throbber
G. Ligler
`UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`____________________________
`GOOGLE LLC,
`Petitioner
`v.
`BLACKBERRY LTD.
`Patent Owner
`_____________________________
`Case No. IPR2017-00911
`Case No. IPR2017-00912
`U.S. Patent No. 8,745,149 B2
`_____________________________
`
` DEPOSITION OF DR. GEORGE T. LIGLER
`Washington, DC
`February 27, 2018
`
` Reported by: Mary Ann Payonk
` Job No. 137673
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`GOOGLE EXHIBIT 1018
`Google LLC v. BlackBerry Ltd.
`IPR2017-00912
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` G. Ligler
`
`Page 2
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` February 27, 2018
` 9:11 a.m.
`
` Deposition of DR. GEORGE T. LIGLER, held
`at the law offices of Sidley Austin LLP, 1501 K
`Street, N.W., Washington, D.C., pursuant to
`Notice before Mary Ann Payonk, Nationally
`Certified Realtime Reporter and Notary Public
`of the District of Columbia, Commonwealth of
`Virginia, and State of New York.
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` G. Ligler
`APPEARANCES:
`ON BEHALF OF PETITIONER:
` PHILLIP CITROEN, ESQUIRE
` JOSEPH PALYS, ESQUIRE
` PAUL HASTINGS
` 875 15th Street, N.W.
` Washington, DC 20005
`
`ON BEHALF OF PATENT OWNER:
` SAMUEL DILLON, ESQUIRE
` CHING-LEE FUKUDA, ESQUIRE
` SHARON LEE, ESQUIRE
` SIDLEY AUSTIN
` 1501 K Street, N.W.
` Washington, DC 20005
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`DR. GEORGE T. LIGLER,
` called as a witness, having been duly
` sworn, was examined and testified as
` follows:
` EXAMINATION
`BY MR. CITROEN:
` Q. Good morning, Dr. Ligler.
` A. Good morning.
` Q. Can you state your name and address
`for the record, please.
` A. Sure. George Todd Ligler. The
`address is 4808 Cypress Ford Drive, Fuquay
`Varina, North Carolina 27526.
` Q. Thank you.
` Have you been deposed before?
` A. Yes, sir, I have.
` Q. How many times?
` A. On the order of 15.
` Q. Okay. And were those all as an
`expert?
` A. No, sir.
` Q. How many of those do you think were
`as an expert?
` A. 14.
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` Q. Okay. And of those 14, did those
`involve patents? Were those patent
`litigations?
` A. Not all of them. Some of them were.
` Q. Okay. About how many were patent
`litigations?
` A. On the order of 10.
` Q. Okay. So you've been through this
`before, so bear with me while I just go over
`the ground rules a little bit with you. So
`I'll be asking you a series of questions today
`and you'll be providing answers to those
`questions.
` Do you understand?
` A. Yes.
` Q. Okay. I ask that we not talk over
`each other just so the record is clear for the
`court reporter. Also, can you please answer
`all the questions orally instead of shaking
`your head or just making noises?
` A. Right.
` Q. Okay. I'll try to take breaks about
`every hour or so, but if you need a break just
`let me know and we'll stop.
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` Your counsel from time to time will
`be making objections, but as we go along please
`still answer the question unless you're
`instructed not to do so.
` Do you understand so far?
` A. Yes.
` Q. You understand you're not supposed to
`discuss the substance of your testimony during
`breaks until the deposition is over?
` A. I understand that, yes.
` Q. Any reason you're not able to testify
`fully and completely today?
` A. No, sir.
` Q. And you understand you're under oath?
` A. Yes.
` Q. Great. So do you understand why
`you're here today?
` A. Yes.
` Q. And why is that?
` A. Well, to be deposed on declarations
`that I have submitted in inter partes
`reexaminations.
` Q. Okay. Did you bring anything with
`you today?
`
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` A. I did.
` Q. And what did you bring?
` A. Two clean copies -- excuse me. A
`clean copy of both of my declarations.
` Q. Okay.
` A. And these are clean copies of some of
`the exhibits in the IPR, primarily references.
` Q. Okay. Other than references, what
`else did you have in that binder?
` A. Okay. A declaration of Dr. Dan
`Olsen, Exhibit 1002.
` (Exhibit No. 1002, previously marked, was
` referenced and indexed.)
