throbber
Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` _______________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _______________________________________
` FEDEX CORPORATION
` Petitioner
` v.
` INTELLECTUAL VENTURES II LLC
` Patent owner
` ________________________________
` CASE IPR 2017-00741
` Patent No. 6,633,900
` ________________________________
`
` EXAMINATION of JACOB SHARONY
` _______________________________
` TAKEN ON
` FRIDAY, FEBRUARY 23, 2018
`
`REPORTED BY:
`JESSIE WAACK, RDR, CRR, CCRR, CCR, NYACR, NYRCR
`JOB NO.: 42932
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
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`UNITED STATES PATENT AND TRADEMARK OFFICE
` _______________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _______________________________________
` FEDEX CORPORATION
` Petitioner
` v.
` INTELLECTUAL VENTURES II LLC
` Patent owner
` ________________________________
` CASE IPR 2017-00741
` Patent No. 6,633,900
` ________________________________
`
` EXAMINATION of JACOB SHARONY,
`taken before JESSICA R. WAACK, Certified
`Realtime Reporter, Registered Diplomate
`Reporter, California Certified Realtime
`Reporter, Certified Court Reporter in New
`Jersey, New York Association Certified
`Reporter, New York Realtime Court Reporter
`and Notary Public of the State of New
`York, at Desmarais, LLP, 230 Park Avenue,
`New York, New York, on Friday,
`February 23, 2018, commencing at 9:04 a.m.
`and concluding at 11:08 a.m.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
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` A P P E A R A N C E S
`ON BEHALF OF THE PETITIONER:
` FINNEGAN, HENDERSON, FARABOW, GARRETT
` & DUNNER, LLP
` BY: DANIEL C. TUCKER, ESQ.
` BY: ALEXANDER M. BOYER, ESQ.
` Two Freedom Square
` 11955 Freedom Drive
` Reston, Virginia 20190-5675
` PHONE: 571-203-2700
` EMAIL: Alexander.boyer@finnegan.com
` EMAIL: Daniel.tucker@finnegan.com
`ON BEHALF OF THE PATENT OWNER:
` DESMARAIS, LLP
` BY: KEVIN K. MCNISH, ESQ.
` BY: KYLE PETRIE, ESQ.
` 230 Park Avenue
` New York, New York 10169
` PHONE: 212-351-3401
` EMAIL: Kmcnish@dllp.com
` EMAIL: Kpetrie@dllp.com
` A L S O P R E S E N T
`TIM SEELEY, chief counsel Intellectual
`Ventures
` --o0o--
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
`
`4
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` INDEX TO EXAMINATION
` WITNESS: JACOB SHARONY
`EXAMINATION PAGE
` BY MR. TUCKER 6
`
` -o0o-
` INFORMATION REQUESTED
` None
`
` WITNESS INSTRUCTED NOT TO ANSWER
` None
`
` PORTIONS MARKED FOR CONFIDENTIALITY
`
`**NOTE: No original exhibits were marked
`during the deposition.
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
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`5
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` INDEX TO PREVIOUSLY MARKED EXHIBITS
` WITNESS: JACOB SHARONY
` Friday, February 23, 2018
` MARKED DESCRIPTION PAGE
`Exhibit 1001 U.S. Patent No. 43
` 6,633,900
`Exhibit 2010 Declaration of Jacob 8
` Sharony, PhD, MBA
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
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` February 23, 2018 9:04 a.m.
` J A C O B S H A R O N Y
` called as a witness herein,
` having been first duly sworn on
` oath, was examined and testified
` as follows:
` EXAMINATION
` BY MR. TUCKER:
` Q. Good morning, Dr. Sharony.
` A. Good morning.
` Q. You understand that you're under
` oath today and required to testify
` truthfully, correct?
` A. I do.
` Q. And is there any reason why you
` cannot testify truthfully today?
` A. No.
` Q. Okay. Great. Did you prepare
` for today's deposition?
` A. I did.
` Q. Okay. When did you prepare for
` today's deposition?
