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

Filing 540

Administrative Motion to File Under Seal Apple Inc.s Responsive Claim Construction Brief filed by Apple Inc.(a California corporation). (Attachments: #1 Apple Inc.s Responsive Claim Construction Brief, #2 Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #3 Exhibit A to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #4 Exhibit B to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #5 Exhibit C to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #6 Exhibit D to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #7 Exhibit E to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #8 Exhibit F to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #9 Exhibit G to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #10 Exhibit H to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #11 Exhibit I to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #12 Exhibit J to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #13 Exhibit K to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #14 Exhibit L to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #15 Exhibit M to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #16 Exhibit N to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #17 Exhibit O to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #18 Exhibit P to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #19 Exhibit Q to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #20 Exhibit R to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief, #21 Exhibit S to Declaration of Mark D. Selwyn in Support of Apple Inc.s Responsive Claim Construction Brief)(Selwyn, Mark) (Filed on 12/22/2011)

EXHIBIT E

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

APPLE INC., a California corporation
Plaintiffs,
v.

§
§
§
§ CIVIL ACTION NO. 11-CV-01846-LHK
§
§
§
§
§
§

SAMSUNG ELECTRONICS CO., LTD., a
Korean business entity, SAMSUNG
ELECTRONICS AMERICA, INC., a New
York corporation, and SAMSUNG
TELECOMMUNICATIONS AMERICA,
LLC, a Delaware limited liability company
Defendants.

DECLARATION OF TONY GIVARGIS, PH.D.
IN SUPPORT OF APPLE’S PROPOSED CLAIM CONSTRUCTION
FOR U.S. PATENT NO. 7,698,711
I.

Introduction

1.

I have been retained as an expert in this case by Apple Inc. (“Apple”). In this
Declaration I provide my opinions regarding the interpretation of the term
“applet” as used in the claims of U.S. Patent No. 7,698,711 to Jeong (“the ‘711
patent”).

II.

Qualifications

2.

I received a Bachelor of Science degree in Computer Science from the University
of California, Riverside, in 1997. In 2001, I received my Ph.D. degree in
Computer Science, also from the University of California, Riverside. My doctoral
thesis, completed under the supervision of Professor Frank Vahid, was titled
“Design Space Exploration of Parameterized System-on-a-Chip Architectures”
and related to computer-aided design optimization of highly integrated circuits on
chip.

3.

Since 2001, I have been a member of the Department of Computer Science
faculty at the University of California, Irvine (“UC-Irvine”). From 2001-2007, I
held the title Assistant Professor of Computer Science. I was promoted to
Associate professor, with tenure, in 2007, and to full Professor in 2011.
Beginning in 2011, in addition to my role as Professor of Computer Science, I
was appointed Associate Dean for Student Affairs in the Donald Bren School of
Information & Computer Sciences at UC-Irvine.

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4.

My research is in the area of Embedded Systems design. Embedded systems are
devices that, in addition to having mechanical and electrical parts, make use of an
embedded computing element, comprised of one or more processors and system
software. An inherent characteristic of embedded systems is the need for
multitasking, i.e., the ability to perform a number of tasks simultaneously. My
research is focused on software intended for embedded systems, real-time
operating systems, multitasking systems, cross-compilers, embedded processor
architectures, multi-core processors, flash memory systems, low power design,
and general system optimization algorithms. I have graduated four Ph.D. students
and am currently directing a group of five Ph.D. and two M.S. students. My
research is supported by the National Science Foundation (NSF), with
approximately $1.7M in current funding.

5.

As a professor, I regularly teach both at the graduate and undergraduate levels. At
UC-Irvine, among computer science and engineering students, I am best known
for routinely teaching the upper division embedded systems course (CS 145).
This course covers the design cycle of a typical embedded device, including all
aspects of hardware and software integration. Additionally, I have taught courses
in the areas of programming (including languages such as Java and C/C++), data
structures and algorithms, logic design, modeling and simulation, ubiquitous
computing, and compilers.

6.

I have published over 70 peer-reviewed conference and journal papers, four of
which have been recognized by Best Paper Awards. My papers are published in
highly ranked, archived, and ACM/IEEE-sponsored venues. I am a co-inventor
on 10 issued US patents. I have co-authored two popular textbooks on embedded
system design that are widely used at top institutions in US as well as around the
globe. I received the prestigious 2011 Frederick Emmons Terman Award for my
textbook entitled Embedded System Design: A Unified Hardware/Software
Introduction.

7.

I am being compensated for my time spent on the case at a rate of $275/hour.

8.

I am attaching as Exhibit A my updated curriculum vitae setting forth my
qualifications and publications.

III.
9.

Materials Reviewed
My opinions expressed in this declaration are based on my review of the
following materials:
A.

The ‘711 patent

B.

The prosecution history of the ‘711 patent

C.

The prosecution history of the parent application of the ‘711 patent
(U.S. Application No. 11/390,338)

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D.

Apple’s LPR 4-2 disclosure of proposed claim construction for
“applet” and materials cited in support

E.

Samsung’s LPR 4-2 disclosure of proposed claim construction for
“applet” and materials cited in support

10.

I also based this opinion on my professional and academic experience including in
the field of embedded systems and programming for multitasking operations.

11.

If asked, I may testify on these materials and experience.

IV.

Understanding of the Law

12.

I have been informed and understand that claim construction is the process of
determining a patent claim’s meaning. I also have been informed and understand
that the proper construction of a claim term is the meaning that a person of
ordinary skill in the art (i.e., the technical field to which the patent relates) would
have given to that term at the time when the patent’s application was filed.

13.

I understand that, for claim construction, one must focus on the claim terms in the
context of the claim as a whole, interpreting the claim language as it ordinarily
would be understood. After the claim language, the most important sources to
consider are the patent specification, followed by the prosecution history. I
understand that, collectively, these sources—the claim language, specification,
and prosecution history—are called “intrinsic evidence.”

14.

I further understand that a patentee may act as his own lexicographer and provide
definitions in the specification. If a patent contains a clear definition of a term,
then the term should be construed in accordance with that definition.

15.

I further understand that actions taken by the patent owner can affect the
constructions of the claim terms. For example, if the patent owner distinguishes
the claims from prior art during prosecution, it would generally be incorrect to
construe the claims so as to cover the distinguished material.

16.

In addition, claim construction may take into account dictionaries, technical
references, and other information—called “extrinsic evidence”—that would have
been available to those skilled in the art at the time when the patent’s application
was filed. I understand that the law considers extrinsic evidence to be less
reliable than intrinsic evidence, and that extrinsic evidence cannot change the
ordinary meaning of the claim language.

V.
17.

Person of Ordinary Skill in the Art
The ‘711 patent was filed in the U.S. Patent and Trademark Office on July 16,
2007 and claims priority to Korean patent application 10-2005-0079921, filed on
August 30, 2005. Accordingly, I understand I am to interpret the claim terms in

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the ‘711 patent from the perspective of the person of ordinary skill in the art as of
August 30, 2005.
18.

VI.

For the '711 patent, a person of ordinary skill in the art in 2005 would have at
least a bachelor's degree in computer science/engineering or similar discipline and
several years' relevant industry or academic research experience in the areas of
multitasking systems, embedded systems or programming for handheld
devices. Alternatively, the ordinary artisan would have had a more advanced
degree in computer science/engineering or a similar field with somewhat less
additional work or research experience.
Technology Background

19.

In some instances in computer programming, it is desirable for a first program or
application to run within the context of a second application (or “host”), where the
host application interprets and executes the instructions of the first program. This
can be advantageous, for example, so that the host application can insulate or
protect a user’s computer from a potentially suspicious first application that is
obtained externally, e.g., on the internet. Another advantage is that the first
application or program can be accessible to a diverse user base and be
implemented in essentially the same form across multiple different platforms.

20.

That is, in software systems where a first application executes within the context
of a second “host” application, the first application can be run independent of the
platform on which the host application is executing. The host application
provides the complete execution environment for the first application
independently of the platform, including the operating system. For example, in
2005, a video game program could run on a host web browser, such as Microsoft
Internet Explorer running on a Windows-based PC. The same video game
program could also run on a different host browser, such as Netscape on a laptop
running the Linux operating system.

21.

Java provides a common example of such programs (today as well as in 2005).
Java is a computer programming language used to develop applications that run
on a variety of platforms, including handheld devices, laptops, and desktops
running different operating systems. A Java-enabled device is one that supports
the necessary tools and environments needed to execute Java applications. Java
or Java-like applications are developed once and distributed widely to users
running different platforms, including different operating systems.

22.

Leading up to 2005, mobile phone manufacturers increasingly produced Javaenabled devices. Java applications running on mobile devices had access to the
multimedia capabilities of the device, including audio and video playback. For
example, major phone manufacturers such as Sony Ericsson, Nokia, and others
marketed Java-enabled mobile phones by 2005. Third-party developers
commonly developed programs for the Java-enabled mobile phone market.

