UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` - - - - - - - - - - - - - -x
`LSI CORPORATION AND AVAGO :
`TECHNOLOGIES U.S., INC., :
` Petitioner, : IPR2017-01068
` v. : U.S. Patent No.
`REGENTS OF THE UNIVERSITY : 5,849,601 B2
`OF MINNESOTA,
` Patent Owner.
` - - - - - - - - - - - - - -x
`
` Virtual Deposition of EMINA SOLJANIN, Ph.D.
` Friday, June 12, 2020
` 10:00 a.m.
`
` Job No.: 301513
` Pages: 1 - 107
` Reported By: Dutcheen O. Cameron, RMR, CRR
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`UMN EXHIBIT 2011
`LSI Corp. et al. v. Regents of Univ. of Minn.
`IPR2017-01068
`
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`Page 1 of 139
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`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` - - - - - - - - - - - - - -x
`LSI CORPORATION AND AVAGO :
`TECHNOLOGIES U.S., INC., :
` Petitioner, : IPR2017-01068
` v. : U.S. Patent No.
`REGENTS OF THE UNIVERSITY : 5,849,601 B2
`OF MINNESOTA,
` Patent Owner.
` - - - - - - - - - - - - - -x
`
` Virtual Deposition of EMINA SOLJANIN, Ph.D.
` Friday, June 12, 2020
` 10:00 a.m.
`
` Job No.: 301513
` Pages: 1 - 107
` Reported By: Dutcheen O. Cameron, RMR, CRR
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`UMN EXHIBIT 2011
`LSI Corp. et al. v. Regents of Univ. of Minn.
`IPR2017-01068
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`Page 1 of 139
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`Transcript of Emina Soljanin, Ph.D.
`Conducted on June 12, 2020
`
`2
`
` Virtual Deposition of EMINA SOLJANIN, Ph.D.,
`
` Pursuant to notice, before Dutcheen O.
`Cameron, RMR, CRR, Notary Public in and for the
`Commonwealth of Pennsylvania.
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`3
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` A P P E A R A N C E S
` ON BEHALF OF PETITIONER:
` EDWARD MAYLE, ESQUIRE
` KRISTOPHER REED, ESQUIRE
` KILPATRICK TOWNSEND & STOCKTON, LLP
` 1400 Wewatta Street
` Suite 600
` Denver, CO 80202
` 303-571-4000
`
` ON BEHALF OF PATENT OWNER:
` PATRICK MCELHINNY, ESQUIRE
` MARK G. KNEDEISEN, ESQUIRE
` K&L GATES, LLP
` 210 Sixth Avenue
` Pittsburgh, PA 15222
` 412-355-6500
`
`ALSO PRESENT:
` Annie Brown, Remote Technician
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`Conducted on June 12, 2020
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`4
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` I N D E X
` EXAMINATIONS PAGE
` EMINA SOLJANIN, Ph.D. 10
` EXAMINATION 10
` BY MR. McELHINNY
`
` E X H I B I T S
` (Previously Marked and Referenced
` And Attached to Transcript)
`Exhibit 1010 15
`Exhibit 2007 17
`Exhibit 2008 19
`Exhibit 1001 23
`Exhibit 1009 48
`Exhibit 1007 60
`Exhibit 1011 81
`Exhibit 2009 93
`Exhibit 2010 97
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`5
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` P R O C E E D I N G S
`COMMENCING -- 10:00 A.M. EST
` MR. McELHINNY: Counsel for LSI, I
`understand that you folks have objected to
`recording this via video. You know, we don't
`quite understand why, but we're happy to have it
`recorded, and the court reporter has indicated
`that it facilitates her finished product on the
`transcript.
` So, you know, we understand that you can
`object or not. If you do object, you can
`understand that we will lodge a similar objection
`to any effort to record the witness or witnesses
`that we proffer in this proceeding.
` MR. REED: Yes. We do not want this video
`recorded. The rule requires it to be by consent
`of the parties. We do not consent to the video
`recording, and I understand that would be
`reciprocal on the other side.
