IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
` __________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` __________
`
` LG ELECTRONICS, INC., and
` LG ELECTRONICS U.S.A., INC.,
` Petitioners,
` v.
` TOSHIBA SAMSUNG STORAGE TECHNOLOGY
` KOREA CORPORATION,
` Patent Owner.
`
` __________
` IPR2015-01642, Patent No. 6,721,110
` IPR2015-01644, Patent No. 6,785,065
` __________
` Washington, D.C.
` April 29, 2016
`
` CROSS-EXAMINATION OF
` MASUD MANSURIPUR, Ph.D.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
` __________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` __________
`
` LG ELECTRONICS, INC., and
` LG ELECTRONICS U.S.A., INC.,
` Petitioners,
` v.
` TOSHIBA SAMSUNG STORAGE TECHNOLOGY
` KOREA CORPORATION,
` Patent Owner.
`
` __________
` IPR2015-01642, Patent No. 6,721,110
` IPR2015-01644, Patent No. 6,785,065
` __________
` Washington, D.C.
` April 29, 2016
`
` CROSS-EXAMINATION OF
` MASUD MANSURIPUR, Ph.D.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`2
`
` Cross-Examination of MASUD MANSURIPUR,
`Ph.D., a witness herein, called for examination by
`counsel for Patent Owner in the above-entitled
`matter, was taken on Friday, April 29, 2016,
`commencing at 9:02 a.m. at the law offices of
`Rothwell, Figg, Ernst & Manbeck, PC, 607 14th
`Street, NW, Washington, D.C. 20005 by Cappy
`Hallock, Registered Professional Reporter,
`Certified Realtime Reporter, Certified Livenote
`Reporter and Notary Public in and for the District
`of Columbia.
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`3
`
`APPEARANCES:
`
` ON BEHALF OF THE PETITIONER:
` BRIAN A. TOLLEFSON, ESQUIRE
` MICHAEL H. JONES, ESQUIRE
` Rothwell, Figg, Ernst & Manbeck, PC
` 607 14th Street, N.W., Suite 800
` Washington, D.C. 20005
` 202-783-6040
` btollefson@rfem.com
` mjones@rfem.com
`
` ON BEHALF OF THE PATENT OWNER:
` JOSEPH A. RHOA, ESQUIRE
` JONATHAN A. ROBERTS, ESQUIRE
` Nixon & Vanderhye, PC
` 901 North Glebe Road, 11th Floor
` Arlington, Virginia 22003
` 703-816-4000 (P) 703-816-4100
` jar@nixonvan.com
` jr@nixonvan.com
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
` C O N T E N T S
` Deposition of MASUD MANSURIPUR, Ph.D.
` April 29, 2016
`
`4
`
`EXAMINATION BY: PAGE
` Mr. Rhoa 5
` -o0o-
`
` PREVIOUSLY MARKED EXHIBITS
` (exhibits retained)
`MANSURIPUR PAGE
`Exhibit 1006 Mansuripur Declaration 5
` Relating to U.S. Patent
` No. 6,721,110
`Exhibit 1001 U.S. Patent No. 6,721,110 26
`Exhibit 1002 U.S. Patent No. 6,343,053 27
`Exhibit 1001 U.S. Patent No. 6,785,065 28
`Exhibit 1011 Mansuripur Declaration 92
` Relating to U.S. Patent
` No. 6,785,065
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`5
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` P R O C E E D I N G S
` - - - - -
`WHEREUPON,
` MASUD MANSURIPUR, Ph.D.,
` A Witness called for examination, having
`been first duly sworn, was examined and testified
`as follows:
` CROSS-EXAMINATION
`BY MR. RHOA:
` Q Please state your name for the record.
` A Masud Mansuripur.
` Q What is your current address?
` A 5748 North Camino del Conde,
`C-o-n-d-e, Tucson, Arizona, 85718.
` (Previously marked Exhibit No. 1006,
`first referral.)
` MR. RHOA: I'm going to hand you
`Exhibit 1006 in the IPR involving U.S. Patent
`Number 6,721,110.