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VII.

The ‘711 patent disclosure

23.

The ‘711 patent describes a “portable terminal,” such as a cellular telephone,
which can be used by the operator to listen to an MP3 music file while
simultaneously working in another application, such as a messaging function. See,
e.g., ‘711 patent at Abstract.

24.

In the “Background of the Invention” section of the ‘711 patent, the specification
describes the purported problem in the art being addressed by the patent:
Generally, a portable terminal having an MP3 music play function
controls and plays an MP3 music file using a separate player. For
example, a user may select an MP3 music play function from
menus of a portable terminal for listening to the music. The user
may also selectively use control-related functions such as play,
pause, repeat, and terminate the MP3 music play function.
However, the user cannot simultaneously work on several menus
of the portable terminal while listening to the music using the
conventional MP3 music play function. In other words, the user
cannot use the other functions of scheduling, picture viewing, or
game menu among others while listening to the music.
To address this problem, a control processor is added to manage
only MP3 music play, resulting in an increase in cost and an
increase in the complexity of hardware and software configurations.
Accordingly, there is a need for an improved system and method to
allow a user to simultaneously work on multiple menus of the
portable terminal while listening to music.
‘711 patent at Col. 1:32-51

25.

The “Summary of the Invention” section goes on to state:
An aspect of exemplary embodiments of the present invention is to
address at least the above problems and/or disadvantages and to provide at
least the advantages described below. Accordingly, an aspect of
exemplary embodiments of the present invention is to provide a multitasking apparatus and method in a portable terminal, in which menu
functions of the portable terminal can be implemented while continuing to
play a music file.
‘711 patent at Col. 1:55-62.

26.

The ‘711 patent goes on to discuss multi-tasking using “a music background play
object.”

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According to another aspect of an exemplary embodiment of the
present invention, a multi-tasking method in a portable terminal is
provided. Where a music background play object is generated in a
standby mode. The music background play object acquires a task
for music background play and provides a control interface for
music play. The music file is played through multi-tasking in the
standby mode using the music background play object upon
selection of a music play mode in the portable terminal. A menu
function of the portable terminal in the music play mode is selected.
The portable terminal switches to a mode of the selected menu of
the portable terminal and implements a corresponding function
while continuing to play the music upon selection of the menu
function of the portable terminal. The portable terminal switches to
the music play mode upon termination of the mode of the selected
menu of the portable terminal.
‘711 patent at Col. 2:26-41.
27.

The ‘711 further describes “a music background play object” with respect to the
flowchart illustrated in FIG. 2:
Referring to FIG. 2, the controller 110 of the portable terminal
generates an MP3 music background play object in the standby
mode in step 201 to play an MP3 music file as background music.
The MP3 music background play object generated in step 201
internally acquires a task for MP3 music background play, returns
to the standby mode, and provides a control interface to allow
other applications to transmit commands for music play and
control through the MP3 music background play object.
When an MP3 music play command is selected in the portable
terminal, the controller 110 senses the selection and executes an
MP3 music play application in step 202. The controller 110
transmits the MP3 music play command to the activated MP3
music background play object in the standby mode through an
interface for an execution command provided by the MP3 music
background play object. The MP3 music background play object
switches to an MP3 music play mode by multi-tasking in step 203.
‘711 patent at Col. 4:52-Col. 5:2.

28.

The only recitation of the term “applet” in the specification is as follows:
FIG. 1 is a block diagram of a portable terminal according to an
exemplary embodiment of the present invention, in which an MP3
music control processor is not included. Application modules of
the portable terminal include at least one applet and each of the
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application modules, that is each menu of the portable terminal,
independently performs multi-tasking.
‘711 patent at Col. 3:8-14 (bold emphasis added).
VIII.
29.

The ‘711 patent claims and file history
The ‘711 patent issued with 20 claims, including 3 independent claims (claims 1,
9, and 17). I understand that claims 1, 2, 7-10, and 15-18 are being asserted by
Samsung in this litigation. Representative claim 1 is reproduced below (letter
designations (a-h) added and the term “applet” highlighted in bold for clarity):
1. A multi-tasking method in a pocket-sized mobile
communication device including an MP3 playing capability, the
multi-tasking method comprising:
(a) generating a music background play object, wherein the music
background play object includes an application module including
at least one applet;
(b) providing an interface for music play by the music background
play object;
(c) selecting an MP3 mode in the pocket-sized mobile
communication device using the interface;
(d) selecting and playing a music file in the pocket-sized mobile
communication device in the MP3 mode;
(e) switching the MP3 mode to a standby mode while the playing
of the music file continues;
(f) displaying an indication that the music file is being played in
the standby mode;
(g) selecting and performing at least one function of the pocketsized mobile communication device from the standby mode while
the playing of the music file continues;
(h) and continuing to display the indication that the music file is
being played while performing the selected function.

30.

In addition to claim 1, the term “applet” is recited in claims 9 and 17 claiming “a
controller for generating a music background play object, wherein the music
background play object includes an application module including at least one
applet.”

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IX.

Disputed claim term of the ‘711 patent

31.

The following term is disputed between the parties:
A.

“applet”

Claim
No.
1, 9,
17

Disputed Term
“applet”

1.
32.

Apple’s Proposed
Construction
“An operating systemindependent computer
program that runs within
an application module.”

Samsung’s Proposed
Construction
“A small application
designed to run within
another program.”

Meaning to One of Ordinary Skill in the Art

A person of ordinary skill in the art in 2005 would have understood the term
“applet” in the claims of the ‘711 patent to mean “an operating systemindependent computer program that runs within an application module.”
2.

Intrinsic Evidence

33.

The language of claims 1, 9, and 17 requires “an application module including at
least one applet.” One of ordinary skill in the art would therefore understand that
the claimed applet runs within an application module.

34.

Neither the ‘711 specification nor the file history provides a definition of the term
“applet.” The only recitation of the term “applet” in the specification is as
follows:
FIG. 1 is a block diagram of a portable terminal according to an
exemplary embodiment of the present invention, in which an MP3
music control processor is not included. Application modules of
the portable terminal include at least one applet and each of the
application modules, that is each menu of the portable terminal,
independently performs multi-tasking.
‘711 patent at Col. 3:8-14 (bold emphasis added).

35.

The prosecution file history of the ‘711 patent contains several mentions of the
term “applet” but does not provide a definition. Remarks made by the examiner
and applicant including the term “applet” are provided in the following
paragraphs.

36.

“Examiner suggested to further include the definition ‘a music background play
object’ as ‘wherein the music background play objects including an application
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module includes at least one applet’ as argued during the interview to distinct
[sic] from the icon as taught by KOKUBO.” U.S. Patent Application No.
11/778,466, Examiner’s Interview Summary of December 16, 2009, see
Continuation Sheet (bold emphasis added).
37.

“The Office did suggest, however, that the inclusion of a limitation further
defining the music background play object would distinguish over the prior art of
record, though not necessarily be allowable depending on the results of a further
search. Specifically, the Office suggested including a limitation indicating that
the music background play object includes an application module including at
least one applet. Applicant appreciates the Office’s suggestion and has amended
the independent claims as suggested.” U.S. Patent Application No. 11/778,466,
Applicant’s December 8, 2009 Arguments/Remarks Made in an Amendment at pp.
6-7 (bold emphasis added).

38.

“For the specific invention as claimed, a music background play object, wherein
the music background play object includes an application module including at
least one applet, is included such that an MP3 file can be played in the
background while other menu tasks can be executed by the user.” Id. at p.7 (bold
emphasis added).

39.

“By use of the music background play object, which is an application module
including at least one applet as discussed with reference to para. [0018], the
terminal is able to perform multi-tasking. That is, by generating the application
module of the music background play object, the music background play object
provides an interface for the playing of music, specifically the selecting of an
MP3 mode. At the same time, the user is able to execute other menu functions of
the device and thus multi-task using the device. It is Applicant's contention that
independent claims 1,9 and 17 are allowable based on the unique use of the music
background play object, wherein the music background play object includes an
application module including at least one applet, alone, and not based on the use
of the music background play object in a standby or any other mode. That is, none
of the prior art discloses a music background play object, wherein the music
background play object includes an application module including at least one
applet in any mode of a device. Accordingly, Applicant believes that the claims
are in condition for immediate allowance.” Id. at pp. 7-8 (bold emphasis added).

40.