` A. In the past few days. I did my
` declaration, the patent involved, cited
` exhibits.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
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` Q. Okay. So you reviewed your
` declaration to prepare --
` A. I did.
` Q. -- for the deposition today?
` And I believe you said you
` reviewed the patent to prepare for your
` deposition --
` A. Yes.
` Q. -- today?
` Did you review other documents
` in preparation for your deposition today?
` A. The one that I mentioned.
` Q. I believe you mentioned the
` cited exhibits. So did you review the
` prosecution history of the '900 patent to
` prepare --
` A. I did.
` Q. -- for your deposition today?
` And did you review the prior
` reference to Storch, S-T-O-R-C-H, in
` preparation for your deposition today?
` A. I did.
` Q. And did you review the prior art
` to Butler in preparation --
` A. Yes, I did.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
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` Q. -- for your deposition today?
` And did you review the petition
` that was filed in this case in
` preparation --
` A. I did.
` Q. -- for your deposition today?
` Did you review Dr. Lavian's
` declaration in support of that position?
` A. Yes.
` Q. I'm going to hand you what has
` been marked Exhibit 2010 in this case.
` That's the declaration of Jacob Sharony,
` PhD, MBA.
` Do you recognize this document?
` A. Yes.
` Q. This is your declaration that
` you submitted in this case; is that
` correct?
` A. Yes.
` Q. And was everything in this
` declaration truthful and accurate when you
` submitted it?
` A. Yes.
` Q. And do you believe that
` everything in this declaration is still
`
`202-220-4158
`
`Henderson Legal Services, Inc.
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`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
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` truthful and accurate today?
` A. Yes.
` Q. Can we turn to Appendix B --
` A. Appendix B?
` Q. -- of your declaration, which is
` your CV?
` A. CV.
` Q. Have there been any updates to
` your CV since you submitted it with this
` declaration on November 17, 2017?
` A. I was granted two new patents, I
` believe, after the '500.
` Q. Okay.
` A. And I believe possibly
` another -- this is the last one. There
` could be other recent expert consulting.
` Q. Okay. You're not sure sitting
` here today whether there are other recent
` consulting engagements?
` A. I believe there are, because it
` doesn't mention our case.
` Q. Okay.
` A. And so there was something after
` the Bascom-AT&T.
` Q. Was there any recent consulting
`
`202-220-4158
`
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`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
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` engagements after the Bascom, the AT&T
` engagement other than the engagement for
` these IPRs that are related in the
` litigation --
` A. Yes. I see now it's 2016. The
` answer is yes.
` Q. And do you remember what those
` engagements were?
` A. Yes. It's -- one of the case is
` Devas vs. The Republic of India.
` Q. And what year was that? 2017?
` A. Yeah.
` Q. Are there any other more recent
` engagements that aren't included in this
` CV?
` A. This is also -- it's ongoing, so
` it's in '18 also.
` Q. Sure. Understood. 2017 to
` present.
` A. Yeah. I was -- in 2017 I helped
` another case. It's IPR, not litigation.
` Q. Uh-huh.
` A. I believe it was Iridescent
` Networks -- well, it was IPR, so it was
` RPX Corporation, I think with Ericsson.
`
`202-220-4158
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`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
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` Those are Iridescent Networks.
` Q. Are there any other consulting
` engagements that are not listed on here
` besides the two that we just discussed?
` A. Consulting regarding expert
` witness?
` Q. Correct.
` A. So we stated Iridescent, Devas,
` country of India. It's not litigation. I
` was just helping that -- Verizon wanted to
` put a big tower, you know, just adjacent
` to his backyard, so he asked for my
` opinion. So I worked something, but I
` don't think it's in the court system.
` Q. Okay.
` A. It might be.
` And there could be a fallout
` from the Devas vs. The Country of India,
` Republic of India. So there might be
` another party suing the country of India.
` Q. Is that a patent infringement
` case?
` A. No.
` Q. What type of case is that?
` A. It's an arbitration.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
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`CASE IPR 2017-00741
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`February 23, 2018
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` Q. Without revealing any
` confidential or privileged information,
` what is the nature of the dispute of the
` Devas vs. Republic of India case?