` (Exhibit No. 1003, previously marked, was
` referenced and indexed.)
` (Exhibit No. 1004, previously marked, was
` referenced and indexed.)
` (Exhibit No. 1011, previously marked, was
` referenced and indexed.)
`BY MR. CITROEN:
` Q. Okay.
` A. Exhibit 1003, the vitae of Dan R.
`Olsen. Let's see, Exhibit 1004, prosecution
`history. Then Exhibit 1011, plaintiff
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`Blackberry's opposition to defendant Blue
`Products' motion to dismiss pursuant to FED R
`CIV P 12(b)(6). And the rest are references.
` Q. Okay. And the references are all
`exhibits to this proceeding?
` A. Yes, sir, that's my understanding.
` Q. Okay. Are there any documents in
`there that were not an exhibit in this
`proceeding?
` A. I don't believe so, sir.
` Q. Okay, great. Thank you.
` So the two declarations you have
`there, those declarations pertain to
`U.S. Patent Number 8,745,149; is that correct?
` A. Yes, sir.
` Q. Is it okay if I refer to that as the
`'149 patent?
` A. Yes.
` Q. Okay, thank you.
` And did you review the '149 patent in
`preparation for today?
` A. In preparation for today, yes, sir.
` Q. You reviewed that patent in
`preparation of your declaration as well?
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` A. Yes, sir, I did.
` Q. Do you understand the teachings of
`that patent?
` MR. DILLON: Objection, form.
` A. I believe I do, yes.
` Q. Okay. So your declarations, did you
`prepare those declarations yourself?
` MR. DILLON: Objection. To the
` extent it calls for or seeks protected
` information related to preparation of
` his report or communications with
` counsel, I caution the witness to
` exclude from his answer any protected
` information.
` A. I prepared the initial draft --
` Q. Okay.
` A. -- of the declarations myself.
` Q. Okay.
` A. Then there was a process through
`which they were completed, interacting with
`counsel.
` Q. Okay. And which counsel did you
`interact with?
` A. Well, I interacted with the three
`
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`attorneys in this room from Sidley Austin.
` Q. When were you first contacted with
`respect to these proceedings?
` A. It would have been sometime in March
`of 2017, sir.
` Q. Okay. And when were you actually
`engaged for this proceeding?
` A. In March of 2017, sir.
` Q. Okay. Who contacted you?
` A. Ching-Lee Fukuda did.
` Q. If you could look at your
`declaration, I'll call it the Appelman
`declaration, if that's okay with you.
` A. Sure.
` Q. Appelman is referring to
`Exhibit 1012.
` A. IPR 00911, sir?
` Q. Correct.
` A. Okay.
` Q. If you go to the last page of that
`declaration --
` A. Yes.
` Q. -- is that your signature there?
` A. Well, no. It's /NAME/.
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` Q. Okay.
` MR. CITROEN: For the record, we're
` marking this as Google Exhibit 1017.
` MR. DILLON: Can we take a quick
` break?
` MR. PALYS: Let him finish putting
` it on the record.
` MR. CITROEN: It's the declaration
` of Dr. George Ligler for IPR2017-00911.
` (Exhibit No. 1017 was marked for
` identification.)
` MR. PALYS: Okay, let's take a
` break.
` MR. CITROEN: Yeah let's go off the
` record for a second.
` (Discussion held off the record.)
` MR. DILLON: That was the final
` version of his declaration just prior to
` the addition of his signature.
` MR. CITROEN: Okay. Fair enough.
`BY MR. CITROEN:
` Q. So Dr. Ligler, during the break did
`you have conversations with counsel?
` A. I did.
`
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` Q. Okay. What did you talk about with
`counsel?
` A. This document and the final page of
`the document where it has /NAME/.
` Q. What specifically did you discuss
`about that document?
` A. I indicated that this was a document
`that had been sent to me in PDF form after the
`filing, and that I had printed it out and
`brought it with me.
` Q. Okay. Do you recall when you signed
`the declaration?
` A. It would have been on December 15,
`and it was done via sending my signature to
`counsel after reviewing the final draft.
` Q. Okay. And this version of the
`declaration that's marked Exhibit 1017, is that
`the version of the declaration that you used
`for preparing for today's deposition?
` A. Yes.
` Q. Okay. Do you have a copy of the
`declaration for the other proceeding, which is
`IPR2007-912?