` MR. McELHINNY: So you don't want
`Dr. Soljanin to be videoed?
` MR. REED: That's correct.
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`6
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` MR. McELHINNY: All right. So if you're
`okay with the fact that -- I mean, so you
`understand that we're not going to permit video of
`our witnesses either, in light of that, and that
`the court reporter's preference is that it
`recorded so that she can prepare a better
`transcript?
` MR. REED: We understand, but we maintain
`our objection.
` MR. McELHINNY: Okay.
` COURT REPORTER: I have a question. Would
`just the audio recording be allowed so that I can
`have the audio recording also? Because sometimes
`being part of the group and not being at the
`main -- the audio is much clearer through the
`original -- through the host.
` MR. REED: No, of course. Audio is fine.
`That's perfectly fine.
` COURT REPORTER: Can we do that, Annie?
` REMOTE TECHNICIAN: I think as long as
`both sides agree to that, I think that that should
`be fine. I can double-check it with my office
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`7
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`while the recording is going on -- or while the
`depo is going on, rather. But until they give me
`the answer one way or the other, I can, you know,
`record it and then delete it if they say that it's
`not permissible.
` But if both parties are okay with it, then
`I can at least start recording that way.
` MR. McELHINNY: We're happy with it to be
`recorded either way. So certainly we won't object
`to the audio.
` MR. REED: No, we understand the role of
`the audio in getting the transcript correct. So
`that's fine.
` REMOTE TECHNICIAN: Okay. Terrific. So
`then what I will be doing is once we are ready to
`start here, there is a script that I will have to
`read on and the reporter can then swear in the
`witness. Once the reporter is done swearing in
`the witness, I will stop the Zoom recording, but I
`will continue with the audio backup recording.
` And then just as a matter of
`clarification, Mr. McElhinny, when you call up the
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`8
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`exhibits, I have the ability to share them on my
`screen so that everybody is able to see them.
`Would you like me to do that, or does everybody
`have hard copies and you'd prefer not to do that?
` MR. McELHINNY: Everyone has hard copies,
`so I think what we'd probably like is for you not
`to do that unless we ask for it specifically. I
`mean, it may make sense in some settings to pull
`them up so we can talk about them, but I'm
`reasonably comfortable that we won't need to do
`that. And since everybody has a hard copy, we
`should be good to go.
` REMOTE TECHNICIAN: Okay. Sounds
`terrific. All right. Well, then, thank you very
`much. With all of that being said, does anybody
`have any further questions or concerns?
` * * *
` (Whereupon, an off-the-record discussion was
` held.)
` * * *
` MR. REED: And Mr. Mayle will be defending
`the witness today, just for the record.
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`9
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` REMOTE TECHNICIAN: All right. If
`everyone's ready, I'm going to go ahead and get
`this recording started here. Stand by.
` ZOOM NARRATOR: This meeting is being
`recorded.
` REMOTE TECHNICIAN: Thank you to everyone
`for attending this proceeding remotely. We
`anticipate this will run smoothly; however, I
`apologize in advance for any interruptions.
` Please have your video enabled to help
`identify who is speaking. If you are unable to
`connect with video and are connecting via phone,
`please identify yourself each time before
`speaking. Thank you.
` COURT REPORTER: Will counsel please
`stipulate that in lieu of formally swearing in the
`witness, the reporter will instead ask the witness
`to acknowledge that their testimony will be true
`under the penalties of perjury, that counsel will
`not object to the admissibility of the transcript
`based on proceeding in this way, and that the
`witness has verified that she is, in fact,
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`10
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`Dr. Soljanin?
` Do both counsel agree?
` MR. McELHINNY: Counsel for the University
`of Minnesota, this is Pat McElhinny, and, yes, we
`agree to that.
` MR. MAYLE: Counsel for petitioners,
`LSI Corporation and Avago Technologies U.S. Inc.,
`Ted Mayle, we also agree.
` COURT REPORTER: The witness,
`Dr. Soljanin, do you hereby acknowledge that your
`testimony will be true under the penalties of
`perjury?
` THE WITNESS: I do.
` COURT REPORTER: Thank you.
