits by combining thousands of transistors into a
16 single chip. VLSI began in the 1970s when complex semiconductor and communication
17 technologies were being developed. The microprocessors typically used in smartphones are an
18 example of a VLSI device. I have also taught graduate and undergraduate level courses in
19 computer architecture, computing hardware, digital logic design, mixed signal circuit design,
20 circuit theory, and engineering design.

My research pursuits have been directed to the

21 development of advanced computing and memory systems for high performance image processing
22 and computer vision applications, data encryption, error correcting codes, and integrated sensor
23 and computing systems.
24

4.

Since 2008, I have also served as the Harvard Business School ("HBS") University

25 Fellow and teach courses at HBS as a Visiting Professor. In this capacity, I have conducted
26 research and taught business school courses on the commercialization of new technologies,
27 technological innovation, and industry architecture.
28
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Case No. 11-cv-01846-LHK
DECLARATION OF WOODWARD YANG, PH.D.

1

5.

I have over 25 years of experience in the field of electrical engineering and

2 computer science, during which time I have published many peer-reviewed papers in the field and
3 have been extensively involved in the development and commercialization of several important
4 mobile phone technologies. These technologies, which are now common in mobile phones,
5 include CMOS image sensors and pseudo-SRAM. Over the course of my career, I have been a
6 named inventor on at least 9 patents.
7

6.

I graduated with a Bachelor of Science degree in Electrical Engineering and

8 Computer Science from the University of California, Berkeley in 1984. During my undergraduate
9 studies, I also pursued research in the university's Electronic Research Laboratory, where I
10 researched the measurement and analysis of hot electron degradation in MOS ("metal oxide
11 semiconductor") transistors.
12

7.

I received a Master's of Science degree in Electrical Engineering and Computer

13 Science from the Massachusetts Institute of Technology in 1987. While pursuing my Masters
14 degree, I served as a research assistant in the Microsystems Technology Laboratory, where I
15 assisted in developing and characterizing low pressure ammonia and oxygen annealing processes
16 that improve the reliability of scaled MOS transistors.
17

8.

I received my Ph.D. in Electrical Engineering and Computer Science from the

18 Massachusetts Institute of Technology in 1990. My doctoral thesis concerned "The Architecture
19 and Design of CCD Processors for Computer Vision." While pursuing my doctorate, I served as
20 research assistant in the university's Artificial Intelligence Laboratory, where I contributed to the
21 development, design, and implementation of analog VLSI hardware in computer vision systems.
22

9.

From approximately 1990-2000, I taught and pursued advanced research at Harvard

23 in the general areas of high performance VLSI computing systems and computer architecture, and
24 also worked as a consultant in the area of advanced image sensors based on both CCD and CMOS
25 technology. The culmination of a large portion of this work was the successful commercialization
26 of CMOS image sensors into miniature cameras that were integrated into computer and mobile
27 phones.
28
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Case No. 11-cv-01846-LHK
DECLARATION OF WOODWARD YANG, PH.D.

1

10.

In 2000, I founded a company called Silicon7. The company designed, developed,

2 manufactured, and marketed advanced memory components and systems for mobile
3 communication devices and platforms. These advanced memory components and systems were
4 optimized for the distinct requirements of mobile communication devices.
5

11.

Over the course of my career, I have received various honors and fellowships. In

6 1984, I received both the National Science Foundation Fellowship and Hertz Foundation
7 Fellowship. In 1992, I received both the Army Research Office Young Investigator Award and
8 the National Science Foundation Young Investigator Award. I have also served as an IEEE
9 Distinguished Lecturer in the areas of CMOS Image Sensors and High Performance VLSI
10 Systems.
11

12.

I have previously been qualified as an expert witness in the field of electrical

12 engineering and computer science in the matter of Certain Electronic Devices, Including Mobile
13 Phones, Portable Music Players, and Computers, ITC Investigation No. 337-TA-701.
14

13.

Attached as Appendix A to this report is my curriculum vitae, which contains a

15 complete listing of my education, my professional experience, the publications that I have
16 authored, and the cases in which I have testified as an expert at trial or in depositions during the
17 previous four years.
18 II.

OPINIONS

19

A.

U.S. Patent No. 7,456,893

14.

The '893 patent is directed to a method and apparatus for "bookmarking" an image

20
21
22
23
24
25
26
27

in a digital photo album. The claimed invention for controlling a digital image processing system
returns a user to the same bookmarked image in a digital image photo album even after capturing
new images. The invention marks a departure from the default mode on digital cameras practiced
in the art, which always returned a user to the last image captured upon returning to a digital photo
album. This default mode resulted in users losing their place in a digital image photo album,
forcing the user to tediously scroll back to their place in a digital image photo album. As
explained in the Background of the Invention: "…when a user temporarily switches from the

28
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Case No. 11-cv-01846-LHK
DECLARATION OF WOODWARD YANG, PH.D.