“As suggested by the Office during the interview, this clarifying limitation is not
disclosed, taught or suggested by Kokubo. Rather, as acknowledged by the
Office in the outstanding rejection, Kokubo merely discloses the generating of ‘an
icon corresponding to a task (application software)’ col. 2, lines 34-39; see also
col. 13, lines 8-10 (‘manually or automatically generated music [music note
symbol] icon 10f is displayed.’ The generating of the icon by Kokubo is not a
disclosure of generating a music background play object, wherein the music
background play object includes an application module including at least one
applet. That is, Kokubo makes no disclosure that the icon includes an application
module, or that the application module includes at least one applet as instantly
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claimed.” Id. at pp. 9-10 (italics in original) (bold emphasis added). See also,
‘711 patent claims 1, 9, and 17.
41.

These passages from the file history reinforce the clear language of the claims and
specification stating that the claimed applet runs within an application module.
3.

Extrinsic Evidence

42.

The McGraw-Hill Dictionary of Scientific and Technical Terms (6th Ed., 2003) at
p.124 defines “applet” as “a small program, typically written in Java.” This
definition supports Apple’s proposed construction because persons of ordinary
skill in the art in 2005 would commonly associate the term “applet” with an
application written in the Java programming language, and Java was well-known
to be operating system-independent, as described above.

43.

The Dictionary for Library and Information Science (1st Ed., 2004) at p.34
defines “applet” as “a small application program written in the Java programming
language developed by Sun Microsystems for distribution over the Internet.
Applets run on any Java-enabled Web browser independent of platform
(Windows, Macintosh, UNIX, etc.).” This definition again supports Apple’s
proposed construction because persons of ordinary skill in the art in 2005
understood “applets” as commonly being written in the Java programming
language, which is characterized by programming independent of the platform,
including the operating system.

44.

The Java Developer’s Resource (1997) by Eliotte Harold (“the Harold reference”)
at p.11 states that “[w]hat’s most special about Java in relation to other
programming languages is that it lets you write special programs called applets
that can be downloaded from the Internet and played safely within a Web
browser.” The discussion in this text supports Apple’s construction because it
reflects the common understanding of persons of ordinary skill in the art in 2005
that applets, typically written in the operating system-independent Java
programming language, are executed within an application module, e.g., a Web
browser. The Web browser or other application module provides the execution
environment for the applet.

45.

The Harold reference at p.12 further explains how applets can be independent of
the host platform: “Java solves the problem of platform independence by using
byte code…. Java programs that have been compiled into byte code still need an
interpreter to execute them on any given platform. The interpreter reads the byte
code and translates it into the platform’s native language on the fly. The most
common such interpreter is Sun’s program java (with a little j). Since the byte
code is completely platform independent, only the interpreter and a few native
libraries need to be ported to get Java to run on a new computer or operating
system.”

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46.

Thus, the above excerpt in the Harold reference further supports Apple’s proposed
construction of “applet” as being “operating system-independent.” Persons of
ordinary skill in the art in 2005 would have understood Java applications,
including applets, as being processor and operating system “agnostic” or
independent. Specifically, Java applications, including applets, execute within a
standardized execution environment. An “interpreter,” designed according to the
standardized execution environment and usually a component of the host
application module, translates the instructions of the Java applications, including
applets, to those of the host platform and operating system. Thus, applets are
“independent” of the operating system because they can rely upon the interpreter
in the host application module to translate their instructions for them; they do not
interact directly with the operating system and instead, in the context of the ‘711
patent, run within the application module.

47.

Further, the Harold reference at p.12 describes the security advantage of applets
as programs running within an application module: “Java solves this [security]
problem by severely restricting what an applet can do. A Java applet cannot write
to your hard disk without your permission. It cannot write to arbitrary addresses
in memory and thereby introduce a virus into your computer. It cannot crash your
system.” See also, e.g., Harold at pp. 9-34. Thus, persons of ordinary skill in the
art in 2005 would understand “applet” to be a program that runs in the context of
another application module, such as a Web browser. The Web browser provides
the execution environment for the applet and restricts its access to a user’s
computer resource and private data.

48.

Java: An Introduction to Computer Science & Programming (3rd Ed., 2004) by
Walter Savitch (“the Savitch reference”) explains that “[t]he word applet sounds
as though it might refer to a small apple, but it is supposed to sound like a small
application. Thus, applets are just ‘little Java programs,’ in some sense of the
word little. However, the character of applets comes not from their size, but from
how and where they are run. Applets are Java programs that can be displayed on a
Web site and viewed over the Internet. They can also be run on your local
computer, without any connection to the Internet.” Savitch at p.797 (italics in
original). See also, e.g., Savitch at Chapter 1, pp. 3-37, and Chapter 13, pp. 795821. The Savitch reference supports Apple’s proposed construction because it
confirms that the person of ordinary skill would understand that applets have the
characteristics of Java-based programs, including running within an application
module independently of the operating system, as described in other references
cited in this declaration.

49.

In IBM e-server pSeries (12th Ed., 2004) by Hoskins, J. and Bluethman, R.
Exploring (“the Hoskins reference”), “Java is an object-oriented programming
environment that operates independent of any operating system or microprocessor.
Java programs, called applications or applets, can be entirely developed using the
compiler, debugger, and applet viewer tools provided in IBM's implementation
for the AIX for Java development environment. (C and C++ compilers and tools
are not needed to create/run Java-based applets.) The same applets can be
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dynamically transmitted over a network and run on any client that has been
enabled for Java. Because applet execution is platform independent, an applet
developed with the AIX 5L tools can be executed on any Java-enabled platform
(for example, Solaris).” Hoskins reference at p.226.
50.

The Hoskins reference as cited above supports Apple’s proposed construction of
applet because it shows that persons of ordinary skill in the art in 2005 would
define an “applet” as an application which “operates independent of any operating
system.” Further, Hoskins notes that “applet execution is platform independent,”
again supporting Apple’s proposed construction that “applet” would have been
understood to be a computer program that runs independent of the operating
system. Java applications, including applets, are designed to execute within a
standardized execution environment. A Java-enabled device provides an
environment that translates the instructions of the Java applications, including
applets, to those of the host platform and operating system.

51.

Further academic publications prior to 2005 support Apple’s proposed
construction of “applet” as including operating system independence. See, e.g.,
“Healy, M.R., Berger, D.E., Romero, V.L., Aberson, C.L., & Saw, A. Evaluating
JAVA applets for teaching on the Internet. Proceedings of the Scuola Superiore G.
Reis Romoli Advances in Infrastructure for e-Business, e-Education, e-Science,
and e-Medicine on the Internet International Conference. (2002) at p.1: “Java
applets are computer applications designed for the Internet. Applets are platformindependent, meaning that they can run on any operating system that has a Java
Virtual Machine to translate applet bytecodes into appropriate platformdependent instructions.” See also, e.g., Healy at pp. 1-5, available online at:
http://ccdl.libraries.claremont.edu/cdm4/item_viewer.php?CISOROOT=/irw&CI
SOPTR=432 .

52.

Operating system-independence was an understood characteristic of applets in the
art by 2005. As a further example, “Interactive Programming with Java Applets”
(2005) by Elizabeth Boese (“the Boese reference”) at p.8 notes that “Java is
platform independent because the source code is compiled to bytecode, and it’s
the bytecode that can be used on any platform (operating system).”

53.

The Boese reference further discusses at p.9: “There are two different types of
Java programs that we can create: applets and applications. Applets are Java
programs embedded into a web page. Applications are stand-alone programs that
can be run by themselves.” The Boese reference thus supports Apple’s proposed
construction of “applet” as a program “running within an application module”
because applets, unlike applications, are not stand-alone programs and cannot run
by themselves. See also, Boese at Chapter 1, pp. 7-20 (available online at
http://books.google.com/books?id=mEC7H9WxXHEC&pg=PA8&dq=applets+ar
e+operating+system+platform+independent&hl=en#v=onepage&q&f=false)

54.

Apple’s proposed construction of “applet” is further supported by Web
Technologies TCP/IP Architecture, and Java Programming” (2nd Ed., 2002) by
12

ACTIVEUS 91392256v1

Godbole, A. S. and Kahate, A. (“the Godbole reference”) at p.524: “[b]y virtue of
the Java heritage, applets are platform independent.” (available online at
http://books.google.com/books?id=uEufGycOJRsC&printsec=frontcover&source
=gbs_ge_summary_r&cad=0#v=onepage&q&f=true). Thus, a person of ordinary
skill in the art in 2005 would understand “applets” to be platform-independent,
which necessarily includes “operating system-independent.”
4.
55.

X.

Conclusion

Based on the above intrinsic and extrinsic evidence, it is my opinion that a person
of ordinary skill in the art in 2005 would have interpreted the term “applet” in the
‘711 patent claims according to Apple’s proposed construction as “an operating
system-independent computer program that runs within an application module.”
Samsung’s Proposed Construction of “Applet”

56.

I have reviewed Samsung’s Patent Local Rule 4-2 Disclosures, including Exhibit
A at p.51. I understand that Samsung has proposed “applet” should be construed
as “a small application designed to run within another program.”

