throbber
RF-060915.txt
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` 1 UNCERTIFIED ROUGH DRAFT -- NOT FOR OFFICIAL USE
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` 2 This real-time rough draft transcript is
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` 3 being provided pursuant to Code of Civil Procedure
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` 4 Section 273(b):
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` 5 "The report of the official
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` 6 reporter, or official reporter pro
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` 7 tempore, of any court, duly
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` 8 appointed and sworn, when prepared
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` 9 as a rough draft transcript, shall
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` 10 not be certified and cannot be
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` 11 used, cited, or transcribed as the
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` 12 official certified transcript of
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` 13 the proceedings. A rough draft
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` 14 transcript shall not be cited or
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` 15 used in any way or at any time to
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` 16 rebut or contradict the official
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` 17 certified transcript of the
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` 18 proceedings as provided by the
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` 19 official reporter or official
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` 20 reporter pro tempore. The
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` 21 production of a rough draft
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` 22 transcript shall not be required."
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` 23
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` 24
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` 25
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`MARVELL 1012
`Marvell v. Intellectual Ventures
`IPR2014-00548
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`RF-060915.txt
` 2 SAN DIEGO, CALIFORNIA; TUESDAY, JUNE 9, 2015
`
` 3 9:04 A.M.
`
` 4 -0o0-
`
` 09:04:08 5 ***
`
` 6 THE VIDEOGRAPHER: Good morning.
`
` 7 Here begins Media Number 1 in Volume I of
`
` 8 the deposition of Ghobad Heidari in the matter of
`
` 9 Marvell Semiconductor, Inc., versus Intellectual
`
` 09:04:33 10 Ventures, LLC, which is being heard in the U.S.
`
` 11 Patent and Trademark Office, Patent and Trial Appeal
`
` 12 Board. The case number is IPR2014-00548.
`
` 13 Today's date is June 9, 2015. The time is
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` 14 9:04 a.m. This deposition is being taken at
`
` 09:04:55 15 501 West Broadway, San Diego, California, Suite 600.
`
` 16 Your videographer is Joshua Davis, here on
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` 17 behalf of GregoryEdwards, LLC.
`
` 18 Would all counsel and all present please
`
` 19 identify yourselves and state whom you represent.
`
` 09:05:13 20 MR. MUKERJI: Indranil Mukerji and
`
` 21 David Holt from Fish & Richardson representing
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` 22 petitioner, and with us on the phone is
`
` 23 Professor Zhi Ding.
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` 24 DR. DING: Hello.
`
` 09:05:26 25 MR. VANDER LEEST: Kirk Vander Leest and
` 2
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` 1 UNCERTIFIED ROUGH DRAFT -- NOT FOR OFFICIAL USE
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` 2 James Hietala representing patent owner,
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` 3 Intellectual Ventures, LLC. I introduced him.
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` 4 MR. MUKERJI: Oh.
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`RF-060915.txt
` 09:05:41 5 THE VIDEOGRAPHER: Your court reporter is
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` 6 Dorien Saito, and she will now swear in the witness.
`
` 7 ***
`
` 8 GHOBAD HEIDARI, PH.D.
`
` 9 ***
`
` 09:05:55 10 EXAMINATION
`
` 11 BY MR. MUKERJI:
`
` 12 Q. Good morning sir.
`
` 13 A. Good morning.
`
` 14 Q. Would you state your name.
`
` 09:06:01 15 A. Ghobad Heidari.
`
` 16 Q. And where do you reside?
`
` 17 A. In San Diego.
`
` 18 Q. What's your business address?
`
` 19 A. What was that given?
`
` 09:06:07 20 Q. What is your business address?
`
` 21 A. Oh, business address is 3525 Del Mar
`
` 22 Heights Road, Suite 170 -- 172, San Diego,
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` 23 California.
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` 24 Q. You understand you're under oath today sir?
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` 09:06:21 25 A. Yes.
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` 2 Q. Okay. Have you been deposed before?
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` 3 A. No, I have not.
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` 4 Q. It's a special day for you.
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` 09:06:30 5 The way this works is I'll ask you
`
` 6 questions and you give answers and you're under oath
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` 7 so please do tell the truth.
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` 8 If there's a question you don't understand
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` 9 or you'd like me to rephrase, let me know, and I'll
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` 09:06:42 10 try to accommodate.
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` 11 A. Thank you.
`
` 12 MR. VANDER LEEST: Can I interject this --
`
` 13 is this supposed to be scrolling or do I have to do
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` 14 the realtime can we go off the record.