` MR. TOLLEFSON: Thank you.
`BY MR. RHOA:
` Q Do you have 1006 in front of you?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`6
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` A Yes, I do.
` Q And this relates to the '110 patent;
`is that correct?
` A It relates to the '110 patent.
` Q Is this your declaration?
` A This is my declaration.
` Q You signed it?
` A I did sign it.
` Q And your CV is attached at the back;
`is that correct?
` A My CV is attached as Appendix A.
` Q Do you understand that this deposition
`that we are doing now involves two different IPRs?
` A I understand that there are three
`different IPRs.
` MR. TOLLEFSON: Do you want me to
`clarify?
` The first deposition, by agreement, is
`on the '110 and the '065 patents.
` THE WITNESS: Okay.
` A Yes, I do understand it is two IPRs.
` Q So you understand that this deposition
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`7
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`that we are doing right now is for the IPR
`involving the '110 patent and for the IPR
`involving the '065 patent?
` A I do understand that.
` Q Are those two patents family member
`patents?
` A That may be a legal term. I
`understand the specifications are the same,
`essentially, but the claims are different.
` Q So the specifications are the same for
`those two patents as far as you know?
` A As far as I know.
` Q Who is your current employer?
` A University of Arizona.
` Q How long have you been employed by the
`University of Arizona?
` A Twenty-eight years.
` Q What is your current position?
` A I'm professor and chair of optical
`data storage.
` Q How long have you held that position?
` A I have been a professor -- I started
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`8
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`as an associate professor. Then after three years
`I became full professor, and then for the past 15
`years or so I have also been the chair of optical
`data storage.
` Q When did you start as an associate
`professor?
` A In 1988.
` Q Where did you get your undergraduate
`degree?
` A In Arya Mehr University of Technology.
` Q Where is that located?
` A In Tehran, Iran.
` Q What year did you get that degree?
` A I got my bachelor's degree in 1977.
` Q What was that degree in?
` A In electrical engineering.
` Q Do you have any degrees that you
`received after that?
` A I received master's degrees and Ph.D.
`after I received my bachelor's degree.
` Q From where?
` A From Stanford University.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`9
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` Q What years?
` A My master's degree in electrical
`engineering I believe was 1978, and then I
`received a master's degree in mathematics a couple
`of years later and a Ph.D. in electrical
`engineering in 1981.
` Q Both from Stanford?
` A All three from Stanford.
` Q How old are you?
` A Excuse me. I didn't hear you.
` Q How old are you?
` A I'm 61 years old.
` Q Have you been retained by LG for this
`matter?
` A I believe I have been retained by the
`attorneys who represent LG.
` Q Do you have an understanding of
`whether you're testifying on behalf of LG or
`testifying on behalf of the attorneys?
` A I'm testifying about the patents that
`are at issue.
` Q So you're not going to answer my last
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
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`question?
` A I have been asked questions about
`certain patents and the prior art, and I
`understand that --
` Q I'm just trying to figure out who has
`retained you. Is it LG or is it the lawyers?
` A I was contacted by the lawyers and I
`understand that the work is on behalf of LG.
` Q Do you have a written agreement with
`either lawyers or LG or both?
` A I have a written agreement and I
`believe it is with the attorneys.
` Q When were you first retained by LG in
`connection with this matter?
` A About four years ago.
` MR. TOLLEFSON: I'd like to take a
`quick break with you to discuss matters that may
`relate to privilege. Okay?
` (Recess taken -- 9:11 a.m.)
` (After recess -- 9:14 a.m.)
` A I apologize. My answer to a previous
`question was incorrect.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
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` Q Please explain.
` A The question was --
` MR. TOLLEFSON: I caution you not to
`reveal any privileged information, discussions
`with the lawyers, on any other matters. And, of
`course, no discussions with the lawyers on this
`matter, either.
` A I started working on this matter a
`couple of months before my declaration date.
` Q So when you say "this matter," you're
`referring to the IPR involving the '110 patent and
`the IPR involving the '065 patent; is that right?
` A When I refer to this matter it is IPR
`related to '110 and '065 matters.