` A. It's -- so around 2011, there
` was a group of investors that invested
` money to lease Spectrum out of satellites
` owned by the Country of India. And for
` some reason the contract was annulled,
` meaning they canceled it. So these group
` of investor sued them.
` Q. Okay. And the RPX case you said
` was an IPR, correct?
` A. Yes.
` Q. And you submitted a declaration
` in that case?
` A. Yes. Two.
` Q. Two declarations?
` A. Two patent -- well, no. It was
` one patent, but there was two
` declarations. I mean, there were two
` different cases.
` Q. There were two IPRs for the same
` patent?
` A. Yes.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
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`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
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`February 23, 2018
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` Q. Other than the Devas case, the
` RPX case and the other personal consulting
` advice that you offered regarding the
` Verizon tower, are there any other expert
` consulting engagements that are not
` included in this list?
` A. I don't think so. I do not
` recall --
` Q. Okay.
` A. -- this list.
` Q. Okay. Great. Thank you.
` A. Yes.
` Q. Let's turn to the first page of
` your CV.
` A. Yes.
` Q. The second category is "Adjunct
` professor at Columbia University,"
` correct --
` A. Yes.
` Q. -- do you see that?
` You're currently an adjunct
` professor at Columbia; is that correct?
` A. I just taught a course in the
` fourth semester.
` Q. Oh, okay. Great. So are you
`
`202-220-4158
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`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
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`February 23, 2018
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` teaching any courses this semester?
` A. No. I will teach in the next
` four -- usually the course is offered
` every -- every four -- every --
` Q. So you generally teach every
` fall at Columbia?
` A. Not every fall, but I taught in
` this fall.
` Q. Okay.
` A. So it's like I taught a
` different course, and from -- every time
` they would like to have a new course,
` because it's topics in advanced
` communication. So previously I taught
` wireless sensing networks.
` This fall I taught millimeter
` wave communication and application 4, 5G;
` 5G meaning what's coming next after 4G,
` LTE. So I teach it in the next fall.
` Q. So this past fall, you taught a
` course in -- related to 5G?
` A. Yes.
` Q. And you'll be teaching that
` course again next fall?
` A. Yeah. It's a graduate level
`
`202-220-4158
`
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`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
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` course.
` Q. Can we just go off the record
` for one second?
` (Whereupon, a recess in the
` proceedings was taken at
` 9:16 a.m.)
` BY MR. TUCKER:
` Q. So, Dr. Sharony, before the
` break we were talking about some of the
` courses that you've taught at Columbia. I
` believe you mentioned a course in 5G?
` A. Yes.
` Q. And also a course in wireless
` sensing networks; is that right?
` A. Yes.
` Q. Okay. What teaching materials
` do you use with your students in the 5G
` class?
` A. I basically prepare slides. I
` use some books, personal knowledge,
` experience working.
` For example, this course is
` meter wave communication, which is a
` technology that would be part of 5G.
` These are very high band. In the -- above
`
`202-220-4158
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`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
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`February 23, 2018
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` 30 gigahertz.
` Just to clarify, most of the
` cellular communication today is in the
` microwave region. It's, like, between
` 700 megahertz to 2.5 gigahertz. So this
` goes all the way above 30 gigahertz, 28,
` 60 and the like.
` So I -- I was about two years in
` the Bay -- close to two years in the Bay
` Area doing consulting on millimeter wave.
` So we did lots of work on that.
` And it was a good thing to
` basically make a course out of it, out of
` millimeter wave --
` Q. Okay.
` A. -- so slides, books, personal
` knowledge, experience.
` Q. You draw from multiple sources,
` from --
` A. Yes.
` Q. -- from the slides --
` A. Yes.
` Q. -- books and your own personal
` knowledge?
` What's the benefit of using a
`
`202-220-4158
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`

`Sharony, Jacob
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`CASE IPR 2017-00741
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` book to teach your course?
` A. A book is -- they are not great
` books. It's very hard in -- this is an
` advanced course. It's an elective course.