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` 09:06:55 15 THE VIDEOGRAPHER: We're going off the
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` 16 record the time is 9:06 a.m.
`
` 17 (A brief recess was taken.)
`
` 18 THE VIDEOGRAPHER: We're back on the
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` 19 record. The time is 908 a.m.
`
` 09:08:07 20 BY MR. MUKERJI:
`
` 21 Q. We why discussing just aid few ground rules
`
` 22 if you need a break let me know and I'll try to
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` 23 accommodate is there any ran your testimony today
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` 24 won't be truthful?
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` 09:08:19 25 A. No.
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` 2 Q. You're not on my medication or anything
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` 3 that may impact your ability to testify?
`
` 4 A. No.
`
` 09:08:25 5 Q. Terrific. Now sir I understand you're
`
` 6 appearing in this proceeding as a -- as an expert
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` 7 that is correct?
`
` 8 A. Correct.
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` 9 Q. On behalf of Intellectual Ventures?
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` 09:08:36 10 A. Correct.
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` 11 Q. Are you being paid for your testimony?
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` 12 A. Yes.
`
` 13 Q. How much are you being paid for your
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` 14 testimony?
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` 09:08:43 15 MR. VANDER LEEST: Objection to form.
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` 16 THE WITNESS: I am being paid -- my normal
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` 17 hourly rate.
`
` 18 BY MR. MUKERJI:
`
` 19 Q. Which is how much?
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` 09:08:54 20 A. $300 an hour.
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` 21 Q. Any difference in rate between testifying
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` 22 time and none testifying time?
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` 23 A. Anything to do with testimony is $300.
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` 24 Q. And none testifying is also 300?
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` 09:09:10 25 A. Yes, well -- consulting would be 1250 but
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` 2 as soon as it went into deposition and testifying
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` 3 time it's three.
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` 4 Q. Okay. Now, sir I'm going to put before you
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` 09:09:25 5 what we marked as Heidari 1:
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` 6 MR. MUKERJI: James, would you like a copy
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` 7 or --
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` 8 MR. HEITALA: I don't need one. Thank you.
`
` 9 BY MR. MUKERJI:
`
` 09:09:40 10 Q. I'm going to ask you to take a look at
`
` 11 Heidari 1 and tell me whether this is the
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` 12 declaration that you rendered in this proceeding.
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` 13 (Witness reviewing document.)
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` 14 THE WITNESS: It appears to be, but I can't
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` 09:10:07 15 look through the entire document. I have a copy of
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` 16 it myself.
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` 17 BY MR. MUKERJI:
`
` 18 Q. I'll represent to you, sir, we haven't
`
` 19 swapped any pages or anything.
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` 09:10:16 20 If you'd turn to the last page of
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` 21 Heidari 1, which should be page 56.
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` 22 (Witness complies.)
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` 23 BY MR. MUKERJI:
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` 24 Q. Is that your signature on page 56?
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` 09:10:31 25 A. Correct.
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` 2 Q. Did you sign this on or about March 3,
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` 3 2015?
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` 4 A. I did.
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` 09:10:36 5 Q. Paragraph 107 which starts on page 55 and
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` 6 leads over to page 56 says all statements that you
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` 7 made here in on your own knowledge are true do you
`
` 8 see that?
`
` 9 A. Yes.
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` 09:10:54 10 Q. And is that in fact the case?
`
` 11 A. Yes.
`
` 12 Q. And that all statements made on information
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` 13 and belief and believe to be true are also being
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` 14 made under oath; is that correct?
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` 09:11:08 15 A. Correct.
`
` 16 Q. Okay. And you understand that the
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` 17 statements you made have been made with the
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` 18 knowledge that willful false statements and the like
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` 19 are punishable by fine or imprisonment or other bad
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` 09:11:23 20 things?
`
` 21 A. Sure.
`
` 22 Q. Does this declaration contain all of the
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` 23 opinions you rendered in this matter?
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` 24 A. It should, yes.
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` 09:11:35 25 Q. Okay. All of the opinions in this
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` 2 declaration these are yours and yours alone?
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` 3 A. It is had my.
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` 4 MR. VANDER LEEST: Objection; form.
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` 09:11:43 5 THE WITNESS: As far as the technical
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` 6 matters involved.
`
` 7 BY MR. MUKERJI:
`
` 8 Q. So I know in this declaration there's a
`
` 9 what I think of sort of a legal section. Which sets
`
` 09:11:57 10 forth certain principles and I'm referring to for
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` 11 example the section starting on page 9 at
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` 12 paragraph 23. Do you see that?