` Q Were you ever retained by LG regarding
`other matters prior to that?
` MR. TOLLEFSON: I object on the
`grounds of privilege and instruct the witness not
`to answer.
` MR. RHOA: Are you really going to
`instruct him that he's not allowed to answer
`questions about whether --
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
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` MR. TOLLEFSON: You may answer that
`question -- you may answer that question yes or
`no.
` Can you read back the question for
`him?
` (The record was read as requested.)
` MR. TOLLEFSON: You may answer yes or
`no.
` A Yes.
` Q When?
` MR. TOLLEFSON: Objection, privilege.
`I instruct the witness not to answer.
` MR. RHOA: Listen, on a privilege log
`you have to put dates, things like that.
` MR. TOLLEFSON: But this is just the
`IPR. If he was hired on other matters and it's
`not public, then it is privileged. I have to
`object.
` MR. RHOA: I am allowed to ask him who
`he has worked for in the past to see if he has any
`bias or interest.
` MR. TOLLEFSON: Sure. Go ahead.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
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` MR. RHOA: That's what I'm doing.
` MR. TOLLEFSON: But I'm not telling
`you what his work is or when he was hired. That's
`privileged.
` MR. RHOA: He has already told us when
`he was hired.
` MR. TOLLEFSON: I'm objecting to that
`answer now that you bring it up. I am objecting
`to that answer as an inadvertent disclosure of
`privileged information and withdrawing that answer
`under the default protective order set forth by
`the USPTO patent laws as privileged.
` MR. RHOA: We disagree with that.
` MR. TOLLEFSON: Okay, that's fine.
`BY MR. RHOA:
` Q Your CV attached to your declaration
`says you have been a consultant to LG, right?
` A Correct.
` Q So it's no secret that you have worked
`for LG before; is that right?
` A LG was one of the sponsors of research
`at the University of Arizona.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
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` Q When did you start consulting for LG?
` A We had a center for data storage at
`the University of Arizona since 1988, since I
`joined the center, and we have had different
`companies coming in and leaving the center. So LG
`was a member at some point between 1988 and
`somewhere in early 2000s.
` Q And those companies donate money to
`the center?
` A The companies gave money or equipment
`to the center, and the professors were members of
`the center and the students worked on research
`projects.
` Q So in your CV when you say consultants
`to LG Electronics, is that what you are referring
`to?
` A Yes.
` Q Any other times you have consulted to
`LG Electronics?
` MR. TOLLEFSON: I caution you not to
`reveal any privileged information relating to, for
`example, any litigations where you have consulted
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
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`where it's not public knowledge that you have
`consulted on those litigations.
` A When I visit Korea, I have visited
`different companies, and LG was one of the
`companies that I visited many years ago.
` Q What is your hourly rate for this
`matter?
` A My hourly rate is $500.
` Q Who first contacted you about this
`matter?
` A I believe I was contacted by one of
`the attorneys from this law firm.
` Q Do you remember who it was?
` A I think it was Jason Shapiro.
` Q And when did he contact you?
` MR. TOLLEFSON: Again, I caution you
`to limit your answer to the IPRs that are the
`subject of this deposition.
` A I don't recall exactly when he
`contacted me but it would have been a few months
`before the date of my declaration in the '110 or
`'065 patent.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`16
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` Q How much have you been paid so far for
`your -- rephrase the question.
` How much have you been paid so far in
`connection with this matter?
` A I don't recall exactly how much I have
`been paid in connection with this matter. It
`could have been somewhere around 50 to $100,000.
` Q Is that for all three IPRs that you
`are working on, or just one?
` A This has been in conjunction with the
`three IPRs I have worked on since almost a year
`ago.
` Q How much time did you spend preparing
`for today's depositions?
` A I spent two days last week and one,
`one and a half days this week.
` Q How many hours total, approximately?
` A I would say about 40 to 50 hours.
` Q Who did you meet with during
`preparation for today's depositions?
` A I met with attorneys.
` Q Which attorneys?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
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` A I met with Mr. Tollefson, attorney
`Mike Jones and attorney Mike Battaglia.