` It's not like a core course that everyone
` wants to take.
` From my experience when you take
` core courses like signal and systems or
` stochastic processes, there are good books
` or discrete systems. They are very good
` books. These are new topics, and usually
` some of the papers -- a collection of
` papers in the field.
` Some of them are a -- wrote by
` several authors. So you always want to
` maybe rely on part of it, but not
` everything on it. So that's what I did in
` this case.
` Q. I guess that's unique to the
` fact that the course that you're teaching
` now is at the forefront of technology --
` A. Yes.
` Q. -- is that right?
` A. Yes.
` Q. So a textbook may not be as
`
`202-220-4158
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`

`Sharony, Jacob
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` helpful when you're working on an emerging
` technology, but it may be more helpful
` when you're dealing with a more
` established technology; is that fair?
` MR. MCNISH: Objection to form.
` THE WITNESS: Could you clarify
` again, please?
` BY MR. TUCKER:
` Q. Sure. Let me break it down,
` because I think I asked two questions
` there. A textbook might not be helpful
` when you are trying to convey information
` about an emerging technology?
` A. There could be some books
` written by some people that are -- they've
` a lot of knowledge in the fields that you
` may want to use. I personally like to --
` to bring it from several sources.
` There could be good books even
` for emerging technologies.
` Q. Okay.
` A. I think by -- it's intuitive
` that if you have, like, a -- courses that
` are especially undergraduate or even
` graduate teaching certain, you know,
`
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`

`Sharony, Jacob
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`CASE IPR 2017-00741
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`February 23, 2018
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` communications systems, this has been
` taught for years.
` So good books will always stay,
` you know -- will always be used. And some
` may -- lectures on using, you know,
` completely textbook.
` Q. Sure.
` A. So you can, in fact -- in my
` experience, some of these books -- so they
` provide you -- so you can buy the book,
` obviously. But they provide you with all
` the figures in that book. And this would
` be available, not for everyone, but people
` that teach.
` So you will be able to get,
` like, a PowerPoint or PDF of all figure in
` the book. And sometime there is a
` caption.
` So I heard that people sometime
` use that, you know. They tell them, you
` know, buy the book for the students, read
` the Chapter 2 and 3, and then they go
` through the figures and discuss it if they
` want just to rely on one source. I relied
` on multiple sources.
`
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`

`

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`CASE IPR 2017-00741
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` Q. Do you use articles as another
` set of materials in your courses?
` MR. MCNISH: Objection to
` relevance.
` THE WITNESS: What kind of
` articles?
` BY MR. TUCKER:
` Q. Yeah. Do you use, for example,
` IEE articles to convey information to your
` students?
` MR. MCNISH: Objection to
` relevance.
` THE WITNESS: Sometimes, yeah,
` if there is a good paper.
` BY MR. TUCKER:
` Q. We'll look at the top -- the
` first category in your CV, Mobius
` Consulting?
` A. Yes.
` Q. That's the consulting firm that
` you founded, correct?
` A. Correct.
` Q. And you still work there, I
` believe; is that correct?
` A. I do.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
`
`21
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` Q. The first bullet point, you
` state, "Professional consulting services
` in mobile wireless strategy."
` Do you see that?
` A. I do.
` Q. What do you mean by "mobile
` wireless strategy"?
` A. Many companies that are -- that
` want to become more productive, more cost
` effective, more efficient want to deploy
` and use wireless. I would say that even
` today any enterprise -- mobile wireless
` became so horizontal. It used to be
` mainly in vertical markets.
` But now, you know, it's in the
` enterprise and the like. For example,
` when I worked at Symbol Technologies, you
` know, we would basically, like in
` supermarket and point of sale, they would
` have, like, a Wi-Fi in previous generation
` before it was even called Wi-Fi. So we
` supplied that.
` And later we moved to what we
` called the carpet environment, like the
` enterprise. So many companies are
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
`
`22
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` interested in deploying wireless.
` I can tell you that last week I
` was in South Carolina. The company
` contacted me, and they wanted to -- help
` in -- you know, to put wireless into the
` systems.