57.

As support for its proposed construction, Samsung cites to the Wiley Electrical
and Electronics Engineering Dictionary (2004), which offers the same definition.
Samsung further cites to the single reference to “applet” in the ‘711 patent
specification at Col. 3:10-14, as discussed above in this declaration.

58.

It is my opinion that a person of ordinary skill in the art in 2005 would not have
construed “applet” as broadly as proposed by Samsung. As an initial matter, the
‘711 patent specification and claims explicitly require a narrower reading in
accordance with Apple’s proposed construction. For example, as discussed above,
each of claims 1, 9, and 17 requires “an application module including at least one
applet.” Based on the claim language alone it is clear that the claimed applet must
run within an application module. Furthermore, the only reference to applet in the
specification (at Col. 3:10-12) states that “[a]pplication modules of the portable
terminal include at least one applet,” confirming that the claimed applets run
specifically within “application modules” and not simply any “program” in
general as proposed by Samsung. As discussed above, the file history of the ‘711
patent also includes numerous statements reinforcing that the claimed applet runs
within an application module.

59.

It is further my opinion that “applets” would have been understood by a person of
ordinary skill in the art in 2005 to be operating system-independent as required by
Apple’s proposed construction. As shown above in numerous supporting
references, an “applet” was widely understood as a program that runs
independently of the host operating system and within the confines of a Web
browser or other application module.

13
ACTIVEUS 91392256v1

EXHIBIT A

Tony Givargis
University of California, Irvine
Computer Science
Irvine, CA 92697-3435
[e-mail]
[phone]

Objective
Research and teaching in the areas of computer science with emphasis on embedded systems.

Education
• Ph.D., Computer Science, University of California, Riverside, 2001.
• B.S., Computer Science, University of California, Riverside, 1997.

Position
• Associate Dean for Student Affairs, School of Information & Computer Sciences, University of California, Irvine, 2011-present.
• Professor, Department of Computer Science, University of California, Irvine, 2011-present.
• Associate Professor, Department of Computer Science, University of California, Irvine, 2007-2011.
• Assistant Professor, Department of Computer Science, University of California, Irvine, 2001-2007.

Member
• Institute of Electrical and Electronics Engineers (IEEE).
• Association for Computing Machinery (ACM).
• Special Interest Group on Design Automation Executive Committee (SIGDA).
• Center for Embedded Computer Systems (CECS) at University of California, Irvine.

Service
Editorial Board
• Associate Editor, ACM Transactions on Embedded Computing Systems (TECS), 2008-present.
• Online Editor, Odysci, 2010-2011.
• Associate Editor, ACM SIGDA Bimonthly Newsletter, 2005-2007.
• Guest Editor, International Journal of Parallel Programming (IJPP), 2007.
• Guest Editor, International Journal of Parallel Programming (IJPP), 2006.
• Associate Editor, Journal of Embedded Computing (JEC), 2004-2006.
1

Distinguished Service
• Executive Committee Member, ACM Special Interest Group on Design Automation (SIGDA), 20092011.
• Technical Program Committee Chair, International Conference on Hardware/Software Codesign and
System Synthesis (CODES+ISSS), 2010 (Co-Chair).
• Technical Program Committee Chair, IFIP Workshop on Software Technologies for Future Embedded
& Ubiquitous Systems (SEUS), 2008 (Co-Chair).
• Technical Program Committee Chair, Special Interest Group on Design Automation (SIGDA) Ph.D.
Forum at Design Automation Conference (DAC), 2007 (Chair).
• Technical Program Committee Chair, Special Interest Group on Design Automation (SIGDA) Technical
Committee on System Design, 2006 (Co-Chair).
• Technical Program Committee Chair, Special Interest Group on Design Automation (SIGDA) Ph.D.
Forum at Design Automation Conference (DAC), 2006 (Co-Chair).
• Special Sessions Chair, International Conference on Hardware/Software Codesign and System Synthesis
(CODES+ISSS), 2005.

Technical Program Committee Member
• International Conference on Computer Aided Design (ICCAD), 2010-present.
• International Conference on Compilers, Architecture, and Synthesis for Embedded Systems (CASES),
2009-present.
• International Symposium on Low Power Electronics and Design (ISLPED), 2007-present.
• International Conference on Hardware/Software Codesign and System Synthesis (CODES+ISSS),
2003-present.
• ACM Student Research Competition at DAC, 2010.
• Special Interest Group on Design Automation (SIGDA) Ph.D. Forum at Design Automation Conference
(DAC), 2005-2008.
• International Conference on Embedded Software and Systems (ICESS), 2008.
• International Workshop on Embedded Single and Multicore Systems on Chips (MCSoC), 2007.
• International Workshop on Embedded Software Optimization (ESO), 2006.
• International Workshop on Logic and Synthesis (IWLS), 2004-2006.
• International Workshop on SoC and MCSoC Design (SoC), 2006.
• International Workshop on Embedded Computing (EC), 2006.
• International Conference on Embedded And Ubiquitous Computing (EUC), 2005.
• International Conference on Compilers, Architecture, and Synthesis for Embedded Systems (CASES),
2005.
• International Conference on Computer Aided Design (ICCAD), 2003, 2004, 2005.
• Asia and South Pacific Design Automation Conference (ASP-DAC), 2003.
• International Workshop on Embedded System Codesign (ESCODES), 2002.
2

Topic Chair
• Embedded Software: International Conference on Hardware/Software Codesign and System Synthesis
(CODES+ISSS), 2006.
• Micro-Architecture and Memory Optimizations: International Conference on Hardware/Software Codesign and System Synthesis (CODES+ISSS), 2005.
• System-Level Optimization: International Conference on Hardware/Software Codesign and System
Synthesis (CODES+ISSS), 2004.

Session Chair
• International Conference on Hardware/Software Codesign and System Synthesis (CODES+ISSS), 2009.
• International Conference on Architecture, Compilers, and Synthesis for Embedded Systems (CASES),
2009.
• Design Automation Conference (DAC), 2009.
• Design Automation Conference (DAC), 2008.
• Design Automation and Test in Europe (DATE), 2008.
• Design Automation Conference (DAC), 2007.
• International Conference on Compilers, Architecture, and Synthesis for Embedded Systems (CASES),
2005.
• International Conference on Hardware/Software Codesign and System Synthesis (CODES+ISSS), 2005.
• International Symposium on Low Power Electronics and Design (ISLPED), 2005.
• International Conference on Computer Aided Design (ICCAD), 2005.
• International Conference on Computer Aided Design (ICCAD), 2004.
• International Conference on Computer Aided Design (ICCAD), 2003.
• International Workshop on Hardware/Software Codesign (CODES), 2002.
• International Workshop on Embedded System Codesign (ESCODES), 2002.
• International Conference on Computer Aided Design (ICCAD), 2001.

Conference Organizer
• Finance Chair, Embedded Systems Week (ESWEEK), 2008.
• Finance Chair, International Symposium on Low Power Electronics and Design (ISLPED), 2007.
• Student Travel Grants Chair, International Conference on Supercomputing (ICS), 2006.
• Web Chair, International Symposium on Low Power Electronics and Design (ISLPED), 2006.
• Audio Visual Chair, International Conference on Hardware/Software Codesign and System Synthesis
(CODES+ISSS), 2006.
• Finance Chair, Special Interest Group on Design Automation (SIGDA) Ph.D. Forum at Design Automation Conference (DAC), 2005.
3

• Publicity Chair, International Conference on Hardware/Software Codesign and System Synthesis (CODES+ISSS),
2004.
• Poster Committee Chair, Southern California Embedded Systems Symposium (SCESS), 2003.
• Local Chair and Treasurer, International Conference on Hardware/Software Codesign and System
Synthesis (CODES+ISSS), 2003.
• Local Chair, International Workshop on Languages, Compilers, and Tools for Embedded Systems
(LCTES), 2003.
• Finance and Registration Co-Chair, International Symposium on High Performance Computer Architecture (HPCA), 2003.