` Q How many of those attorneys are in the
`room today for today's deposition?
` A Attorney Tollefson and attorney Mike
`Jones.
` Q Do you know how much money LG has paid
`to the University of Arizona in connection with
`your, the activities you described regarding your
`consulting with them?
` A I don't recall right now how many
`years they were members and what level membership
`they were.
` Q Do you know if they paid more or less
`than a million dollars total?
` A I don't know the number of years they
`were involved, but probably less than a million
`dollars.
` Q Have you ever been an expert witness
`in a patent case before you were retained by these
`lawyers for this matter?
` A Have I been an expert witness in other
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`18
`
`1
`
`2
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`3
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`4
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`cases?
` Q Patent cases.
` A I have been an expert in other patent
`cases.
` Q How many other patent cases have you
`been an expert witness in?
` A Somewhere between 10 and 20.
` Q How many of them are mentioned in your
`CV?
` A I have not mentioned -- I don't
`believe I have mentioned my expert witnessing in
`my CV.
` Q Can you recall the names of the patent
`cases where you have been an expert witness?
` Let me rephrase that.
` Can you name the patent cases where
`you have actually testified as an expert witness?
` A In a case involving an optical switch
`company, I testified before a judge. I think it
`was a litigation case.
` There was a case before the ITC judge
`in Washington, D.C., I testified.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`19
`
`1
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`2
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`3
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`4
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` Q Do you know what the name of that case
`was?
` A It involved Phillips Company and
`Taiwanese company, I believe it was Gigastorage.
` Q Is that both those cases that you
`described? Is that both -- both cases you just
`described involved Phillips?
` A No. The first case I described
`involved Optical Switch Corporation, I believe.
`It was a dispute between the shareholders and the
`CEO of the company.
` And then the matter in front of the
`ITC was between Phillips and a couple of Taiwanese
`companies. Then there was another case in
`Madison, Wisconsin involving Imation Corporation.
` Q How do you spell that?
` A Imation?
` Q Yes.
` A I-m-a-t-i-o-n.
` Q And you testified at trial in all
`those cases; is that correct?
` A The case involving Imation was in
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`20
`
`1
`
`2
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`3
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`4
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`5
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`6
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`front of a jury.
` Q So that was a trial?
` A I suppose.
` Q Any other cases where you testified
`that were patent cases?
` A I don't recall right now.
` Q Any other cases where you had your
`deposition taken that were patent cases that you
`have not just mentioned?
` A Yes. I had my deposition taken in
`other cases which did not go to trial or to court.
` Q Can you identify the names of those
`cases, if they were patent cases?
` A There was a case in the 1990s
`involving two companies. I don't remember the
`name. DiscoVision I believe was one of them. I
`don't remember the other company. There have been
`cases involving Imation.
` Q Same spelling as before?
` A Yes.
` And Phillips. There was a case
`involving a company called Target Technologies,
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`21
`
`1
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`2
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`3
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`4
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`5
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`and a few other cases.
` Q You don't have a law degree, do you?
` A Could you repeat the question, please?
` Q You don't have a law degree, do you?
` A I do not have a law degree.
` Q Ever taken any legal classes?
` A I don't believe I have taken any legal
`classes.
` Q Are you identified as an inventor on
`any U.S. patents?
` A Am I identified as an inventor on any
`U.S. patent? Yes, I am.
` Q Approximately how many?
` A I believe I am a named inventor on
`eight or nine patents.
` Q Do you have an understanding of
`whether Mr. Tollefson is representing you in
`today's deposition?
` A I do not know if Mr. Tollefson is
`representing me.
` Q When you were preparing for today's
`deposition what did Mr. Tollefson say to you?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`22
`
`1
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`2
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`3
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` MR. TOLLEFSON: Objection, privileged.
` Do not answer.
` Q Are you going to follow those
`instructions?
` A Yes.
` Q When you were preparing for today's
`depositions, what did you say to Mr. Tollefson?
` MR. TOLLEFSON: Objection, privileged.
` Do not answer.