`
` 13 A. Yes.
`
` 14 Q. Okay. So that paragraph 23 that talks
`
` 09:12:15 15 about the -- the process for an invalidity analysis
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` 16 I take it that was something that was written by
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` 17 Intellectual Ventures I LLC lawyers; correct?
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` 18 MR. VANDER LEEST: Objection;
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` 19 attorney-client privilege. That's beyond the scope
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` 09:12:30 20 of fair play. Don't answer. I instruct the witness
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` 21 not to answer.
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` 22 BY MR. MUKERJI:
`
` 23 Q. Sir, did you write paragraph 23?
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` 24 MR. VANDER LEEST: Objection; form and
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` 09:12:44 25 attorney-client privilege. Instruct the witness not
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` 2 to answer.
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` 3 BY MR. MUKERJI:
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` 4 Q. Are you taking Mr. Vander Leest
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` 09:12:58 5 instruction?
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` 6 A. Yes.
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` 7 MR. VANDER LEEST: You can answer that.
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` 8 THE WITNESS: I have been helped by my
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` 9 counsel to understand the rules for the claim
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` 09:13:15 10 construction. I'm not an expert in legal matters so
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` 11 you can just most of this area is -- is with the
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` 12 substantial of counsel.
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` 13 BY MR. MUKERJI:
`
` 14 Q. That's fair. And I didn't mean it as an
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` 09:13:31 15 accusation so let me lay a little bit of a
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` 16 foundation you're not a lawyer sir?
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` 17 A. No.
`
` 18 Q. You're not a patent lawyer?
`
` 19 A. No.
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` 09:13:37 20 Q. Have you drafted patents?
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` 21 A. No.
`
` 22 Q. Have you ever drafted patents?
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` 23 A. No.
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` 24 Q. Do you know how to read claims?
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` 09:13:44 25 A. I know how to read claims. It depends on
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` 2 what you mean by is that a legal question or just
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` 3 general question?
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` 4 Q. I'm not sure what the distinct is so when
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` 09:13:55 5 you read patent claims and you?
`
` 6 A. I can read.
`
` 7 Q. Sorry.
`
` 8 A. If that's what you meant.
`
` 9 Q. Okay. And you understand patent claims?
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` 09:14:02 10 A. I can understand them to the extent that
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` 11 they are technical in nature and I don't purport
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` 12 that I can understand all the legal ramifications.
`
` 13 Q. I'm not sure I can either sometimes. So
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` 14 you understand the patent that's the subject of this
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` 09:14:19 15 proceeding is what we'll shorthand as the 870
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` 16 patent; correct?
`
` 17 A. Correct.
`
` 18 Q. You read the 870 patent?
`
` 19 A. Correct.
`
` 09:14:28 20 Q. You read the claims of the 870 patents?
`
` 21 A. Yes.
`
` 22 Q. Did you read the claims?
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` 23 A. I read the claims.
`
` 24 Q. When is the last time you read the patent?
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` 09:14:38 25 A. I read the patent over the weekend.
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` 2 Q. This past weekend?
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` 3 A. Yes.
`
` 4 Q. Okay. When was the first time you read the
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` 09:14:45 5 patent?
`
` 6 A. When I was asked to consult for my client,
`
` 7 who started working on this project.
`
` 8 Q. Did you read it before or after you agreed
`
` 9 to consult?
`
` 09:14:57 10 A. I don't recall exactly. I was told to -- I
`
` 11 may have -- I may have looked at it before hand,
`
` 12 yes.
`
` 13 Q. The first time you actually read it not
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` 14 just skimmed it but actually read it for
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` 09:15:21 15 comprehension did you understand the patent?
`
` 16 A. I understood the patent.
`
` 17 Q. Did you understand the claims?
`
` 18 A. I understood the claims from a technical
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` 19 perspective, yes.
`
` 09:15:31 20 Q. At any point in this process did you
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` 21 require assistance to understand the claims?
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` 22 MR. VANDER LEEST: Objection; form.
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` 23 THE WITNESS: Understanding from what
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` 24 perspective? Again technical legal.
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` 25 ///
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` 2 BY MR. MUKERJI:
`
` 3 Q. Understand sufficient to do the job you
`
` 4 done in this case?
`
` 09:15:46 5 A. Yes, I understood.
`
` 6 Q. Okay. But did you need help to understand?