` A. I do.
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` Q. Can I see a copy of it please?
` A. Of course.
` MR. CITROEN: So let's mark this
` document as Exhibit 1017 for
` IPR2017-00912. And this is titled
` Declaration of Dr. George T. Ligler.
` (Exhibit No. 1017 was marked for
` identification.)
`BY MR. CITROEN:
` Q. Can you turn to the last page of what
`is now marked Exhibit 1017 for IPR-912?
` A. 912 has a different exhibit number,
`sir.
` Q. It should be Exhibit 1017. So yeah,
`just to be clear, that'll have the same exhibit
`number but different proceedings. One's 911;
`one's 912.
` A. Thank you.
` Q. No problem. If you could go to the
`last page of 1017 for the 912 proceeding.
` A. Okay. I'm there, sir.
` Q. Is that your signature on the last
`page?
` A. No, it's not.
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` Q. Okay. What appears on the last page?
` A. Well, in the place where the
`signature would be, it is/NAME/.
` Q. Okay. Is this a document that you
`used to prepared for today's deposition?
` A. Yes, sir, it is.
` Q. Okay. And were these two exhibits,
`which are both labeled 1017 for proceedings 911
`and 912, provided to you by counsel?
` A. Yes, sir, they were.
` MR. CITROEN: Okay. I'm going to
` give you a copy of the as-filed
` declaration in the 911 proceeding. This
` is Exhibit 2007 in the 911 proceeding.
` (Exhibit No. 2007, previously marked, was
` referenced and indexed.)
`BY MR. CITROEN:
` Q. And Dr. Ligler, just to make our
`discussions easier, is it okay if we call that
`declaration the Appelman declaration, referring
`to the prior art reference Appelman?
` A. Yes, sir, that's fine.
` MR. CITROEN: Okay. If you want to
` write on there to make it easier for
`
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` you, that's fine. I'm going to hand you
` your as-filed declaration in the 912
` proceeding, and this is Exhibit 2007 as
` well.
` (Exhibit No. 2007, previously marked, was
` referenced and indexed.)
`BY MR. CITROEN:
` Q. And if it's okay with you, can we
`call that declaration the Graham declaration?
` A. Sure.
` Q. And that's referring to -- Graham is
`referring to Exhibit 1005; correct?
` A. Yes, sir.
` Q. You said earlier you spent time
`preparing for today's deposition; correct?
` A. I did.
` Q. Approximately how much time did you
`spend preparing for today's deposition?
` A. Most of the day yesterday, sir.
` Q. Okay. Approximately how many hours?
` A. Approximately 10 hours.
` Q. Okay. And did you spend any time
`preparing for this declaration before
`yesterday?
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` A. For the deposition, sir?
` Q. Yes, I'm sorry, for the deposition.
` A. Yes, I did, sir.
` Q. Okay. And approximately how much
`time in total did you spend preparing for
`today's deposition?
` A. Perhaps 16 hours, sir.
` Q. Okay. And what did you do to
`prepare?
` MR. DILLON: Objection. To the
` extent this seeks protected information
` related to the preparation of his report
` or communications with counsel, I
` caution the witness to exclude from his
` answer any protected information.
` A. Prior to yesterday, I reviewed
`portions of my declaration and -- my
`declarations, excuse me, and some excerpts from
`some of the references.
` Q. Okay. So other than the documents
`that you just referenced did you review any
`other materials in preparation for today's
`deposition?
` A. Yesterday, yes.
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` Q. Okay. And what documents did you
`review yesterday?
` MR. DILLON: Objection. To the
` extent it seeks protected information
` related to communications with counsel,
` I caution the witness to exclude from
` his answer any protected information.
` A. With that advice, I think nothing
`that's not of record in the proceedings.
` Q. Okay. So everything that you
`reviewed is an exhibit in one of these two
`proceedings; correct?
` A. Yes, sir.
` Q. All right. Do you feel that you're
`prepared to answer my questions today?
` MR. DILLON: Objection to form.
` A. Yes, sir, I do.
` Q. Okay. Earlier, you said that you
`were deposed about 10 times in proceedings
`involving patents; is that right?
` A. Yes, on the order of 10 times.
` Q. Okay. To the best of your ability,
`can you go through those and identify the
`proceedings by name? If you can.