1 stored-image display mode to another operating mode (e.g., a photographing mode), the user has
2 to again sequentially display files that were already displayed to find his or her most recently
3 viewed stored image." The invention of the '893 patent was to enable the user of a camera-phone
4 to quickly and conveniently find "his or her most recently viewed stored image," even after
5 switching between the viewing and photographing modes.
6

15.

The asserted claims of the '893 patent are directed to an apparatus with a digital

7 bookmarking function: claims 10 and 12. In particular, this claimed apparatus must be a "digital
8 image processing apparatus," i.e., a device containing a digital camera. According to claim 10,
9 this device must include a digital camera, memory that stores digital images, and a display. The
10 device claimed in claim 10 must further include a controller that is used in camera mode to take
11 pictures and store them in memory and in display mode to view images which have been
12 previously photographed, captured, and/or stored.

Finally claim 10 requires that the device

13 switches back and forth between camera mode and display mode but displays the last viewed
14 image rather than the last captured image in the display mode.
15

16.

Claim 12 of the '893 patent, which is dependent on claim 10, requires that the

16 identifying step in claim 10 means setting the index value of the last image displayed in memory.
17

17.

I understand that Apple contends that claims 10 and 12 of the '893 patent are

18 invalid as indefinite. Specifically, I understand Apple to contend that independent claim 10 covers
19 both an apparatus and a method for using the apparatus and is therefore insolubly ambiguous.
20

18.

I disagree with Apple's contention. By its clear terms, claim 10 is directed to an

21 apparatus with a recited structure, including an "optical system," a "photoelectric conversion
22 module," a "recording medium," a "display screen," and a "controller." This apparatus performs a
23 specific function upon returning to a reproduction mode after capturing new photos in a
24 photographing mode: first displaying the last image displayed in the reproduction mode. Claim
25 10 is, therefore, directed to an apparatus capable of performing this recited function.
26

19.

I also understand that Apple contends that claim 10 requires user action to practice

27 the claim. In addition, I understand that Apple contends that I agree that claim 10 requires user
28 action to practice the claim.
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Case No. 11-cv-01846-LHK
DECLARATION OF WOODWARD YANG, PH.D.

1

20.

I disagree with Apple's contentions.

2 performing a mode-switching operation …."

Claim 10 states, in part, "upon a user

That phrase is immediately followed with a

3 description of what the apparatus's controller is to do if the user performs a mode-switching
4 operation, that is, if the user flips a switch. It is my understanding that this claim language is
5 describing how the apparatus is to function if the user flips a switch. This does not mean that the
6 claim requires the user to flip a switch (or to do anything, for that matter). Rather, it is simply
7 describing how the apparatus must function if the user does, in fact, flip a switch.
8

21.

I further understand that the sole basis for Apple's contention that I agree that claim

9 10 requires user action to practice the claim is the following testimony from my deposition:

11

Q. I'm asking is your understanding of this language, does the "wherein, upon a
user performing a mode switching operation," does that require some action by the
user?

12

MR. STRETCH: Same objection.

13

A. There's clearly the implication that the user is going to do – flip a switch, going
to switch something; and then it's describing – the remainder of that is describing
what that – what has – what the device has to do –

10

14
15

Q. Thank you.
16
17
18
19
20

A. – but that's initiated by the user.
(Yang Deposition Transcript, Stake Decl. Ex. 14 at 80:25-81:9.)
22.

I disagree with Apple's contention that my testimony requires user action to

practice the claim. Prior to the exchange that Apple cites to above, I had testified as follows:

22

Q. Would you agree with me that in claim 10, the last clause starts where –
"wherein, upon a user performing," that that – to practice the claim that's – the
language of that – of claim 10 requires the user to take some action?

23

MR. STRETCH: Objection. Calls for a legal conclusion.

24

A. Well, I'm not really a lawyer and I'm not that familiar with the law, but let me
try to describe it this way. It's like a switch. Mode switching is a switch. So you
flip a switch, and then it's describing how the device has – or the apparatus has to
operate or behave. So it's really talking about there's a switch; if you flip the
switch, this is what's going to happen. So I think it's an apparatus.

21

25
26
27

(Yang Deposition Transcript, Stake Decl. Ex. 14 at 80:2-21.)

28
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Case No. 11-cv-01846-LHK
DECLARATION OF WOODWARD YANG, PH.D.

1 This testimony, as well as the testimony that Apple cites, is consistent with my understanding that
2 the language of claim 10 is describing how the apparatus is to function if the user flips a switch. If
3 Apple is asserting that I testified that claim 10 requires user action, that it is incorrect and is taking
4 my testimony out of context.
5

23.

As a person of skill in the art, I readily understand the language of claims 10 and 12

6 of the '893 Patent. In addition, I readily understand the scope of claims 10 and 12. Because
7 claims 10 and 12 claim an apparatus and not any user action, it is my understanding that
8 infringement occurs when one creates an apparatus that meets all of the limitations in claims 10
9 and 12.
10

B.