` MR. McELHINNY: Are we ready to go, then?
` REMOTE TECHNICIAN: Yes.
` MR. McELHINNY: Thank you.
` * * *
` EMINA SOLJANIN, Ph.D., having acknowledged
`that her testimony will be true under penalties of
`perjury, was examined and testified as follows:
` EXAMINATION
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`11
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`BY MR. McELHINNY:
` Q Good morning, Dr. Soljanin. Thank you for
`your attendance today via video. This is a little
`new for all of us, but we appreciate you agreeing
`to participate in this way. As I indicated, my
`name is Pat McElhinny. I am with the law firm of
`K&L Gates. I represent the patent owner in this
`case, the University of Minnesota.
` Could you state your full name for the
`record, please.
` A My name is Emina Soljanin. It's
`E-M-I-N-A, S-O-L-J-A-N-I-N.
` Q And would you tell us your residential and
`business address?
` A My residential address is 26 Britten Road,
`Green Village, New Jersey 07935. My university
`address is 94 Brett Road, New Brunswick. I'm not
`sure about the zip code.
` Q And then that's Rutgers University?
` A That is Rutgers University electrical
`engineering department.
` COURT REPORTER: I'm sorry. Doctor, could
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`you please repeat your home address for me.
` THE WITNESS: 26 Britten,
`B-R-E-T-T-E-N (sic), Road, Green Village, New
`Jersey 07935.
` COURT REPORTER: Thank you.
` Q And you understand that -- today that
`you've agreed that you're testifying effectively
`under oath and that your answers are subject to
`the penalty of perjury?
` A I do.
` Q And on the call with us are counsel for
`the petitioners in this proceeding, Mr. Mayle and
`Mr. Reed; you understand that?
` A Yes.
` Q And those two gentlemen retained you in
`connection with this proceeding to assist LSI and
`Avago, correct?
` A Could you say that again, the two
`gentlemen?
` Q Those gentlemen retained you to assist
`their clients, LSI and Avago, correct?
` A Yes.
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` Q So is there any reason that you can't be
`truthful or accurate today?
` A No.
` Q And just so that we're all on the same
`page, you've given depositions before, correct?
` A This is my third deposition.
` Q And you understand that you need to give
`verbal answers and let me finish the question
`before you answer so that we can get a clear
`transcript?
` A I do.
` Q And will you agree with me that if you
`don't understand or don't hear a question, that
`you'll ask me to restate or rephrase it?
` A Yes.
` Q Is there anyone in the room with you
`today?
` A No.
` Q And do you have a means to communicate
`separately with Mr. Reed or Mr. Mayle --
` A No.
` Q -- aside from -- okay.
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` And our office sent to you a big stack of
`potential exhibits today. Do you have that with
`you?
` A I received them this morning. Yes, I do.
` Q Okay. And so were there any issues? You
`have the package of all the documents?
` A Yes. I do.
` Q Okay. So let me ask you this: I take it
`you've been retained to provide expert testimony
`on behalf of LSI and Avago in this proceeding,
`correct?
` A Yes.
` Q And when were you retained?
` A I don't remember the first time, the
`first -- the initial contact. I believe it was
`2016.
` Q Okay. Are you charging LSI and Avago an
`hourly rate for your services?
` A Correct.
` Q And what is that rate?
` A $425.
` Q You said 495?
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` A 425.
` Q Okay. Thank you. And can you -- do you
`have a sense as to how much in total you've billed
`for this matter?
` A Could you say that again?
` Q Do you have a sense as to how much in
`total you have billed on this matter?
` A How much in total, actually, I don't
`because the last time I sent an invoice was 2018.
` Q Okay. Dr. Soljanin, you provided a
`declaration in this proceeding, this IPR
`proceeding, and you understand that?
` A Yes.
` (LSI Corp. Exhibit 1010 previously marked
`for identification and is attached to the
`transcript.)
` Q And if you take a look at the stack of
`your exhibits, is that declaration the declaration
`that has been marked on the front page as
`Exhibit 1010?
` A That was -- yes, it is this folder.