`
` 7 A. It's -- I don't know what you mean by help
`
` 8 to understand it. It's this process took a long
`
` 9 time so a lot of back and forth so and you learn a
`
` 09:16:05 10 you go forward more and more every time you read it
`
` 11 and discuss it.
`
` 12 Q. Back and forth with whom?
`
` 13 A. With the counsel with the -- the different
`
` 14 documents that I had to reread and --
`
` 09:16:19 15 Q. Other than counsel had had you discussed
`
` 16 your work in this matter with anyone?
`
` 17 A. No.
`
` 18 Q. Did you -- did you require counsel's
`
` 19 assistance to understand the claims?
`
` 09:16:31 20 A. Uh-huh.
`
` 21 MR. VANDER LEEST: Objection; form and
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` 22 attorney-client privy know not to make speaking are
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` 23 objection but case law you can't go into the
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` 24 declaration of the operation in this proceedings.
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` 09:16:45 25 MR. MUKERJI: I'm just asking about his
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` 2 understanding of the claims.
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` 3 MR. VANDER LEEST: You asked.
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` 4 MR. MUKERJI: You can instruct him.
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` 09:16:51 5 MR. VANDER LEEST: You I'll give you a
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` 6 little leeway but we're not going to get this very
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` 7 far.
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` 8 Can you read the question back.
`
` 9 (The record was read by the
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` 09:17:10 10 reporter.)
`
` 11 MR. VANDER LEEST: I'm going to object as
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` 12 asked and answered and as to form and that's all you
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` 13 can answer.
`
` 14 THE WITNESS: Again, if you're asking from
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` 09:17:23 15 a technical perspective no, I didn't need it.
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` 16 BY MR. MUKERJI:
`
` 17 Q. Now, I see in this section that starts on
`
` 18 page 9 it carries over to page 10 that you set forth
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` 19 certain constructions of various claim phrases from
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` 09:17:41 20 the 870 patent; is that correct?
`
` 21 A. Correct.
`
` 22 Q. And these are constructions that were
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` 23 rendered by the board?
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` 24 A. Correct.
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` 09:17:49 25 Q. Okay. Did you apply these constructions in
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` 2 your work in this case?
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` 3 A. I did.
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` 4 Q. Okay. Now, sir, earlier you had told me
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` 09:18:06 5 you had not been deposed before and I believe in
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` 6 your report you say you have never acted as an
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` 7 expert before; is that correct?
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` 8 A. As an expert witness.
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` 9 Q. That's correct?
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` 09:18:17 10 A. Correct.
`
` 11 Q. Okay. Have you ever attempted to act as an
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` 12 expert witness but were not able to for any reason?
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` 13 MR. VANDER LEEST: Objection; form.
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` 14 THE WITNESS: I don't know what Ma that
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` 09:18:30 15 means.
`
` 16 BY MR. MUKERJI:
`
` 17 Q. Okay. Have you ever been decision equal
`
` 18 bid by acting as an expert by a court?
`
` 19 A. No.
`
` 09:18:39 20 Q. Has anyone ever objected to your acting as
`
` 21 an expert in court?
`
` 22 A. I was once being considered for an expert
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` 23 position opposing counsel objected this was not in a
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` 24 court but they managed to dismiss me from the case
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` 09:19:08 25 so it never started.
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` 2 Q. Are you referring to the GPNE matter?
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` 3 A. I believe it was GPNE but I can't be sure.
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` 4 Q. GPNE versus Apple?
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` 09:19:22 5 A. That reminds me, yes.
`
` 6 Q. Do you know why you were dismissed from the
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` 7 case?
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` 8 A. I don't recall exactly but it had something
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` 9 to do with my background having had had experience
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` 09:19:38 10 with certain firms that they did not appreciate.
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` 11 And I was -- and I wasn't -- I didn't receive much
`
` 12 information about what exactly per expired --
`
` 13 transpired in terms of the proceedings to dismiss me
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` 14 again I heard they did not allow me to continue.
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` 09:20:04 15 Q. Do you know that a federal district court
`
` 16 determined that you should not receive April wills
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` 17 confidential information because of the nature of
`
` 18 your business?
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` 19 A. That's -- that's probably what it was but
`
` 09:20:17 20 I'm not certain what exactly transpired.
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` 21 Q. I think I may have phrase this had
`
` 22 preceding set of section is in terms of court let me
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` 23 ask this set of question with regard to the board
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` 24 which is the governing authority in this proceeding.
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` 09:20:35 25 A. Right.
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` 2 Q. Okay. Have you ever testified before the
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` 3 board?
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` 4 A. No, I have not.