U.S. Patent No. 7,577,460

11

24.

Claim 1 of the ‘460 patent is clear and unambiguous. Claim 1 is reproduced below,

12 with the claim’s steps labeled [a] to [e]:
13

1. A data transmitting method for a portable composite
communication terminal which functions as both a portable phone
and a camera, comprising the steps of:

14
15

[a] entering a first E-mail transmission sub-mode upon user request
for E-mail transmission while operating in a portable phone mode,
the first e-mail transmission sub-mode performing a portable phone
function;

16
17
18

[b] entering a second E-mail transmission sub-mode upon user
request for E-mail transmission while operating in a display submode, the second e-mail transmission sub-mode displaying an image
most recently captured in a camera mode;

19
20

[c] sequentially displaying other images stored in a memory through
the use of scroll keys;

21
22

[d] transmitting the address of the other party and a message
received through a user interface in the first E-mail transmission
sub-mode;

23
24

[e] and transmitting the address of the other party and the message
received through the user interface and the image displayed on the
display as an E-mail in the second E-mail transmission sub-mode.

25
26
27

25.

Claim 1 is directed to the performance of three core functions on a camera phone.

28 Specifically, steps [a] and [d] claim the transmission of an email displaying a message only (i.e.,
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Case No. 11-cv-01846-LHK
DECLARATION OF WOODWARD YANG, PH.D.

1 without any image). Steps [b] and [e] claim the transmission of an email displaying an image and
2 a message. Step [c] claims displaying images stored on the device in sequence.
3

26.

A user interface for entering an email address and a text message is also specified

4 in Claim 1. More specifically, claim 1 requires transmission of e-mail through two distinct
5 transmission "sub-modes":
6 transmission sub-mode."

a "first e-mail transmission sub-mode" and a "second e-mail
The device enters this first e-mail transmission sub-mode from a

7 "portable phone mode," in which phone calls may be placed or received. This first sub-mode
8 transmits text-only e-mail. The device enters the second e-mail transmission sub-mode from a
9 "display sub-mode," in which images stored on the phone may be reviewed. This second sub10 mode transmits e-mails enclosing a stored image and a text message. Claim 1 further requires that
11 the user can sequentially display images stored on the device through the use of scroll keys.
12

27.

The specification of the ‘460 patent teaches each of the three core functions

13 claimed by the claim 1. The specification discloses sequentially displaying photos stored on a
14 camera phone, stating: “Upon user pressing the volume up/down key 312 in a play sub-mode of
15 the camera mode, an image previous or next to a current image is displayed.”) (‘460 patent, col. 5:
16 9-12.) The specification further discloses that distinct e-mail functionalities are available when a
17 user requests to send an e-mail in “play sub-mode” (i.e., image review mode) rather than in
18 “portable phone mode” (i.e., phone standby mode):
19
20
21
22
23
24
25
26
27
28

Meanwhile, upon entry of the send key in step 908, the portable phone controller
32 determines whether there is any still image to be enclosed in the E-mail. If the
E-mail transmission sub-mode is selected in the play sub-mode of the camera
mode, this implies that image data to be enclosed in the E-mail exists. If the
image enclosure operation is implemented in the E-mail transmission sub-mode
selected in the portable phone mode, as in step 912, this implies that image data to
be enclosed in the E-mail exists. However, if only the E-mail transmission submode is selected in the portable phone mode, this implies that no image data
enclosed in the E-mail exists.
(‘460 patent, col. 12:30-41; see also col. 10:65-11:12; figs. 6, 9.) Specifically, the specification
teaches that the user can send an email with message only when the user requests to send an e-mail
in “portable phone mode.” (‘460 patent, col. 12:38-41 (“However, if only the E-mail transmission
sub-mode is selected in the portable phone mode, this implies that no image data enclosed in the
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Case No. 11-cv-01846-LHK
DECLARATION OF WOODWARD YANG, PH.D.

1 E-mail exists.”); Figs. 6, 9.) In contrast, the user can send an e-mail displaying an image and a
2 message by requesting e-mail transmission while reviewing images. (‘460 Patent, col. 11: 9-11
3 (“By selecting the E-mail transmission sub-mode in the play sub-mode, the user can transmit an E4 mail with a still image enclosed therein.”); Figs. 8, 9.) The specification teaches that this request
5 to send an e-mail in the play sub-mode “implies that image data to be enclosed in the E-mail
6 exists.” (‘460 patent, col. 12:33-35; figs. 8, 9.) Viewed in light of the specification, Figure 9 of
7 the patent illustrates that image enclosure results from requesting e-mail transmission in play sub8 mode:
9
10
11
12
13
14
15
16
17
18
19 (Fig. 9; col. 12:30-51 (discussion of labels 914-918).)
20

28.