Reviewer & Panelist
• National Science Foundation (NSF).
• Kentucky Science & Engineering Foundation (KSEF).
• University of California Microelectronics Innovation and Computer Research Opportunities (UC-MICRO).
• Council of Physical Sciences of the Netherlands Organization for Scientific Research (NWO).
• IEEE Computer.
• IEEE Transactions on Computers (TC).
• IEEE Transactions on Computer Aided Design (TCAD).
• IEEE Transactions on Very Large Scale Integration Systems (TVLSI).
• IEEE Transactions on Design & Test of Computers (TD&T).
• IEEE Transactions on Circuits and Systems II (TCAS-II).
• ACM Transactions on Embedded Computing Systems (TECS).
• ACM Transactions on Design Automation of Electronic Systems (TODAES).
• IEE Proceedings - Computers and Digital Techniques (IEE-C&DT).
• Springer Design Automation for Embedded Systems (SDAES).
• Cluwer Design Automation for Embedded Systems (CDAES).
• Elsevier Journal of Microprocessors and Microsystems (MICPRO).
• Elsevier Journal of System Architecture (JSA).
• Asia and South Pacific Design Automation Conference (ASP-DAC).
• Design Automation Conference (DAC).
• International Conference on Computer Aided Design (ICCAD).
• International Conference on Hardware/Software Codesign and System Synthesis (CODES+ISSS).
• International Symposium on Micro-architecture (MICRO).
• International Workshop on Compilers, Architecture, and Synthesis for Embedded Systems (CASES).
• International Workshop on Logic and Synthesis (IWLS).
4

University
• Member, University Committee on Computing and Communications (UCCC), 2007-2010.

Campus
• Member, Council on Research, Computing and Library Resources (CORCLR), 2007-2010.
• Chair, Faculty Board for Undecided/Undeclared Students: A Board of the Council on Educational
Policy, 2003-2007.

School
• Associate Dean, ICS Student Affairs, 2011-present.
• Chair, ICS Strategic Planning: Graduate Education Group, 2011-2012.
• Member, Task Force on ICS First Year Curriculum, 2010-2011.
• Chair, Task Force on the CS Major, 2010-2011.
• Member, Computer Science Chair Recommendation Committee, 2009-2010.
• Chair, Computing & Network Policy, 2009-2010.
• Member, Computing & Network Policy, 2008-2009.
• Member, CS&E Steering Committee, 2003-2006.
• Member, DARPA Grand Challenge Team eXtreme Anteater Racers (XAR) Group, 2004-2005.
• Member, Entrepreneurship Committee, 2004-2005.
• Member, Executive Committee, 2003-2004.
• Member, Transition Committee, 2003-2004.
• Member, Faculty Recruit Committee (Ubiquitous Computing), 2003-2004.
• Member, Faculty Recruit Committee (Embedded Systems), 2002-2003.
• Member, CS Degree Program Committee, 2002-2003.
• Member, Graduate Recruit & Admissions Committee, 2002-2003.
• Member, CS&E Degree Program Committee, 2001-2002.

Awards
• NSF Grant (#1136146), National Science Foundation, $1.5M, 2011.
• ASEE ECE Division Hewlett-Packard Frederick Emmons Terman Award, 2011.
• NSF Grant (#1016789), National Science Foundation, $200K, 2010.
• ICS Dean’s Award for Excellence in Undergraduate Teaching, University of California, Irvine, 2010.
• NSF Grant (#0837124), National Science Foundation, $70K, 2009.

5

• Best Paper, International Conference on Compilers, Architecture, and Synthesis for Embedded Systems
(CASES), 2008.
• Research & Travel Award, Council on Research, Computing, and Library Resources (CORCLR), University of California, Irvine, 2007.
• NSF Grant (#0749508), National Science Foundation, $200K, 2007.
• Faculty Desktop Computing Initiative Award, University of California, Irvine, 2007.
• SIGDA Technical Leadership Award, American Computing Machinery (ACM), 2007.
• Best Paper, American Control Conference (ACC), 2006.
• Best Paper, ACM Transactions on Design Automation of Electronic Systems (TODAES), 2006.
• Research & Travel Award, Council on Research, Computing, and Library Resources (CORCLR), University of California, Irvine, 2005.
• Collaborative Research Initiation Award (CRIA), School of Information and Computer Sciences, University of California, Irvine, 2005.
• Chancellor’s Award for Excellence in Fostering Undergraduate Research, University of California,
Irvine, 2005.
• Research & Travel Grant, School of Information and Computer Sciences, University of California,
Irvine, 2004.
• Ted & Janice Smith Faculty Seed Funding Award, 2004.
• Discovery Grant, University of California, 2003.
• Research Grant, Microsoft Corporation & University of California MICRO Matching Funds, 2003.
• Excellence in Teaching Award, Instructional Resource Center/Division of Undergraduate Education,
University of California, Irvine, 2003.
• Research & Travel Grant, School of Information and Computer Science, University of California, Irvine,
2003.
• Equipment Donation, Xilinx University Program, 2002.
• NSF ITR Grant, National Science Foundation, 2002.
• Research & Travel Grant, School of Information and Computer Sciences, University of California,
Irvine, 2002.
• Equipment Donation, Xilinx University Program, 2001.
• Outstanding Ph.D. Thesis, Department of Computer Science & Engineering, University of California,
Riverside, 2001.
• Best Paper, Design Automation and Test in Europe (DATE), 2000.
• GAANN Fellowship, Department of Computer Science & Engineering, University of California, Riverside, 1998.
• Graduate Scholarship, Design Automation Conference, 1998.
• Scholarship, International Council on Systems Engineering Inland Empire, 1997.
6

• MICRO Fellowship, Department of Computer Science & Engineering, University of California, Riverside, 1997.
• Outstanding Student Award, College of Engineering, University of California, Riverside, 1997.
• Outstanding Academic Program Excellence, Honors Convocations, University of California, Riverside,
1997.

Presentations
Tutorials
• ESL Design: Why the Time is Right and What are the Key Enabling Technologies. IEEE International
Conference on Computer Aided Design (ICCAD) 2005.
• New Developments in Embedded System Design: Software for Embedded System. IEEE International
Conference on Computer Design (ICCD) 2005.

Patents
Issued
P.9 A. Nacul, T. Givargis. Phantom Serializing Compiler and Method of Operation of Same. United States
Patent, 7,886,283 , February 2011.
P8. J. Addink, S. Addink, T. Givargis. Methods and apparatus for using water use signatures and water
pressure in improving water use efficiency. United States Patent 7,330,796, February 2008.
P7. J. Addink, S. Addink, T. Givargis. Methods and Apparatus for Using Water use Signatures in Improving Water use Efficiency. United States Patent 6,963,808, November 2005.
P6. J. Addink, T. Givargis. Interactive Irrigation System. United States Patent 6,950,728, September
2005.
P5. J. Addink, K. Buhler, T. Givargis. Modifying Irrigation Schedules of Existing Irrigation Controllers.
United States Patent 6,892,114, May 2005.
P4. J. Henkel, T. Givargis, F. Vahid. Method for Core-Based System-Level Power Modeling using ObjectOriented Techniques. United States Patent 6,865,526, March 2005.
P3. K. Buhler, T. Givargis. Two Tire Irrigation Valve Controller. United States Patent 6,812,826, November 2004.
P2. J. Addink, T. Givargis. Detecting Weather Sensor Malfunctions. United States Patent 6,714,134,
March 2004.
P1. J. Addink, K. Buhler, T. Givargis. Irrigation Accumulation Controller. United States Patent 6,298,285,
October 2001.

7

Publications
Book
B3. F. Vahid, T. Givargis. Programming Embedded Systems - An Introduction to Time-Oriented Programming. UniWorld Publishing, July 2010. www.programmingembeddedsystems.com.
B2. A. Nacul, M. Lajolo, T. Givargis. Interface-Centric Abstraction level for Rapid Hardware/Software
Integration, Book Chapter in Applications of Specification And Design Languages for SOCs. Springer,
ISBN: 1-4020-4997-8, July 2006.
B1. F. Vahid, T. Givargis. Embedded System Design: A Unified Hardware/Software Introduction. John
Wiley and Sons, ISBN: 0471386782, October 2001.

Journal
J20. C. Huang, F. Vahid, and T. Givargis. A Custom FPGA Processor for Physical Model Ordinary
Differential Equation Solving. IEEE Embedded Systems Letters, to appear.
J19. S. Choudhuri, T. Givargis. Deterministic Service Guarantees for NAND Flash using Partial Block
Cleaning. Academy Publisher Journal of Software (JSW), vol. 4, no. 7, pp. 728-737, September 2009.
J18. M.A. Ghodrat, T. Givargis, A. Nicolau. Optimizing Control Flow in Loops using Interval and Dependence Analysis. Springer Journal on Design Automation of Embedded Systems (DAES), vol. 13, no.
3, pp. 193-221, September 2009.
J17. S. Sirowy, D. Sheldon, T. Givargis, F. Vahid. Virtual Microcontrollers. ACM SIGBED Review, vol.
6, no. 1, January 2009.
J16. A. Nacul, T. Givargis. Synthesis of Time-Constrained Multitasking Embedded Software. ACM Transactions on Design Automation of Electronic Systems (TODAES), vol. 11, no. 4, pp. 822-847, October
2006.
J15. M.A. Ghodrat, T. Givargis, A. Nicolau. Expression Equivalence Checking using Interval Analysis.
IEEE Transactions on Very Large Scale Integration Systems (TVLSI), vol. 14, no. 8, pp. 830-842,
August 2006.
J14. C.V. Lopes, A. Haghighat, A. Mandal, T. Givargis, P. Baldi. Localization of Off-the-Shelf Mobile
Devices Using Audible Sound: Architectures, Protocols and Performance Assessment. ACM Mobile
Computing and Communications Review (MC2R), vol. 10, no. 2, pp. 38-50, April 2006.
J13. T. Givargis. Zero Cost Indexing for Improved Processor Cache Performance. ACM Transactions on
Design Automation of Electronic Systems (TODAES), vol. 11, no. 1, pp. 3-25, January 2006. Received
the 2006 TODAES Best Paper Award.
J12. T. Givargis, David Eppstein. Memory Reference Caching for Activity Reduction on Address Buses.
Elsevier Journal of Microprocessors and Microsystems (MICPRO), vol. 29, no. 4, pp. 145-153, May
2005.
J11. A. Ghosh, T. Givargis. Cache Optimization for Embedded Processor Cores: An Analytical Approach.
ACM Transactions on Design Automation of Electronic Systems (TODAES), vol. 9, no. 4, pp. 419-440,
October 2004.
J10. A. Nacul, T. Givargis. Adaptive Cache Management for Low Power Embedded Systems. Korea
Multimedia Society, Key Technology of Next Generation IT, ISSN 1229-778X, pp. 30-39, December
2003.