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` A. Well, I'll do the best I can.
` Q. Sure, sure.
` A. Cyrix v. Intel, Eastern District of
`Texas, and that would have been in the early to
`mid 1990s.
` Q. Okay. And did you provide deposition
`testimony in that proceeding?
` A. Yes, sir, I did.
` Q. Did you represent the plaintiff or
`the defendant?
` A. I didn't represent anyone. I was
`retained by counsel for the -- well, what was,
`in fact, the plaintiff in one case and the
`defendant in another. Related cases.
` Q. Okay. So who retained you?
` A. I was retained by counsel for Cyrix
`Corporation, and that would have been Fish &
`Neave.
` Q. And what was the subject matter of
`that litigation?
` A. Microprocessor technology, sir.
` Q. Thank you.
` Okay, so you said that was in the
`early 1990s; correct?
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` A. Yes.
` Q. Okay. And do you recall any of the
`other proceedings that you were an expert?
` A. Yes, sir, I do.
` Q. And can you tell me the next one?
` A. I'm not sure that it will be
`chronologically the next one --
` Q. That's fine.
` A. -- but the next one that I recall is
`one involving Motorola. And I'm trying to
`remember what the other party was. But
`Motorola, and the technology was cellular
`modems, modems for cellular telephones. And
`modems. More generally, modem technology.
` Q. Okay. Do you recall the time frame?
` A. Mid to late 1990s, sir.
` Q. Okay. And did you provide deposition
`testimony in that proceeding?
` A. Yes, sir, I did.
` Q. Okay. You were retained by Motorola
`in that case?
` A. I was retained by counsel for
`Motorola, sir.
` Q. Okay. Do you recall any of the other
`
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`proceedings that you were involved in?
` A. Yes, sir, I do.
` Q. Okay.
` A. Samsung v. Inventec, I-N-V-E-N-T-E-C.
`That was in the Southern District of Texas, and
`it was in the late 1990s.
` Q. And what was the subject matter of
`that proceeding?
` A. Personal computer, some of the
`technology underlying personal computers and
`particularly, computer motherboards.
` Q. To back up for one second, the
`Motorola case about cellular modems, do you
`recall where that case was, what court?
` A. No. It was about modem technology
`more generally. It was not limited to cellular
`modems, sir.
` Q. Thanks for that clarification. Okay.
` Do you recall any other proceedings
`that you were involved in?
` A. Yes, sir, I do.
` Q. Okay.
` A. Ampex v. Kodak.
` Q. How do you spell Ampex?
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` A. A-M-P-E-X.
` Q. Who did you represent in that case?
` A. Well, I was retained by counsel for
`plaintiff, Ampex.
` Q. And what was the subject matter of
`that proceeding?
` A. Digital camera technology, sir.
` Q. What specifically with respect to
`digital cameras?
` A. It had to do with elements of the
`image capture chain, so the chain of
`electronics involved from the time the user
`takes the picture to the time that a JPEG or
`some other format of digital image is stored in
`the memory in the camera.
` Q. Okay. Did it involve user interfaces
`of digital camera at all?
` A. It did. I would say that was not
`primarily about user interfaces. It was
`primarily about -- directed toward the internal
`processing of the information captured by the
`camera and subsequent processing to the point
`that one had a digital image stored on the
`camera.
`
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` Q. Okay. And do you recall the time
`frame for that case?
` A. Somewhere in the first decade of --
`between 2000 and, say, 2008.
` Q. And which court was that in?
` A. That was in the District of Delaware,
`sir.
` Q. And do you recall any more cases that
`you were involved in?
` A. Yes, sir, I do.
` Q. Okay.
` A. Ericsson v. Samsung.
` Q. And what was the time frame of that
`case?
` A. It was between 10 and 15 years ago, I
`believe.
` Q. And do you recall which court that
`was in?
` A. No, sir.
` Q. Okay. Do you recall the subject
`matter of that case?
` A. Yes, sir. It had to do with cellular
`telephones and cellular infrastructure.
` Q. And what specifically about the
`
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`cellular telephones?
` A. I'm having trouble recalling that.
` Q. Okay. Do you remember if it was
`hardware functionality or --
` A. Hardware functionality and software.
`Definitely was looking at schematics and was
`looking at testimony with regard to the
`software.
` Q. Okay. Thank you.