` (Court reporter interrupts for
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`clarification.)
` A It's this binder.
` Q Yes. That's -- that looks like the
`exhibit. Is that the declaration that you
`provided in this IPR proceeding?
` A Yes.
` Q And you signed that declaration under
`oath; that's your understanding?
` A Yes.
` Q And you prepared it carefully before you
`signed it; is that correct?
` A To the best of my ability.
` Q Now, you understand that there's a
`separate proceeding between these two parties
`regarding what we'll call "the Moon patent" or
`"the '601 Patent." Do you understand that, that
`there's two proceedings?
` A I know that there was a litigation for
`which I also had a declaration and deposition. Is
`that what you are referring to?
` Q It is, and I'll call that "the District
`Court litigation." And so as you indicated, you
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`signed a declaration in that proceeding as well,
`correct?
` A Yes.
` (UMN Exhibit 2007 previously marked for
`identification and is attached to the transcript.)
` Q And is that declaration the document that
`has been marked as Exhibit 2007 in the package?
` A Could you tell me the folder that this is,
`or --
` MR. MAYLE: First before that --
` A I just got the exhibits this morning, so
`that's -- okay.
` MR. MAYLE: Sorry to interrupt.
`Petitioners object to the admission of this
`exhibit, I believe it's 2007, as a trial exhibit
`for this proceeding as both hearsay and outside
`the scope of Professor Soljanin's direct
`testimony. We also make a standing objection as
`to any questions, if there will be any, regarding
`Exhibit 2007 as outside the scope of Professor
`Soljanin's direct testimony.
` Q Professor Soljanin, do you see that
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`document?
` A Yes, this is the thinner folder.
` Q Okay. Good.
` (Court reporter interrupts for
`clarification.)
` A I just said that there is a thick and thin
`folder.
` Q So you agree that Exhibit 2007 is the
`declaration that you signed under oath in the
`District Court litigation?
` A Yes.
` Q And is that also a document that you
`prepared carefully before signing it?
` A Yes.
` Q And if you take a look at the -- I think
`it's probably the thickest document that you have,
`this Exhibit 2008.
` MR. MAYLE: Petitioners object to the
`admission of Exhibit 2008, as well, as a trial
`exhibit. It's both hearsay and outside the scope
`of Professor Soljanin's direct testimony. We also
`make a standing objection as to any questions, if
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`there are any, regarding Exhibit 2008 as outside
`the scope of Professor Soljanin's direct
`testimony.
` (UMN Exhibit 2008 previously marked for
`identification and is attached to the transcript.)
` Q Dr. Soljanin, have you found the
`transcript?
` A I found the 2008. What is it supposed
`to -- is this a -- I found a folder, but it says
`Exhibit 2008.
` Q Yes. Okay. And do you understand that
`that's a transcript of the deposition that you
`gave in May of 2018 in the District Court
`litigation?
` MR. MAYLE: Object to form.
` A So this is before Tab A. Between the
`cover and the Tab A seems to be the transcript?
` Q Yes. And the tabs reflect the exhibits.
`You'll see, if you flip through the tabs, they're
`marked as the deposition exhibits. Do you
`understand that?
` A I don't remember, but I understand what
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`you said.
` Q Okay. And you had an opportunity to
`review this transcript and sign what's called an
`errata sheet, and if you turn to the end of the
`transcript piece and before the index of the
`transcript, you'll see something that I'm going to
`ask you about. It looks like -- it looks like
`this, if you look at your screen (indicating).
` A Yes. Which page is that?
` Q Well, they're not numbered. So you'll see
`the transcript is -- has four pages of transcript
`per page, and if you go to the end of the
`transcript which is pages 222, 223, it's the page
`after that.
` A So I have -- there's page 60,
`Acknowledgment. What does it say at the top of
`the page?
` Q There's a -- it's just an address for Epiq
`Court Reporting, E-P-I-Q Court Reporting, and it
`has a place for your signature at the bottom of
`the page.
` A Yes. And for me it says page 59 of 358.
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`Transcript of Emina Soljanin, Ph.D.