` And for the record, we are
`representing LG and the witness.
` Q Are you going to follow his
`instruction not to answer?
` A Yes.
` Q This declaration that we have here,
`Exhibit 1006 in the IPR involving the '110 patent,
`do you have that in front of you?
` A I have that in front of me.
` Q Who prepared the first draft of this
`declaration?
` MR. TOLLEFSON: I object. Privileged.
` I instruct the witness not to answer.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`23
`
`1
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`2
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`3
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` Q Are you going to follow his
`instruction not to answer?
` A Yes.
` Q Did the attorneys prepare the first
`draft of this declaration?
` MR. TOLLEFSON: Same objection.
` Q Are you going to follow --
` MR. TOLLEFSON: Same instruction.
` Q Are you going to follow his
`instruction not to answer?
` A Yes.
` Q Do you recall how many drafts of your
`declaration were circulated back and forth between
`you and the attorneys?
` MR. TOLLEFSON: Same objection. Same
`instruction.
` MR. RHOA: And I'm just asking for
`numbers here.
` MR. TOLLEFSON: No --
` MR. RHOA: The kind of thing you put
`on a privilege log.
` MR. TOLLEFSON: That's all privileged.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`24
`
`1
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`2
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`3
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`4
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`5
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` MR. RHOA: Really.
` Q Are you going to follow his
`instructions not to answer?
` A I will follow his instruction.
` Q Do you still have copies of any of
`your declaration drafts?
` MR. TOLLEFSON: Same objection.
` Q Are you going to answer the question?
` MR. TOLLEFSON: Same instruction.
`Same objection.
` MR. RHOA: Are you instructing him not
`to answer?
` MR. TOLLEFSON: I am instructing him
`not to answer.
` Q Are you going to follow his
`instructions not to answer?
` A Yes.
` Q Have you ever been retained by someone
`other than LG in connection with any of the
`patents involved in these IPRs?
` A I don't believe I have, no.
` Q Have you taken any medication today
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`25
`
`1
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`2
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`3
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`4
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`5
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`that could affect your testimony in any way?
` A I'm not taking any medication that
`could affect my testimony.
` Q When was the first time you saw the
`patents involved in these IPRs?
` A You mean the '110 patent?
` Q Let's take the '110 patent. When was
`the first time you saw the '110 patent?
` A I don't recall exactly, but must have
`been before the date of my declaration.
` Q Three months before your declaration
`or three years before your declaration? How long?
` A A few months.
` Q Would those same answers apply to the
`'065 patent?
` A Same answers as to the '065 patent.
` Q So you've never provided opinions or
`work for any of these patents prior to these
`matters; is that right?
` MR. TOLLEFSON: I caution you, if you
`have, then they are probably privileged, so I
`caution you not to reveal any opinions or
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`26
`
`1
`
`2
`
`3
`
`4
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`5
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`6
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`discussions that you have had with lawyers, if you
`have had any.
` Q You can answer.
` A I don't recall having any.
` MR. RHOA: I'm going to hand you U.S.
`Patent 6,721,110, which is identified as
`Exhibit 1001 in the IPR involving the '110 patent.
` (Previously marked Exhibit No. 1001,
`first referral.)
`BY MR. RHOA:
` Q Do you have that patent in front of
`you?
` A I have Exhibit 1001 in front of me.
` Q Is Exhibit 1001 U.S. Patent
`Number 6,721,110?
` A Yes, it is 6,721,110 B2.
` Q During today's deposition if I mention
`the '110 patent, will you understand that this is
`the patent that I'm referring to?
` A I will understand.
` Q Are you familiar with this patent?
` A I am familiar with this patent.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`27
`
`1
`
`2
`
`3
`
`4
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`5
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`
` Q Do you understand its content?
` MR. TOLLEFSON: Objection, form.
` A What do you mean by understand?
` Q Do you understand what is written in
`this patent?
` A I have read it and I believe I know
`what it is about.
` MR. RHOA: I'm going to hand you
`Exhibit 1002 in the IPR involving the '110 patent.
`Toll me when you have it in front of you.