` Do you recall any other proceedings
`that you were involved in?
` A. Yes, sir.
` Q. Okay.
` A. Let's see, as a testifying expert,
`right? Or at -- more generally?
` Q. Cases that you were an expert and
`that involved patents.
` A. Okay.
` Q. And that you provided testimony.
` A. That I provided testimony?
` Q. Yes, sir.
` And just to be clear, when I say
`"testimony," it could be in the form of a
`declaration or an expert report, deposition
`
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`testimony.
` A. So something like a Markman
`declaration would --
` Q. Yes.
` A. -- be included?
` Q. Yes, sir.
` A. Okay. There was a case involving the
`Ademco Corporation in Minneapolis. Ademco was
`the defendant.
` Q. How do you spell that?
` A. A-D-E-M-C-O.
` Q. That was a patent case?
` A. Yes.
` Q. And do you recall the time frame for
`that case?
` A. I think it was in the late 1990s. It
`might have slipped into this century.
` Q. Okay. And what was the subject
`matter of that case?
` A. Burglar alarm systems.
` Q. All right. Do you recall any other
`proceedings?
` A. Yes. There was a proceeding up in
`Wisconsin where the subject matter was software
`
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`for hospitals or healthcare systems, doctors'
`practices.
` Q. What kind of software was involved?
` A. If one assumed that one had a
`practice of physicians, a number of physicians
`and a number of patients, it was the software
`that registered the case histories, what had
`happened, handled billing, things of those
`natures, things of that nature.
` Q. Okay. Do you recall the parties that
`were involved in that case?
` A. No. And that wasn't a patent case.
` Q. That was not a patent case?
` A. I'm sorry. I shouldn't have added
`that one.
` Q. That's fine. No problem. Do you
`recall any other --
` A. Yes, sir, I do.
` Q. -- proceedings? Really testing your
`memory.
` A. Yeah. Eastern District of Texas,
`Apple, Smartflash v. Apple. Smartflash is one
`word.
` Q. What was the time frame for that
`
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`proceeding?
` A. That would have been this decade.
`I'm thinking somewhere on the order of 2014,
`2015.
` Q. Okay. Did you represent Apple or
`Smartflash?
` A. I was retained by counsel for Apple.
` Q. And what was the subject matter of
`that case?
` A. It was -- it had to do with digital
`rights.
` Q. Can you be more specific?
` A. Sure. Various technology involving
`digital rights management. It's called DRM in
`the field.
` Q. Okay.
` A. And it was with regard to both the
`iOS platforms. Apple was the defendant. And
`Macs, MacOSs.
` Q. Okay. We can go on to the next
`proceeding if you recall any more.
` A. I'm sure there were several
`additional but those are the ones I can recall
`off of the top of my head at this moment.
`
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` G. Ligler
` Q. Okay. Thank you. Good memory.
` If you could look at your Appelman
`declaration, so it's the declaration labeled
`Exhibit 2007 in the 911 proceeding.
` A. Yes, sir.
` Q. If you could turn to paragraph 7.
` A. Yes, sir.
` Q. Here you state that you've been
`involved in the research, development,
`specification, and/or assessment of a number of
`systems involving presentation of graphical
`images and user interfaces on displays, and
`then you have in parentheses a list of
`examples.
` A. Yes.
` Q. Do you see that? Okay. I'd like to
`talk to you about these specific examples that
`you provide here.
` So the first one you see there is
`graphical user interfaces and data applications
`for cellular telephones and personal computers.
` Do you see that?
` A. I do.
` Q. Do you recall the time frame of that
`
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`project?
` A. Well, there were several projects
`involved, sir.
` Q. Okay. Can you tell me about that?
` A. Sure.
` Q. About those projects.
` A. Sure, sure. Worked on graphical user
`interfaces and data applications for cellular
`telephones in the early to mid 1990s. One
`project in particular was for a major cellular
`carrier. I was retained by a major cellular
`carrier to work on advanced product development
`for improved use of mobile phones in trucks.
` Q. And how did the user interface in
`those data applications for cellular telephones
`improve use of mobile phones in trucks?
` A. Well, in several ways. One aspect of
`the system was integration of vehicle location.
`Remember, we're in the early 1990s now. It's
`not as ubiquitous as it is today. Vehicle
`location systems and routing instructions to
`improve the communications between the dispatch
`of a lighter-than-load. This was focused on
`lighter-than-load trucking firms.