8

J9. T. Givargis, F. Vahid, J. Henkel. Instruction-Based System-level Power Evaluation of System-on-aChip Peripheral Cores. IEEE Transactions on Very Large Scale Integration Systems (TVLSI), vol. 10,
no. 6, pp. 856-863, December 2002.
J8. T. Givargis, F. Vahid, J. Henkel. System-Level Exploration for Pareto-Optimal Configurations in Parameterized System-on-a-Chip. IEEE Transactions on Very Large Scale Integration Systems (TVLSI),
vol. 10, no. 4, pp. 416-422, December 2002.
J7. T. Givargis, F. Vahid. Platune: A Tuning Framework for System-on-a-Chip Platforms. IEEE Transactions on Computer Aided Design (TCAD), vol. 21, no. 11, pp. 1317-1327, November 2002.
J6. F. Vahid, T. Givargis, S. Cotterell. Power Estimator Development for Embedded System Memory
Tuning. Journal of Circuits, Systems, and Computers (JCSC), vol. 11, no. 5, pp. 459-476, October
2002.
J5. T. Givargis, F. Vahid. Tuning of Cache Ways and Voltage for Low-Energy Embedded System Platforms. Springer Journal on Design Automation of Embedded Systems, vol. 7, issue 1-2, pp. 35-51,
September 2002.
J4. T. Givargis, F. Vahid, J. Henkel. Evaluating Power Consumption of Parameterized Cache and Bus Architectures in System-on-a-Chip Designs. IEEE Transactions on Very Large Scale Integration Systems
(TVLSI), vol. 9, no. 4, pp. 500-508, August 2001.
J3. F. Vahid, T. Givargis. Platform Tuning for Embedded Systems Design. IEEE Computer, vol. 34, no.
3, pp. 112-114, March 2001.
J2. J. Farrell, T. Givargis, M. Barth. Real-Time Differential Carrier Phase GPS-Aided INS. IEEE Transactions on Control Systems Technology (TCST), vol. 8, no. 4, pp. 709-721, July 2000.
J1. J. Farrell, T. Givargis. Differential GPS Reference Station Algorithm - Design and Analysis. IEEE
Transactions on Control Systems Technology (TCST), vol. 8, no. 3, pp. 519-531, May 2000.

Conference
C47. B. Miller, F. Vahid, T. Givargis. Demonstration of Digital Mockups for the Testing of a Medical
Ventilator. ACM SIGHIT International Health Informatics Symposium (IHIS), to appear.
C46. B. Miller, F. Vahid, T. Givargis. Application-Specific Codesign Platform Generation for Digital Mockups in Cyber-Physical Systems. Electronic System Level Synthesis Conference (ESLsyn), to appear.
C45. M.A. Ghodrat, T. Givargis. Efficient Dynamic Voltage/Frequency Scaling through Algorithmic Loop
Transformation. International Conference on Hardware/Software Codesign and System Synthesis
(CODES+ISSS), pp. 203-209, Grenoble, October 2009.
C44. S. Sirowy, F. Vahid, T. Givargis. Digitally-Bypassed Transducers: Interfacing Digital Mockups to
Real-Time Medical Equipment. International Conference of the IEEE Engineering in Medicine and
Biology Society (EMBS), pp. 919-922, Minneapolis, September 2009.
C43. A. Ghosh, T. Givargis. Source Routing made Practical in Embedded Networks. International Conference on Computer Communications and Networks (ICCCN), pp. 1-6, San Francisco, August 2009.
C42. A. Ghosh, T. Givargis. QoS Routing in Wired Sensor Networks with Partial Updates. World Academy
of Science, Engineering and Technology (WASED), pp. 389-393, Oslo, July 2009.
C41. S.K. Mylavarapu, S. Choudhuri, A. Shrivastava, J. Lee, T. Givargis. FSAF: File System Aware Flash
Translation Layer for NAND Flash Memories. Design Automation and Test in Europe (DATE), pp.
339-344, Dresden, April 2009.
9

C40. S. Choudhuri, T. Givargis. FlashBox: A system for logging non-deterministic events in deployed
embedded systems. International ACM Symposium on Applied Computing (SAC), pp. 1676-1682,
Honolulu, March 2009.
C39. M.A. Ghodrat, T. Givargis, A. Nicolau. Control Flow Optimization in Loops using Interval Analysis.
International Conference on Compilers, Architecture, and Synthesis for Embedded Systems (CASES),
pp. 157-166, Atlanta, October 2008. Received the 2008 CASES Best Paper Award.
C38. F. Vahid, T. Givargis. Timing is Everything - Embedded Systems Demand Early Teaching of Structured Time-Oriented Programming. Workshop on Embedded Systems Education (WESE), Atlanta,
October 2008.
C37. S. Sirowy, D. Sheldon, T. Givargis, F. Vahid. Virtual Microcontrollers. Workshop on Embedded
Systems Education (WESE), Atlanta, October 2008.
C36. F. Vahid, T. Givargis. Highly-Cited Ideas in System Codesign and Synthesis. International Conference
on Hardware/Software Codesign and System Synthesis (CODES+ISSS), pp. 191-196, Atlanta, October
2008.
C35. S. Choudhuri, T. Givargis. Deterministic Service Guarantees for NAND Flash using Partial Block
Cleaning. International Conference on Hardware/Software Codesign and System Synthesis (CODES+ISSS),
pp. 19-24, Atlanta, October 2008.
C34. S. Choudhuri, T. Givargis. Real-Time Access Guarantees for NAND Flash using Partial Block Cleaning. Workshop on Software Technologies for Future Embedded & Ubiquitous Systems (SEUS), pp.
138-149, Italy, September 2008.
C33. A. Ghosh, T. Givargis. A Software Architecture for Accessing Data in Sensor Networks. International
Conference on Networked Sensing Systems (INSS), pp. 67-70, Japan, June 2008.
C32. S. Choudhuri, T. Givargis. Performance Improvement of Block Based NAND Flash Translation Layer.
International Conference on Hardware/Software Codesign and System Synthesis (CODES+ISSS), pp.
257-262, Salzburg, September 2007.
C31. M.A. Ghodrat, T. Givargis., A. Nicolau. Short-Circuit Compiler Transformation: Optimizing Conditional Blocks. Asia and South Pacific Design Automation Conference (ASP-DAC), pp. 504-510,
Tokyo, January 2007.
C30. S. Choudhuri, T. Givargis. System Architecture for Software Peripherals. Asia and South Pacific
Design Automation Conference (ASP-DAC), pp. 56-61, Tokyo, January 2007.
C29. A. Nacul, T. Givargis. Phantom: A Serializing Compiler for Multitasking Embedded Software. American Control Conference (ACC), pp. 1918-1923, Minneapolis, June 2006. Received the 2006 ACC Best
Paper Award.
C28. M.A. Ghodrat, T. Givargis, A. Nicolau. Equivalence Checking of Arithmetic Expressions using Fast
Evaluation. International Conference on Compilers, Architecture, and Synthesis for Embedded Systems
(CASES), pp. 147-156, San Francisco, September 2005.
C27. A. Nacul, T. Givargis. Lightweight Multitasking Support for Embedded Systems using the Phantom
Serializing Compiler. Design Automation and Test in Europe (DATE), pp. 742-747, Munich, March
2005.
C26. A. Ghosh, T. Givargis. LORD: A Localized, Reactive and Distributed Protocol for Node Scheduling
in Wireless Sensor Networks. Design Automation and Test in Europe (DATE), pp. 190-195, Munich,
March 2005.