The specification’s discussion of two distinct states on a camera phone with distinct

21 e-mail functionalities supports claim 1’s requirement of a “first E-mail transmission sub-mode”
22 and a “second E-mail transmission sub-mode.” As I explained in my expert report, a “mode” is a
23 “specific state of the device in which certain functions are available to the user,” while a “sub24 mode” is “another specific state in which another set of functions are available to the user upon
25 subselection from the current ‘mode.’” A camera phone with distinct states with distinct e-mail
26 functionalities, therefore, has a “first” and a “second E-mail transmission sub-mode.”
27

29.

The prosecution history of the ‘460 patent further confirms that claim 1 is directed

28 to the performance of three core functions on a camera phone. The ‘460 patent claims priority to
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Case No. 11-cv-01846-LHK
DECLARATION OF WOODWARD YANG, PH.D.

1 U.S. Application No. 09/540,830 (the “‘830 application”). Claim 20 of the ‘830 application was
2 similar to claim 1 but omitted “sequentially displaying other images stored in a memory through
3 the use of scroll keys” (step [c]). (Stake Decl. Ex. 4 at APLNDC-WH-A0000014309-10.)
4

30.

The Patent Office initially rejected claim 20 as obvious in view of the combination

5 of the Wagner, Suso, and Dawson patents, all U.S. patents. (Stake Decl. Ex. 5 at APLNDC-WH6 A0000014263.) The Patent Office asserted that the Wagner patent disclosed a device that:
7
8
9
10

[F]unctions as a portable phone comprising the steps of entering a first E-mail
transmission sub-mode upon user request for E-mail transmission while operating
in a portable phone mode, the first E-mail transmission sub-mode performing a
portable phone function, and transmitting the address of the other party and a
message received through a user interface in the first E-mail transmission submode.

11 (Id. at APLNDC-WH-A0000014263-64.) (emphasis added.) The Patent Office further asserted
12 that the Dawson patent disclosed an “e-mail system” having distinct e-mail transmission sub13 modes for sending text-only e-mails and for sending e-mails with an image and a message:
14
15
16
17

Dawson teaches an audio-visual e-mail system having a first E-mail transmission
mode for transmitting a text-only email message and a second E-mail
transmission sub-mode upon user request for E-mail transmission, wherein the
second E-mail sub-mode displays an image captured by a digital camera and
transmits the address of the other party and the message received through the
user interface and the image display on the display

18 (Id. at APLNDC-WH-A0000014264.) In its first Office Action, the Patent Office therefore readily
19 understood that claim 20 claimed sending separate emails through two distinct sub-modes.
20

31.

Samsung responded to the initial rejection of claim 20 by amending it to claim

21 “sequentially displaying other images stored in a memory through the use of scroll keys.” (Stake
22 Decl. Ex. 6 at APLNDC-WH-A0000014254.) Samsung contended that its amendment
23 distinguished claim 20 from the asserted patents. (Id. at APLNDC-WH-A0000014251.)
24

32.

In two subsequent Office Actions, the Patent Office rejected claim 20 over the

25 Harris, Hull, and Sugiyama patents. (Stake Decl. Ex. 7 at APLNDC-WH-A0000014238-39; Stake
26 Decl. Ex. 8 at APLNDC-WH-A0000014156-58.) The Patent Office contended that these
27 references, in combination, rendered claim 20 obvious by disclosing the three core functions of the
28 ‘460 patent. The Patent Office contended that the Harris patent disclosed a “portable phone and
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Case No. 11-cv-01846-LHK
DECLARATION OF WOODWARD YANG, PH.D.

1 camera” that sent text-only email, that the Hull patent disclosed sending e-mails with an image and
2 a message, and that the Sugiyama patent disclosed the use of scroll keys to sequentially display
3 images. (Id.)
4

33.

The Patent Office ultimately allowed claim 1 of the ‘460 patent to issue after

5 Samsung demonstrated that none of these three patents disclosed a device “capable of operating in
6 a first and a second E-mail transmission sub-mode.” (Stake Decl. Ex. 9 at APLNDC-WH7 A0000014122.) Samsung specifically contended that “[e]ach of the references can only operate in
8 one of the two modes, not both.” (Id.) The Patent Office issued no further anticipation or
9 obviousness rejections of pending claim 20 in either the ‘830 application or in Divisional
10 Application No. 11/493,754, from which the ‘460 patent issued on August 18, 2009.
11

34.

I disagree with Apple's contention that the '460 patent is invalid as indefinite. In its

12 Motion, Apple contends that claim 1 fails to clarify whether the claim requires: (a) "sending two
13 separate email messages from two separate email transmission sub-modes”; (b) "sending one
14 email message from the ‘first E-mail transmission sub-mode’ if the E-mail does not have an image
15 attachment and sending one email message from the ‘second E-mail transmission submode’ if the
16 email has an image attachment"; or (c) “sending one email message from the ‘second E-mail
17 transmission sub-mode’ only, whereby the email is created by transmitting the address of the other
18 party and a message received through a user interface in the ‘first E-mail transmission sub-mode’
19 to the ‘second E-mail transmission sub-mode.’”