`
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` Q. Okay.
` A. And to improve the communications
`between the driver and dispatch.
` Q. And what types of communications are
`you referring to?
` A. Routing, present situation,
`emergencies, things of that nature.
` Q. And these communications, were they
`automatically sent by the mobile device or was
`it the driver who would send the information?
` A. Both.
` Q. Okay. And how would a driver use the
`interface to communicate the information?
` A. Well, there was a limited set of
`functionality that was going to be provided to
`the driver.
` Q. Okay.
` A. And this was product planning phases,
`so there were rudimentary GUIs worked out,
`because they were customized to the limited
`functionality that the driver would have. This
`was not going to be a cellular telephone that
`the driver could use to call friends, relatives
`and -- you know, it was going to be specific to
`
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` G. Ligler
`the business purposes. So there was a
`customized GUI interface for the specific
`applications.
` Q. So the GUI interface for these
`applications, the driver could manipulate those
`interfaces to communicate messages --
` A. Yes.
` Q. -- to another point? Okay.
` Did those messages have timestamps?
` A. I don't recall.
` Q. Do you recall any sort of time
`associated with those messages?
` MR. DILLON: Objection to form.
` A. Other than the fact that timestamps
`were kept within the cellular infrastructure
`for the message transmissions, no, sir.
` Q. Okay. When you say that the
`timestamps were kept within the cellular
`infrastructure, can you explain what that
`means?
` A. Sure. If you look at your cellular
`billing statement today or in that time frame,
`you would have a certain -- minutes were kept
`track of.
`
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` Q. Okay.
` A. And those minutes were timestamped in
`terms of when the call was made. So the
`infrastructure automatically kept track of that
`type of information.
` Q. Okay. But the interface on the
`cellular device wouldn't output that time
`information?
` A. As I said, I don't recall.
` Q. Okay. You stated -- or, excuse me,
`you state here in your declaration in paragraph
`7 that it's the applications for cellular
`telephones and personal computers. What
`specifically was the purpose of the personal
`computers in this -- these projects?
` MR. DILLON: Objection to form.
` A. In the mid to late 1990s, I consulted
`for Compaq Computer Corporation, which was
`then, prior to its acquisition by HP, the
`largest manufacturer of personal computers in
`the world.
` Q. Okay.
` A. And while I looked at a number of
`different technology areas with Compaq, one of
`
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`them was graphical user interfaces on the
`personal computer.
` Q. Were these personal computers
`performing or -- strike that.
` Were these personal computers
`presenting the same GUI interface that the
`cellular telephones were?
` A. Oh, no, no, no. The reason I say
`that is because the cellular telephone project
`that we have discussed was a very specific
`customized GUI interface to that application.
` Q. So the personal computers aspect was
`a separate project from the cell phone project
`that we just discussed?
` A. Yes, sir, that's correct.
` Q. Okay. You stated that one of the
`technology areas that you looked into with
`Compaq was graphical user interfaces on the
`personal computer.
` What specifically were you looking at
`with respect to the graphical user interfaces
`on the personal computer?
` A. Primarily performance, sir.
` Q. What do you mean by "performance"?
`
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` A. How long it would take to render the
`information on the GUI. So one ended up having
`to trade off space between the amount of
`complexity that a given screen of the GUI would
`have and the rate that it took to present that
`information to the user, and would that be
`acceptable. So it was basically functionality
`and performance tradeoffs.
` Q. So was the GUI performance associated
`with any particular type of information that
`was being displayed or was it more just general
`performance criteria?
` MR. DILLON: Objection to form.
` A. More just general performance
`criteria, sir, with examples.
` Q. Do you recall any of the examples?
` A. No, sir.
` Q. So you said that one ended up having
`to trade off space between the amount of
`complexity that a given screen of the GUI would
`have and the rate that it took to present that
`information.
` What do you mean by "trade off
`space"? So in particular, the term "space,"
`
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`what do you mean by "space" in that sentence?
` MR. DILLON: Objection to form.
` A. I was using a term of art in computer
`system engineering, "tradespace."
` Q. Okay.
` A. And there are several parameters that
`went into the consideration of what the
`trade -- tradeoff space was.
` Q. Okay. Were you looking at devices
`with different tradeo

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