10

C25. A. Mandal, C.V. Lopes, T. Givargis, A. Haghighat, R. Jurdak, P. Baldi. Beep: 3D Indoor Positioning
Using Audible Sound. IEEE Consumer Communications and Networking Conference (CCNC), pp.
348-353, Las Vegas, January 2005.
C24. A. Nacul, T. Givargis. Code Partitioning for Synthesis of Embedded Applications with Phantom.
International Conference on Computer-Aided Design (ICCAD), pp. 190-196, San Jose, November
2004.
C23. A. Nacul, T. Givargis. Dynamic Voltage and Cache Reconfiguration for Low Power. Design Automation
and Test in Europe (DATE), pp. 1376-1377, Paris, February 2004.
C22. M. Buss, T. Givargis, N. Dutt. Exploring Efficient Operating Points for Voltage Scaled Embedded
Processor Cores. Real-Time Systems Symposium (RTSS), pp. 275-281, Cancun, December 2003.
C21. A. Ghosh, T. Givargis. Cache Optimization for Embedded Processor Cores: An Analytical Approach.
International Conference on Computer-Aided Design (ICCAD), pp. 342-347, San Jose, November 2003.
C20. T. Givargis. Improved Indexing for Cache Miss Reduction in Embedded Systems. Design Automation
Conference (DAC), pp. 872-880, Anaheim, June 2003.
C19. A. Ghosh, T. Givargis. Analytical Design Space Exploration of Caches for Embedded Systems. Design
Automation and Test in Europe (DATE), pp. 650-655, Munich, March 2003.
C18. T. Givargis, D. Eppstein. Reference Caching Using Unit Distance Redundant Codes for Activity Reduction on Address Buses. International Workshop on Embedded System Hardware/Software Codesign
(ESCODES), San Jose, September 2002.
C17. M. Palesi, T. Givargis. Multi-Objective Design Space Exploration Using Genetic Algorithms. International Workshop on Hardware/Software Codesign (CODES), Estes Park, May 2002.
C16. T. Givargis, F. Vahid, J. Henkel. System-Level Exploration for Pareto-Optimal Configurations in
Parameterized Systems-on-a-Chip. International Conference on Computer-Aided Design (ICCAD),
San Jose, November 2001.
C15. T. Givargis, F. Vahid. J. Henkel. Trace-Driven System-Level Power Evaluation of System-on-a-Chip
Peripheral Cores. Asia and South Pacific Design Automation Conference (ASP-DAC), Yokohama,
January 2001.
C14. G. Stitt, F. Vahid, T. Givargis, R. Lysecky. A First-Step Towards an Architecture Tuning Methodology.
International Conference on Compilers, Architecture, and Synthesis for Embedded Systems (CASES),
San Jose, November 2000.
C13. T. Givargis, F. Vahid, J. Henkel. Instruction-Based System-Level Power Evaluation of System-ona-Chip Peripheral Cores. International Symposium on System Synthesis (ISSS), Madrid, September
2000.
C12. R. Lysecky, F. Vahid, T. Givargis. Experiments with the Peripheral Virtual Component Interface.
International Symposium on System Synthesis (ISSS), Madrid, September 2000.
C11. T. Givargis, F. Vahid. Parameterized System Design. International Workshop on Hardware/Software
Codesign (CODES), San Diego, May 2000.
C10. T. Givargis, F. Vahid, J. Henkel. Fast Cache and Bus Power Estimation for Parameterized Systemon-a-Chip Design. Design Automation and Test in Europe (DATE), Paris, March 2000.
C9. R. Lysecky, F. Vahid, T. Givargis. Techniques for Reducing Read Latency of Core Bus Wrappers.
Design Automation and Test in Europe (DATE), Paris, March 2000. Received the 2000 DATE Best
Paper Award.
11

C8. T. Givargis, F. Vahid. J. Henkel. A Hybrid Approach for Core-Based System-Level Power Modeling.
Asia and South Pacific Design Automation Conference (ASPDAC), Yokohama, January 2000.
C7. T. Givargis, J. Henkel, F. Vahid. Interface and Cache Power Exploration for Core- Based Embedded
System Design. International Conference on Computer-Aided Design (ICCAD), San Jose, November
1999.
C6. R. Lysecky, F. Vahid, T. Givargis, R. Patel. Pre-Fetching for Improved Core Interfacing. International
Symposium on System Synthesis (ISSS), San Jose, November 1999.
C5. J. Farrell, T. Givargis. Experimental Differential GPS Reference Station Evaluation. American Control
Conference (ACC), San Diego, June 1999.
C4. J. Farrell, T. Givargis. M. Barth. Differential Carrier Phase GPS-Aided INS for Automotive Applications. American Control Conference (ACC), San Diego, June 1999.
C3. F. Vahid, T. Givargis. The Case for a Configure-and-Execute Paradigm. International Workshop on
Hardware/Software Codesign (CODES), Rome, May 1999.
C2. F. Vahid, T. Givargis. Incorporating Cores into System-Level Specification. International Symposium
on System Synthesis (ISSS), Hsinchu, December 1998.
C1. T. Givargis, F. Vahid. Interface Exploration for Reduced Power in Core-Based Systems. International
Symposium on System Synthesis (ISSS), Hsinchu, December 1998.

Workshop
W2. A. Nacul, M. Lajolo, T. Givargis. Interface-Centric Abstraction Level for Rapid Hardware/Software
Integration. Forum on Specification and Design Languages (FDL), Lausanne, September 2005.
W1. A. Haghighat, C. Lopes, T. Givargis, and A. Mandal. Location-Aware Web System. Workshop on
Building Software for Pervasive Computing at the Object-Oriented Programming, Systems, Languages
and Applications (OOPSLA) Conference, Vancouver, October 2004.

Miscellaneous
M1. U. Brinkschulte, M. Cinque, T. Givargis, S. Russo. Guest Editorial. Journal of Software, vol. 4, no.
7, pp. 631-633, Septempber 2009.

Affiliated Students
Ph.D. Final Defense Committee Chair
• Mohammad Ali Ghodrat, Department of Computer Science, University of California, Irvine, 9/1/2009.
• Siddharth Choudhuri, Department of Computer Science, University of California, Irvine, 1/5/2009.
• Arijit Ghosh, Department of Computer Science, University of California, Irvine, 07/09/2008.
• Andre Nacul, Department of Computer Science, University of California, Irvine, 04/23/2007.

12

Ph.D. Final Defense Committee Member
• Michael Bebenita, Department of Computer Science, University of California, Irvine, 10/11/2011.
• Jinsik Kim, Department of Electrical Engineering & Computer Science, University of California, Irvine,
05/18/2010.
• Yonghyun Hwang, Department of Computer Science, University of California, Irvine, 12/16/2009.
• Babak Salamat, Department of Computer Science, University of California, Irvine, 06/8/2009.
• Aseem Gupta, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 05/29/2009.
• Gabor Madl, Department of Computer Science, University of California, Irvine, 05/27/2009.
• Love Singhal, Department of Computer Science, University of California, Irvine, 01/13/2009.
• Lei Zhou, Department of Electrical Engineering & Computer Science, University of California, Irvine,
12/03/2008.
• Seung-Eun Lee, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 12/03/2008.
• Minyoung Kim, Department of Computer Science, University of California, Irvine, 7/8/2008.
• Jun Ho Bahn, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 12/20/2007.
• Daniel Jesus Valencia Sanchez, Department of Computer Science, University of California, Irvine,
09/10/2007.
• Chen Liu, Department of Electrical Engineering & Computer Science, University of California, Irvine,
08/03/07.
• Vasanth Venkatachalam, Department of Computer Science, University of California, Irvine, 5/14/2007.
• Ning Wang, Department of Computer Science, University of California, Irvine, 5/14/2007.
• Kiran Ramineni, Department of Computer Science, University of California, Irvine, 3/13/2007.
• Shireesh Verma, Department of Computer Science, University of California, Irvine, 2/26/2007.
• Ilya Issenin, Department of Computer Science, University of California, Irvine, 12/06/2006.
• Hooman Parizi, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 11/14/2006.
• Partha Biswas, Department of Computer Science, University of California, Irvine, 03/02/2006.
• Samar Abdi, Department of Computer Science, University of California, Irvine, 11/28/2005.
• Chengzhi Pan, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 09/07/2005.
• Haobo Yu, Department of Computer Science, University of California, Irvine, 11/30/2004.
• Shean McMahon, Department of Computer Science, University of California, Irvine, 11/01/2004.
• Mahesh Naga Mamidipaka, Department of Computer Science, University of California, Irvine, 08/23/2004.
• Dongwan Shin, Department of Computer Science, University of California, Irvine, 04/16/2004.
• Junyu Peng, Department of Computer Science, University of California, Irvine, 04/02/2004.
13

Ph.D. Qualifying Exam Committee Chair
• Siddharth Choudhuri, Department of Computer Science, University of California, Irvine, 12/21/2006.
• Mohammad Ali Ghodrat, Department of Computer Science, University of California, Irvine, 03/25/2005.
• Arijit Ghosh, Department of Computer Science, University of California, Irvine, 09/14/2004.
• Andre Nacul, Department of Computer Science, University of California, Irvine, 05/26/2004.