To the extent I understand these alternate

20 interpretations, I disagree that claim 1 is ambiguous. The specification and figures of the ‘460
21 patent only supports Apple’s first interpretation of claim 1. As I explained in my expert report,
22 claim 1 of the '460 patent is infringed if a camera phone performs—in any sequence—three
23 claimed functions: (1) transmitting text-only e-mails in a first e-mail transmission sub-mode,
24 entered through a portable phone mode; (2) transmitting e-mails enclosing both an image and a
25 textual message in a second e-mail transmission sub-mode, entered through a display sub-mode;
26 and (3) sequentially displaying images stored on the phone through the use of scroll keys.
27 Notably, Apple’s second and third interpretations of claim 1 do not require performance of all
28 claimed functions, and are, therefore, incorrect.
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Case No. 11-cv-01846-LHK
DECLARATION OF WOODWARD YANG, PH.D.

APPENDIX A

Expert Report of Woodward Yang
Appendix A

Woodward Yang
Home Address
14 Fox Run Lane
Lexington, MA 02420
[phone]
[phone] cell

Work Address
Maxwell-Dworkin 325
School of Engineering and Applied Sciences
Harvard University
Cambridge, MA 02138
Tel: [phone]
Fax: [phone]

Education:
Massachusetts Institute of Technology
August 1990
Ph.D. in Electrical Engineering and Computer Science
Thesis: ``The Architecture and Design of CCD Processors for Computer Vision''
Massachusetts Institute of Technology
S.M. in Electrical Engineering and Computer Science
Thesis: ``Low Pressure Nitrided Oxide in MOS Capacitors''

January 1987

University of California, Berkeley
B.S. in Electrical Engineering and Computer Science

May 1984

Research and Professional Experience:
Professor of Electrical Engineering and Computer Science
School of Engineering and Applied Sciences, Harvard University
Gordon McKay Professor
September 1997 - present
Associate Professor
September 1994 - 1997
Assistant Professor
September 1990 - 1994
Analysis, design and implementation of microelectronic circuits and VLSI systems.
Teaching and curriculum planning in electrical engineering and computer science.
HBS University Fellow and Visiting Professor
Harvard Business School
Research and teaching in technology innovation and industry evolution.

September 2008 - present

Founder
March 2000 – March 2008
Silicon7, Incorporated
Seongnam-si, Kyoungki-do, KOREA
Application Specific Memory products for mobile communications and computing platforms.
Science and Technology Board Member
Polaroid Corporation, Cambridge, Massachusetts
Evaluation of research and technology developments.

June 1998 – June 2001

Consultant and Senior Fellow
Hyundai Electronics Industries, Ichon, Korea

August 1995 – March 2000

Development of high performance CMOS image sensor technology for embedded
image sensing and processing applications. Research on advanced DRAM design and
merged memory logic (MML) technology for advanced computer systems.

Consultant
December 1993 - June 1998
Hamamatsu Photonics K.K., Hamamatsu City, Japan
Development of smart image sensors and CCD/CMOS analog charge-domain circuitry.
Consultant
Istituto per la Ricerca Scientifica e Tecnologica (IRST), Trento, Italy
Research and development of advanced CMOS/CCD technology and circuitry.

June 1991 - December 1993

Consultant
June 1988 - August 1990
M.I.T. Lincoln Laboratory, Dr. Alice M. Chiang, Advisor
Design and implementation of CCD image sensors and analog signal processors.
Research Assistant
M.I.T. Artificial Intelligence Laboratory, Professor Tomaso Poggio, Advisor
Implementation of analog VLSI hardware for computer vision.

September 1987 - August 1990

Research Assistant
September 1984 - August 1987
M.I.T. Microsystems Technology Laboratory, Professor Charles G. Sodini, Advisor
Development and characterization of low pressure ammonia and oxygen annealing
process for improved reliability of scaled MOS transistors.
Research Assistant
January 1983 - May 1984
U.C. Berkeley Electronic Research Laboratory, Professor Chenming Hu, Advisor
Measurement and analysis of hot electron degradation in MOS transistors.