` They supply all kind of piping,
` you know, gas, oxygen to hospitals. And
` there is a need for connecting all kind of
` sensors into simple systems. So people,
` officer, nurse can have indication if
` there is a problem. So there are always
` companies that are interested in that.
` Q. So in the example that you just
` gave for the company in South Carolina,
` you said they supply piping to hospitals,
` and they want to connect all of their
` sensors into simple systems.
` Are those sensors wireless?
` A. Not now. They want to do it
` wireless.
` Q. Okay.
` A. But it's very costly to put wire
` from every sensors.
` Q. I see.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
`
`23
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` A. And sometimes it's outside the
` building, so you have to dig trenches and
` the like. So wireless is more cost
` effective in this case.
` Q. And what part of the consulting
` engagement with the company in South
` Carolina relates to mobile?
` A. In that specific case, the
` sensor obviously are fixed into the pipe,
` and there are alarm panels. So they would
` like to send the signals.
` The mobility part could be
` health giver, taker, that, for example --
` I mean, this is one possibility to have
` like a pendant and, you know -- so they
` can get, you know, realtime, you know,
` indication. And then they can press and
` use voice over IP to communicate.
` But when you talk about sensors,
` sometimes they are fixed. So it's the
` wireless part, so. The wireless systems
` that are fixed --
` Q. So there are wireless --
` A. -- which has nothing to do with
` mobility.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
`
`24
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` Q. There are wireless systems that
` are not mobile?
` A. Right. But every mobile system
` is wireless.
` Q. And how would you describe
` "mobile"?
` A. In what context?
` Q. Well, you provide services in
` mobile wireless strategy?
` A. Right, right.
` Q. So which aspects of the strategy
` are mobile?
` MR. MCNISH: Objection to form.
` THE WITNESS: So as I said,
` there are many wireless systems which
` are not mobile. Perfect example, you
` can connect between two towers. They
` are fixed. Microwave links. They are
` not -- nothing is moving there.
` In the context of electronics
` communications, mobile means it's a
` unit what moves around and yet
` connected. So think about anytime,
` anywhere communication wherever you
` are.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
`
`25
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` So by definition, you must use
` wireless. As you move around, and you
` have to be all the time in contact, in
` communication, wireless is necessary.
` So the mobility aspects come --
` for example, think about the -- like a
` smart city where you want to provide
` first responders connectivity.
` So they usually will be in
` police cars or EMS, fire department.
` So they move all the time, but yet you
` need to provide connectivity at all
` time as they move around.
` So this, of course, is a mobile
` system -- mobile communication system.
` BY MR. TUCKER:
` Q. I believe you stated earlier
` that, in your opinion, a mobile system
` must be wireless; is that correct?
` A. Mobile communication system.
` Yeah, there is -- in this context that we
` deal, the word "mobile" is a general --
` general term. It means something is
` moving.
` In the context of electronic
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
`
`26
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` communication -- so anytime, anywhere,
` meaning wherever you are, you need to be
` connected.
` I think we become accustomed to
` it in today's world. You know, we are
` always connected wherever we are, assuming
` there is coverage.
` So mobile necessitate or rely on
` wireless connectivity. The reverse is not
` necessarily -- as I gave an example, it
` could be like a fixed wireless between two
` towers.
` Q. So you can have a wireless
` network that is not mobile; is that
` correct?
` MR. MCNISH: Objection. Form.
` THE WITNESS: When you say
` network --
` BY MR. TUCKER:
` Q. Let me rephrase.
` A. Okay.
` Q. You have wireless network
` communications that are not mobile; is
` that correct?
` MR. MCNISH: Objection. Form.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
`
`27
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` THE WITNESS: The example that I
` gave, there is a link between two
` tower. I wouldn't call it a network,
` so. It's a link. It's not a network.
` So a network is -- we have many
` devices, many infrastructure
` components that are basically
` connected to each other.
` And so if you have a device that
` is moving around or doesn't have to
` move around all the time, just
` changing its place --
` BY MR. TUCKER:
` Q. Uh-huh.