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` 09:20:39 5 Q. Have you ever been retained as an expert
`
` 6 other than in this matter for an intra partes
`
` 7 proceeding?
`
` 8 A. No, I have not.
`
` 9 Q. Or a covered business method proceeding?
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` 09:20:51 10 A. No, I have not.
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` 11 Q. Have you ever offered any testimony to the
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` 12 patent office in any capacity?
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` 13 A. No, I have not.
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`RF-060915.txt
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` 14 Q. Okay. If I recall correctly you were at
`
` 09:21:06 15 Dr. Ding's depo?
`
` 16 A. I was.
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` 17 Q. And you Dr. Ding you understand is
`
` 18 petitioner's expert in this matter; correct?
`
` 19 A. Correct.
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` 09:21:16 20 Q. Do you have any concerns about Dr. Ding's
`
` 21 technical competence in this matter?
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` 22 MR. VANDER LEEST: Objection; form.
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` 23 THE WITNESS: What do you mean by
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` 24 "concerns"?
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` 25 ///
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` 2 BY MR. MUKERJI:
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` 3 Q. Do you think Dr. Ding is unqualified to
`
` 4 testify on this matter on the technical aspects?
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` 09:21:31 5 MR. VANDER LEEST: Objection; form.
`
` 6 THE WITNESS: I have not analyzed his
`
` 7 background with respect to these matters so I don't
`
` 8 feel comfortable giving anything on that.
`
` 9 BY MR. MUKERJI:
`
` 09:21:54 10 Q. Do you decision pews Dr. Ding qualifies as
`
` 11 an expert in this matter?
`
` 12 MR. VANDER LEEST: Objection; asked and
`
` 13 answered objection form.
`
` 14 THE WITNESS: I don't know exactly what
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` 09:22:03 15 you're referring to I have not looked at that matter
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` 16 so I don't want to judge him one way or the other.
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` 17 BY MR. MUKERJI:
`
` 18 Q. When you listened to him testify did you
`
` 19 take issue to any of his testimony?
`
` 09:22:16 20 MR. VANDER LEEST: Objection; form.
`
` 21 THE WITNESS: Which -- which part or
`
` 22 what -- what type of issue are we referring to.
`
` 23 BY MR. MUKERJI:
`
` 24 Q. Did you disagree with him?
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` 09:22:26 25 A. I may have disagreed with some, yeah.
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` 2 Q. Do you recall the disagreements today?
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` 3 A. Do I recall it? I don't recall all of it,
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` 4 no.
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` 09:22:39 5 Q. What do you recall?
`
` 6 A. I -- you're talking about with respect to
`
` 7 his testimony -- his cross examination only; right?
`
` 8 Q. Okay. Let's start there.
`
` 9 A. What I do recall for example was that he
`
` 09:23:08 10 was very much trying to make certain aspects of not
`
` 11 more patent to appear a certain way. One particular
`
` 12 one I remember has to do with the big patent
`
` 13 protection.
`
` 14 Q. Sorry. I missed that.
`
` 09:23:46 15 A. Big pattern detection.
`
` 16 Q. Oh, big pattern detection.
`
` 17 And you take the contrary view on this
`
` 18 case; correct?
`Page 16
`
`

`

`RF-060915.txt
`
` 19 A. It depends on what contrary means.
`
` 09:23:55 20 What do you mean by that.
`
` 21 Q. You disagree with him?
`
` 22 A. I have a different view, yes.
`
` 23 Q. Are you a named inventor on any patents?
`
` 24 A. Yes, I am.
`
` 09:24:07 25 Q. How many?
` 18
`
` UNCERTIFIED ROUGH DRAFT -- NOT FOR OFFICIAL USE
`

`
` 1 UNCERTIFIED ROUGH DRAFT -- NOT FOR OFFICIAL USE
`
` 2 A. I'm not quite sure exactly how many. Last
`
` 3 count they gave me was 33.
`
` 4 Q. Do any of those patents impact your
`
` 09:24:21 5 analysis in this case?
`
` 6 MR. VANDER LEEST: Objection; form.
`
` 7 THE WITNESS: I don't understand the
`
` 8 question. What do you mean impact my analysis.
`
` 9 MR. MUKERJI:
`
` 09:24:30 10 Q. Are any of those patent relevant to the
`
` 11 afternoon analysis in this case?
`
` 12 MR. VANDER LEEST: Objection; form.
`
` 13 THE WITNESS: They're all related to my
`
` 14 background so I use my background for analys

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