Honors and Awards:
National Science Foundation Young Investigator Award
Army Research Office Young Investigator Award
Hertz Foundation Fellowship
National Science Foundation Fellowship
University of California Alumni Scholarship
Phi Beta Kappa, Eta Kappa Nu, Tau Beta Pi

1992
1992
1984 – 1990
1984
1980 - 1984
1984

Patents:
Method and Charge--Coupled Apparatus for Algorithmic Computations, Woodward Yang, May 12, 1992, U.S.
Patent No. 5,113,365.
Image Sensor Array With Threshold Voltage Detectors and Charged Storage Capacitors, Woodward Yang,
May 25, 1993, U.S. Patent No. 5,214,274.
Error Correcting Sigma-Delta Modulation Decoding, Philip Steiner and Woodward Yang, November 17, 1998,
U.S. Patent No. 5,838,272.
CMOS image sensor with equivalent potential diode, Woodward Yang, Ju Il Lee and Nan Yi Lee, February 26,
1999, US Patent No. 6,180,969.
CMOS image sensor with equivalent potential diode and method for fabricating the same, Woodward Yang, Ju
Il Lee and Nan Yi Lee, February 26, 1999, US Patent No. 6,184,055.

CMOS image sensor with testing circuit for verifying operation thereof, Oh Bong Kwon, Woodward Yang, Suk
Joong Lee, and Gyu Tae Hwang, February 26, 1999, US Patent No. 6,633,335.
Antifuse circuitry for post-package DRAM repair, Woodward Yang, et al., January 10, 2000, US Patent No.
6,240,033.
Image sensor with analog-to-digital converter that generates a variable slope ramp signal, Kang Jin Lee, Chan
Ki Kim, Jae Won Eom and Woodward Yang, February 8, 2001, US Patent No. 6,545,624.
Error-correcting circuit for high density memory, Elaine Ou and Woodward Yang, June 9, 2009, US Patent No.
7,546,517.

Selected Presentations, Interviews and Invited Lectures:
“Chip Industry must learn not to overshoot,” EE Times cover page, interview and commentary, June 6, 2006.
“Disruptive Innovation,” Keynote Speaker at Consumer Electronics Show, January 2006.
“Using DRAM Technology to Make SRAM,” The Weekly Economist interview, September 24, 2002.
“Silicon7 8-Mbit SRAM sports single-transistor cell,” EE Times interview, September 2001.
“Hyundai modifies DRAM process to produce CMOS image sensors,” EE Times interview, March 1999.
“Merged Memory Logic,'' W. Yang, IEEE Solid-State Circuits Society Distinguished Lecturer,
Hanyang University, Korea, March 1999.
``The Dawn of Billion Transistor Chips,'' W. Yang, 1998 Korea - U.S. Science and Technology Symposium:
Computing and Telecommunication, Chicago, April 1998.
``Innovation in Microelectronic Manufacturing,'' W. Yang, National Research Council Workshop on the
Electronics Industry, November 1997.
``The Smart Access Memory: An Intelligent RAM for Nearest Neighbor Database Searching,'' A. Lipman and
W. Yang, Workshop on Mixing Logic and DRAM at the 24th International Symposium on Computer
Architecture, http://iram.cs.berkeley.edu/isca97-workshop, June 1997.
``Using MML to Simulate Multiple Dual-Ported SRAMs: Parallel Routing Lookups in an ATM Switch Controller,''
A. Brown, D. Chian, N. Mehta, Y. Papaefstathiou, J. Simer, T. Blackwell, M.D. Smith, and W. Yang, Workshop
on Mixing Logic and DRAM at the 24th International Symposium on Computer Architecture,
http://iram.cs.berkeley.edu/isca97-workshop, June 1997.
``Trends in Electronic Image Sensing and Processing,'' IEEE Laser and Electro Optical Society, Lincoln, MA,
March 1996.
``VLSI Systems for Machine Vision,'' LG Industrial Systems, Anyang, Korea, August 1996.
``An Embedded Processor-Memory Architecture,'' Samsung Electronics, Kiheung, Korea, June 1996.
``VLSI Hardware for Example-Based Learning,'' IBM T.J. Watson Laboratories, Hawthorne, NY, October 1995.
``Intelligent VLSI Systems,'' Hyundai Electronics, Ichon, Korea, December 1994.
``Bidirectional Delay Line'' and ``Pulse-based Photodetector,'' NSF Workshop on Neuromorphic Analog VLSI
Systems, Telluride, CO, July 1994.