Ph.D. Qualifying Exam Committee Member
• Mehryar Rahmatian, Department of Computer Science, University of California, Irvine, 9/16/2010.
• Deepak Mishra, Department of Computer Science, University of California, Irvine, 9/15/2010.
• Dali Zhao, Department of Computer Science, University of California, Irvine, 9/2/2010.
• Tae Su Kim, Department of Computer Science, University of California, Irvine, 3/19/2010.
• Zhiming Chen, Department of Computer Science & Engineering, University of California, Riverside,
12/10/2009.
• Hessam Kooti, Department of Computer Science, University of California, Irvine, 12/7/2009.
• Vahid Salmani, Department of Computer Science & Engineering, University of California, Riverside,
12/2/2009.
• Marcelo Cintra, Department of Computer Science, University of California, Irvine, 11/17/2009.
• Patricia Lee, Department of Computer Science, University of California, Irvine, 9/18/2009.
• Rosario Cammarota, Department of Computer Science, University of California, Irvine, 9/17/2009.
• Kazuyuki Tanimura, Department of Computer Science, University of California, Irvine, 9/3/2009.
• Matthew Badin, Department of Computer Science, University of California, Irvine, 6/4/2009.
• Michael Bebenita, Department of Computer Science, University of California, Irvine, 5/29/2009.
• Mason Chang, Department of Computer Science, University of California, Irvine, 5/27/2009.
• Sangwon Chae, Department of Computer Science, University of California, Irvine, 12/09/2008.
• Wendy Zhang, Department of Computer Science, University of California, Irvine, 12/08/2008.
• Fred Tzeng, Department of Computer Science & Engineering, University of California, Riverside,
1/31/2008.
• Minyoung Kim, Department of Computer Science, University of California, Irvine, 01/15/2008.
• AmirHossein GholamiPour, Department of Computer Science, University of California, Irvine, 12/11/2007.
• Shahin Golshan, Department of Computer Science, University of California, Irvine, 12/10/2007.
• Scott Hendrickson, Department of Informatics, University of California, Irvine, 11/16/2007.
• David Sheldon, Department of Computer Science & Engineering, University of California, Riverside,
10/24/2007.

14

• Scott Sirowy, Department of Computer Science & Engineering, University of California, Riverside,
10/24/2007.
• Yonghyun Hwang, Department of Computer Science, University of California, Irvine, 09/19/2007.
• Zhen Zhang, Department of Computer Science, University of California, Irvine, 09/4/2007.
• Jing Qian, Department of Electrical Engineering & Computer Science, University of California, Irvine,
09/4/2007.
• Babak Salamat, Department of Computer Science, University of California, Irvine, 05/15/2007.
• Sudeep Pasricha, Department of Computer Science, University of California, Irvine, 02/07/2007.
• Deyi Pi, Department of Electrical Engineering & Computer Science, University of California, Irvine,
12/5/2006.
• Seung Eun Lee, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 12/1/2006.
• Jayram Nageswaran, Department of Computer Science, University of California, Irvine, 11/14/2006.
• Gabor Madl, Department of Computer Science, University of California, Irvine, 09/06/2006.
• Lei Zhou, Department of Electrical Engineering & Computer Science, University of California, Irvine,
06/16/2006.
• Love Singhal, Department of Computer Science, University of California, Irvine, 06/12/2006.
• Ilya Issenin, Department of Computer Science, University of California, Irvine, 05/23/2006.
• Sevin Fide, Department of Electrical Engineering & Computer Science, University of California, Irvine,
05/16/2006.
• Farzad Etemadi, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 04/13/2006.
• Vasanth Venkatachalam, Department of Computer Science, University of California, Irvine, 04/11/2006.
• Jiwon Hahn, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 03/28/2006.
• Ersin Sengul, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 03/08/2006.
• Daniel Jesus Valencia Sanchez, Department of Computer Science, University of California, Irvine,
02/24/2006.
• Hooman Torabi Parizi, Department of Electrical Engineering & Computer Science, University of California, Irvine, 12/15/2005.
• Afshin Niktash, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 12/13/2005.
• Jun Ho Bahn, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 12/7/2005.
• Chulsung Park, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 12/6/2005.
15

• Aseem Gupta, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 09/14/2005.
• Gunar Schirner, Department of Computer Science, University of California, Irvine, 09/06/2005.
• Pramod Chandraiah, Department of Electrical Engineering & Computer Science, University of California, Irvine, 09/06/2005.
• Yan Huang, Department of Computer Science, University of California, Irvine, 08/24/2005.
• Partha Biswas, Department of Computer Science, University of California, Irvine, 06/13/2005.
• Jiming Liu, Department of Computer Science, University of California, Irvine, 05/06/2005.
• Pablo Diaz Gutierrez, Department of Computer Science, University of California, Irvine, 03/24/2005.
• Srinivas Vadlamani, Department of Electrical Engineering & Computer Science, University of California, Irvine, 03/16/2005.
• Rafael Lopez, Department of Computer Science, University of California, Irvine, 02/02/2005.
• Kiran Ramineni, Department of Computer Science, University of California, Irvine, 12/09/2004.
• Seung-mok Yoo, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 12/07/2004.
• Chen Liu, Department of Electrical Engineering & Computer Science, University of California, Irvine,
11/30/2004.
• Ashish Bhargave, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 11/2005/2004.
• Cristian Petrescu-Prahova, Department of Computer Science, University of California, Irvine, 09/13/2004.
• Shireesh Verma, Department of Computer Science, University of California, Irvine, 09/09/2004.
• Chris Fensch, Department of Computer Science, University of California, Irvine, 09/08/2004.
• Ning Wang, Department of Computer Science, University of California, Irvine, 09/01/2004.
• Enis Akay, Department of Electrical Engineering & Computer Science, University of California, Irvine,
06/2004/2004.
• Amir Kamalizad, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 06/03/2004.
• Deepak Chandra, Department of Computer Science, University of California, Irvine, 03/30/2004.
• Chunhui Zhang, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 03/15/2004.
• David Lee, Department of Chemistry, University of California, Irvine, 05/07/2003.
• Jinfeng Liu, Department of Electrical Engineering & Computer Science, University of California, Irvine,
03/20/2003.
• Mehrdad Reshadi, Department of Computer Science, University of California, Irvine, 03/19/2003.
• Chengzhi Pan, Department of Electrical Engineering & Computer Science, University of California,
Irvine, 03/12/2003.
16

• Samar Abdi, Department of Computer Science, University of California, Irvine, 09/12/2002.
• Marcio Dias, Department of Informatics, University of California, Irvine, 06/03/2002.
• Chris L¨er, Department of Informatics, University of California, Irvine, 05/14/2002.
u
• Dongwan Shin, Department of Computer Science, University of California, Irvine, 09/20/2001.
• John Xie, Department of Computer Science, University of California, Irvine, 09/20/2001.
• Haobo Yu, Department of Computer Science, University of California, Irvine, 09/20/2001.
• Junyu Peng, Department of Computer Science, University of California, Irvine, 09/14/2001.

Undergraduate Research Opportunities Program (UROP) Faculty Mentor
• Manish Sinha, Information & Computer Sciences, University of California, Irvine, 2007.
• Hussien Sleiman, Information & Computer Sciences, University of California, Irvine, 2005.
• Luis Angel, Information & Computer Sciences, University of California, Irvine, 2005.
• Martin Yasin, Information & Computer Sciences, University of California, Irvine, 2005.
• Anton Popov, Information & Computer Sciences, University of California, Irvine, 2005.
• Nick Mangano, Information & Computer Sciences, University of California, Irvine, 2005.
• Harvey Herela, Information & Computer Sciences, University of California, Irvine, 2005.
• Chad Christensen, Information & Computer Sciences, University of California, Irvine, 2005.
• Adam Wasserstrom, Information & Computer Sciences, University of California, Irvine, 2005.
• Lu Q Zheng, Information & Computer Sciences, University of California, Irvine, 2005.
• Ray Shen, Information & Computer Sciences, University of California, Irvine, 2005.
• Long Ting Kan, Information & Computer Sciences, University of California, Irvine, 2005.

Summer Undergraduate Research Program (SURP) Faculty Mentor
• John Liu, Computer Science & Engineering, University of California, Riverside, 2003.
• Kenny Vu, Information & Computer Sciences, University of California, Irvine, 2002.

17