` A. -- so is -- if you want to
` connect it, it has to rely on wireless.
` Q. So that's the other side of the
` coin? I think the point that you just
` made, and correct me if I'm wrong, is that
` in order to be mobile, you must have
` wireless capabilities, in your opinion,
` correct?
` A. Mobile communication. Meaning
` you move around all the time. So, you
` know, we basically use the term
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
`
`28
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`
` untethered. You are untethered. You are
` free to go, roam around, yet you have to
` be connected like in a -- for example, it
` could be in the Wi-Fi. It would be
` relying on the cell tower when we drive,
` when we walk in the street.
` Even -- I can have like a --
` yeah, I mean, I think I explained it.
` Q. In your opinion, does a mobile
` networking technology necessarily require
` the use of wireless communications?
` A. Please repeat.
` Q. In your opinion, does a mobile
` networking technology necessarily require
` the use of wireless communications?
` MR. MCNISH: Objection to form.
` THE WITNESS: I think we said
` that, yes. As you move around and you
` want to be connected, you have to rely
` on wireless connection.
` BY MR. TUCKER:
` Q. Maybe I can give you an example
` that we can talk about and you can tell
` me --
` ///
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
`
`29
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`
` (Simultaneous unreportable
` cross-talk occurs.)
` (Court reporter requests one
` speaker at a time.)
` BY MR. TUCKER:
` Q. So I'll date myself. So I went
` to college in the year 2000, 2001. When I
` bought my laptop to go to college, it did
` not have wireless capability built in,
` right?
` A. Okay.
` Q. That was sort of typical back
` then, right? that laptops did not
` necessarily have wireless built in;
` instead, you needed a network adapter
` card.
` Do you remember that?
` A. I do.
` Q. And so when I got to college, my
` dorm room had an ethernet cable that I
` would plug in, and I would do my work from
` my dorm.
` Are you following me?
` A. Yes.
` Q. And if I wanted to go connect at
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
`
`30
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` Internet at the library, which was across
` campus, I would bring my laptop, and I
` would connect my laptop to an ethernet
` cable at the library.
` And if I went home for
` Thanksgiving, I would bring my laptop to
` my parents' and I would connect my laptop
` via an ethernet cable at my parents'
` house.
` Was that laptop a mobile device,
` in your opinion?
` MR. MCNISH: Objection to form.
` THE WITNESS: It's not mobile
` networking, because you are not
` connected anytime, anywhere.
` Meaning when you went from your
` dorm to the library, you were not
` connected. If I wanted to reach you
` or send you email or a file, you will
` not get it.
` So that's why I like to use, you
` know, anytime, anywhere.
` BY MR. TUCKER:
` Q. So you used the word -- my
` question was: Was that laptop that I
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
`
`31
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` described a mobile device?
` MR. MCNISH: Objection to form.
` MR. TUCKER: That wasn't a
` question. It was a statement.
` BY MR. TUCKER:
` Q. You answered: It's not mobile
` networking.
` So that was a different question
` that you answered. So I'll repeat the
` question that I asked, which was: Is the
` network in my example a mobile device, in
` your opinion?
` MR. MCNISH: Objection to form.
` THE WITNESS: You said "the
` network"? I think the sentence was
` not clear.
` BY MR. TUCKER:
` Q. You're right. So I tried to
` clarify, and I made it more complicated.
` My question is: Is the laptop
` that I described in my example a mobile
` device?
` MR. MCNISH: Objection to form.
` THE WITNESS: My answer is no.
` Obviously, you are moving. It's a
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`

`

`Sharony, Jacob
`
`CASE IPR 2017-00741
`
`February 23, 2018
`
`32
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` portable device. But the main point
` is you are not connected. So when we
` say "mobile," it's in the context of
` communication, right?
` Again, the term "mobile," you
` know, they use it even in gas station.
` Why? Because automobiles are coming.
` They move all the time.
` But in the context of electronic
` communication, you are all the time
` connected, untethered. And that's the
` whole notion of enterprise mobility,
` right?
` You basically -- you don't have
` to sit here. You can

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