Depositions and Trial Testimonies:
In the matter of CERTAIN ELECTRONIC DEVICES, INCLUDING MOBILE PHONES, PORTABLE MUSIC
PLAYERS, AND COMPUTERS (ITC, Investigation No. 337-TA-701, deposition and trial) – retained by Nokia
Publications:
"Science and Technology Entrepreneurship for Greater Societal Benefit: Ideas for Curricular Innovation,"
Fleming, Lee, Woodward Yang, and John Golden in Spanning Boundaries and Disciplines: University
Technology Commercialization in the Information Age, edited by Gary D. Libecap, Marie Thursby and
Sherry Hoskinson, Emerald Group Publishing Limited, 2010.
“The New Economics of Semiconductor Manufacturing,” Clayton Christensen, Steve King, Matt Verlinden and
Woodward Yang, IEEE Spectrum, vol. 45, issue 5, pp. 24-29 May 2008.
“Energy Consumption Model for Power Management in Wireless Sensor Networks,” Qin Wang and Woodward
Yang, IEEE Communications Society Conference on Sensor, Mesh and Ad Hoc Communications and
Networks SECON 2007, June 2007.
“A Realistic Power Consumption Model for Wireless Sensor Network Devices,” Qin Wang, Mark Hempstead
and Woodward Yang, IEEE Communications Society Conference on Sensor, Mesh and Ad Hoc
Communications and Networks SECON 2006, September 2006.
“Fast Error-Correcting Circuits for Fault-Tolerant Memory,” E. Ou and W. Yang, IEEE International Workshop
on Memory Technology, Design and Testing, pp. 8-12, August 2004.
“A Low-Power 256-Mb SDRAM with an On-Chip Thermometer and Biased Reference Line Sensing Scheme,”
J.P. Kim, W. Yang, and H.-Y. Tan, IEEE Journal of Solid-State Circuits, vol. 38, no. 2, pp. 329-337, February
2003.
“An Antifuse EPROM Circuitry Scheme for Field-Programmable Repair in DRAM,” J.K. Wee, W. Yang, E.K.
Ryou, J.S. Choi, S.H. Ahn, J.Y. Chung and S.C. Kim, IEEE Journal of Solid-State Circuits, vol. 35, no. 10,
pp. 1408-1414, October 2000.
''An Embeddable Low Power SIMD Processor Bank,'' S.-H. Hong and W. Yang, Digest of Technical Papers of
IEEE International Solid--State Circuits Conference, pp. 192-193, February 2000.
''Antifuse EPROM Circuit for Field Programmable DRAM,'' J.-S. Choi, J.-K. Wee, P.-J. Kim, J.-K. Oh, C.-H.
Lee, H.-Y. Cho, J.-Y. Chung, S.-C. Kim and W. Yang, Digest of Technical Papers of IEEE International Solid-State Circuits Conference, pp. 406-407, February 2000.
''An Improved Digital CMOS Imager,'' O.-B. Kwon, K.-N. Park, D.-Y. Lee, K.-J. Lee, S.-C. Jun, C.-K. Kim, Y.-B.
Lee and W. Yang, IEEE Workshop on Charged-Coupled Devices and Advanced Image Sensors, Nagano,
Japan, June 1999.
''A Linear-Response, High-Dynamic Range CMOS Imager Suitable for Spectroscopic Applications,'' D. Qian
and W. Yang, IEEE Workshop on Charged-Coupled Devices and Advanced Image Sensors, Nagano, Japan,
June 1999.
''New Self Refresh Scheme Using Cell Leakage Monitoring Circuit,'' Y.-H. Seol, H.-Y. Cho, J.-K. Wee, D.-H.
Ryu, J.-G. Oh, J.-S. Choi, J.-J. Lee, J.-H. Lee, and W. Yang, (in Korean) Proceedings of the 6th Korean
Conference on Semiconductors, pp. 377-378, Seoul, Korea, February 1999.
''High Voltage Circuitry for Post Package DRAM Repair,'' P.-J. Kim, J.-G. Oh, J.-K. Wee, D.-H. Ryu, Y.-H. Seol,
H.-Y. Cho, J.-S. Choi, J.-H. Han, J.-H. Lee, and W. Yang, (in Korean) Proceedings of the 6th Korean
Conference on Semiconductors, pp. 385-386, Seoul, Korea, February 1999.