` (Previously marked Exhibit No. 1002,
`first referral.)
` A I have Exhibit 1002 in front of me.
` Q What is Exhibit 1002?
` A It's the United States patent
`6,343,053 B1.
` Q Is this the Akanuma patent,
`A-k-a-n-u-m-a?
` A It is the Akanuma patent referred to
`in my declarations.
` Q So if I refer to Akanuma during
`today's deposition, will you understand that I'm
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`28
`
`1
`
`2
`
`3
`
`4
`
`5
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`6
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`7
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`
`referring to U.S. Patent Number 6,343,053?
` A I will understand, yes.
` MR. RHOA: I'm going to hand you U.S.
`Patent Number 6,785,065. Please tell me when you
`have it in front of you.
` (Previously marked Exhibit 1001, first
`referral.)
` THE WITNESS: I have Exhibit 1001 in
`front of me.
`BY MR. RHOA:
` Q Now, this is Exhibit 1001 in the other
`IPR, correct? It's in the IPR involving the '065
`patent, right?
` A It is the exhibit in the other IPR
`involving the '065 patent.
` Q If I refer to the '065 patent during
`today's deposition, will you understand that I'm
`referring to U.S. Patent Number 6,785,065?
` A I will understand.
` Q Are you familiar with the '065 patent?
` A I am familiar with the '065 patent.
` Q Do you understand the technology in
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`29
`
`1
`
`2
`
`3
`
`4
`
`5
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`6
`
`7
`
`8
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`11
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`
`the '065 patent?
` MR. TOLLEFSON: Objection to form.
` A What do you mean by understand?
` Q You don't know what the word
`understand means?
` A I want to be clear as to what you're
`asking.
` Q I'm asking you if you understand the
`technology in the '065 patent.
` A I have read the '065 patent and I
`understand the relevant technology.
` Q Are you familiar with the Akanuma
`patent which is U.S. Patent Number 6,343,053?
` A I believe I already answered that
`question about Akanuma.
` Q Regardless of whether you've answered
`it before, can you answer the question?
` A Could you repeat the question again?
` Q Are you familiar with the Akanuma
`patent which is U.S. Patent Number 6,343,053?
` A I'm familiar with the Akanuma patent.
` Q Have you read the entire patent?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`30
`
`1
`
`2
`
`3
`
`4
`
`5
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`6
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`7
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`
` A I have read the entire Akanuma patent.
` Q Do you understand the content of the
`Akanuma patent?
` MR. TOLLEFSON: Objection, form.
` A I have read the patent and I
`understand the technology described in this
`patent.
` Q When was the first time you saw
`Akanuma?
` A Again, it was a few months before my
`declaration date, I believe.
` Q And would that same answer apply to
`the '110 patent?
` MR. TOLLEFSON: Objection, form.
` A I believe I answered that question
`before.
` Q That's not a valid reason to not
`answer a question.
` A What is the question?
` MR. RHOA: Can you read back the
`question for him please.
` (The record was read as requested.)
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`31
`
`1
`
`2
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`3
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`4
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`5
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`6
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`
` A I have read the '110 patent and I
`believe I understand the relevant technology.
` Q When was the first time you saw the
`'110 patent? Was it a few months before your
`declaration?
` A If I recall correctly it was a few
`months before my declaration.
` MR. RHOA: This is a good time for a
`break if you want to take one.
` MR. TOLLEFSON: All right, thanks.
` (Recess taken -- 9:43 a.m.)
` (After recess -- 9:58 a.m.)
`BY MR. RHOA:
` Q The word coil is used quite a bit in
`the '110 and '065 patents, right?
` A I believe the word coil is used in the
`patents.
` Q What would one of ordinary skill in
`the art as of 2001 have understood a coil to be?
` A This is related to any of the
`statements made in my declaration?
` Q I'm asking you questions during the
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`Exhibit 2002
`
`
`
`IPR2015-01642; IPR2015-01644
`Mansuripur, Ph.D., Masud
`
`April 29, 2016
`
`32
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`1
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`
`deposition today. You answer my q
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