``An Integrated 800 x 600 CMOS Imaging System,'' W. Yang, O.-B. Kwon, J.-I. Lee, G.-T. Hwang and S.-J.
Lee, Digest of Technical Papers of IEEE International Solid--State Circuits Conference, pp. 304-305, February
1999.
``VLSI Hardware for Example-Based Learning,'' A. Lipman and W. Yang, IEEE Transactions on VLSI
Systems, vol. 5, no. 3, pp. 320-328, September 1997.
``A Reconfigurable VLSI Coprocessing System for the Block Matching Algorithm,'' A. Bugeja and W. Yang,
IEEE Transactions on VLSI Systems, vol. 5, no. 3, pp. 329-337, September 1997.
``A CCD/CMOS Image Sensor Array with Integrated A/D Conversion,'' M. Gottardi and W. Yang, Proceedings
of the IEEE International Symposium on Circuits and Systems, Vol. III, pp. 1908-1911, June 1997.
``Circuit integration pushes image sensor performance,'' W. Yang, Laser Focus World, Penwell Publishing,
pp. 129-139, February 1997.
``A Framework for Analysis of High Order Sigma-Delta Modulators,'' P. Steiner and W. Yang, IEEE
Transactions on Circuits and Systems II: Analog and Digital Signal Processing, vol. 44, no. 1,
pp. 1-12, January 1997.
``Competitive learning algorithms for channel optimized vector quantizers,'' D. Martinez and W. Yang, The
1996 IEEE International Conference on Neural Networks, pp. 1462-1467, June 1996.
``Stability of High Order Sigma-Delta Modulators,'' P. Steiner and W. Yang, Proceedings of IEEE International
Symposium on Circuits and Systems, Vol. III, pp. 52-57, May 1996.
``Simple Pulse Asynchronous State Machines,'' J. Miller and W. Yang, Proceedings of IEEE International
Symposium on Circuits and Systems, Vol. III, pp. 405-409, May 1996.
``Neuromorphic CMOS Circuitry for Active Bidirectional Delay Lines,'' W. Yang, Proceedings of IEEE
International Symposium on Circuits and Systems, Vol. III, pp. 473-476, May 1996.
``A Robust Backward Adaptive Quantizer,'' D. Martinez and W. Yang, Proceedings of IEEE Workshop on
Neural Networks for Signal Processing V, pp. 531-540, August 1995.
``A Real-Time Face Recognition System Using Machine Vision Techniques,'' W. Yang, invited paper,
CardTech/SecurTech Conference Proceedings, pp. 179-193, April 1995.
``Stability Analysis of the Second Order Sigma-Delta Modulator,'' P. Steiner and W. Yang, Proceedings of IEEE
International Symposium on Circuits and Systems, Vol. V, pp. 365-368, June 1994.
``An Interline CCD Imaging Array with On-Chip A/D Conversion,'' D. J. Friedman and W. Yang, Proceedings of
SPIE, Charge--Coupled Devices and Solid State Optical Sensors IV, vol. 2172, pp. 54-63, February 1994.
``A Wide Dynamic Range, Low Power Photosensor Array,'' W. Yang, Digest of Technical Papers of IEEE
International Solid--State Circuits Conference, pp. 230-231, February 1994.
``A Real--Time Face Recognition System Using Custom VLSI Hardware,'' J.M. Gilbert and W. Yang,
Proceedings of IEEE Workshop on Computer Architectures for Machine Perception, pp. 58-66, December
1993.
``A CCD/CMOS Image Motion Sensor,'' M. Gottardi and W. Yang, Digest of Technical Papers of IEEE
International Solid—State Circuits Conference, pp. 194-195, February 1993.
``Analog CCD Processors for Image Filtering,'' W. Yang, Proceedings of SPIE, Visual Information Processing:
From Neurons to Chips, vol. 1473, pp. 114-127, April 1991.

``The MIT Vision Chip Project: Analog VLSI Systems for Fast Image Acquisition and Early Vision Processing,''
J.L. Wyatt, D.L. Standley, and W. Yang, Proceedings of the International Conference on Robotics and
Automation, vol. 2, pp. 1330-1335, April 1991.
``A Full Fill--Factor CCD Imager with Integrated Signal Processors,'' W. Yang and A.M. Chiang, Digest of
Technical Papers of International Solid--State Circuits Conference, pp. 218-219, February 1990.
``A Charge--Coupled Device Architecture for On Focal Plane Image Signal Processing,'' W. Yang, Proceedings
of International Symposium on VLSI Technology, Systems, and Applications, pp. 266-270, May 1989.
``Optical Flow: Computational Properties and Networks, Biological and Analog,'' Tomaso Poggio, Woodward
Yang, and Vincent Torre, The Computing Neuron, R. Durbin, C. Maill, and G. Mitchison (editors), pp. 255370, Addison--Wesley, New York, 1989.
``Optimization of Low Pressure Nitridation/Oxidation of SiO2 for Scaled MOS Devices,'' W. Yang, R.
Jayaraman, and C.G. Sodini, IEEE Transactions on Electron Devices, vol. ED-35, no. 7, pp. 935-944, July
1988.
``Radiation Effects in Low Pressure Reoxidized Nitrided Oxide Gate Dielectrics,'' G. Dunn, R. Jayaraman, W.
Yang, and C.G. Sodini, Applied Physics Letters, vol. 52, no. 20, pp 1713-1715, May 1988.
``The MIT Vision Machine,'' T. Poggio, J. Little, E. Gamble, W. Gillet, D. Geiger, D. Weinshall, M. Villalba, N.
Larson, T. Cass, H. Bulthoff, M. Drumheller, P. Oppenheimer, W. Yang, and A. Hurlbert, DARPA Image
Understanding Workshop, pp. 177-198, April 1988.
``MOS Electrical Characteristics of Low Pressure Re—oxidized Nitrided Oxide,'' R. Jayaraman, W. Yang, and
C.G. Sodini, Technical Digest of International Electron Devices Conference, pp. 668-671, December 1986.
``Hot Carriers Induced Degradation in Thin Gate Oxide MOSFET's,'' M--S. Liang, C. Chang, W. Yang, C. Hu,
and R.W. Brodersen, Technical Digest of International Electron Devices Conference, pp. 186-189, December
1983.