`Conducted on June 12, 2020
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`21
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` Q Yes. I see that. I'm not really sure why
`it says that, but we're on the same page.
` A Yes.
` Q So let me ask you this: Is that your
`signature on that page?
` A Yes.
` Q And you signed it after reading the
`transcript and making the corrections above,
`correct?
` A Yes. Yes.
` Q And when you did that, you did it
`carefully and to ensure that the transcript was
`accurate, correct?
` A To the best of my ability.
` Q Okay. Have you been retained by Broadcom,
`LSI, or Avago in any other proceeding other than
`the two proceedings involving the University of
`Minnesota?
` A There is --
` MR. MAYLE: Objection.
` A There is another proceeding. I believe
`it's -- I don't know the details now but your --
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`Conducted on June 12, 2020
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`22
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`your law firm, I think, is handling. This is with
`the CMU.
` Q That's a litigation -- a patent litigation
`involving Carnegie Mellon University; is that your
`understanding?
` A Correct.
` Q And you have been retained by LSI and
`Avago in that proceeding to appear as an expert in
`that proceeding, correct?
` A Yes.
` Q And are there -- aside from the University
`of Minnesota proceedings and the Carnegie Mellon
`proceeding, are there any other proceedings in
`which you've been retained by LSI, Avago, or
`Broadcom?
` A No.
` Q Now, this University of Minnesota
`proceeding relates to what I'll refer to as "the
`'601 Patent" or "the Moon patent." Is that okay
`with you?
` A Yes.
` Q Okay. And in the event that we need it,
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`Conducted on June 12, 2020
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`23
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`it's been marked as Exhibit 1001. Do you have
`that?
` A I do.
` (LSI Corp. Exhibit 1001 previously marked
`for identification and is attached to the
`transcript.)
` Q Let me -- before we get into the questions
`about your opinions, let me ask you this question:
`Can you provide us with a definition of an even
`number?
` A Even number? A number divisible by two
`without a remainder.
` Q Okay. Is zero an even number?
` A Well, in mathematics, zeros and ones
`are -- have a special meaning. So according to
`definition that it's divisible by two without a
`remainder, it's correct, but people don't refer to
`zero that way.
` Q If you turn to Exhibit 1001, Column 3.
` A Yes.
` Q Column 3 of the Exhibit 1001, at about
`line 50, refers to something called "minimum
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`Conducted on June 12, 2020
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`24
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`distance properties of sequence detectors."
` Do you see that?
` A Line 15, there is a sentence that says:
`"With the NRZI format, the MTR code constraint is
`equivalent to limiting the maximum runlength" --
` Q I'm sorry. I think you said 15. I said
`50, 5-0.
` A Oh, sorry. Sorry. 50. "The present
`invention pertains to an improved coding technique
`to enhance the minimum distance properties of
`sequence detectors."
` Q Okay. So you found the sentence, and my
`question is: What's your understanding of the
`phrase "distance properties" in that sentence?
` MR. MAYLE: Object to form.
` (Court reporter interrupts for
`clarification.)
` MR. MAYLE: Yes. Objection to form.
` COURT REPORTER: You have to say it louder
`because I cannot hear you.
` MR. MAYLE: Okay.
` COURT REPORTER: Thank you.
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`Conducted on June 12, 2020
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`25
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` A In this sentence, I don't know what is
`meant, "minimum distance properties" of a
`detector.
` Q How about just the phrase "distance
`properties" in that sentence? Do you know what
`that means?
` A Distance properties are associated with
`codes and channels.
` Q Okay. And do you have an understanding of
`what that means in that sentence?
` MR. MAYLE: Objection to form.
` A I don't know what it means in this
`sentence exactly.
` Q Okay. Let's turn, then, to your opinions.
`And in that regard, we're going to spend a little
`bit of time with Exhibit 1010, which is the
`declaration that you prepared in this IPR
`proceeding. Do you have that in front of you?
` A Exhibit 1010, is that --
` (Court reporter interrupts for
`clarification.)
` A 1010 is which folder? Could you remind
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`26
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`me?
` Q That's the declaration that you provided
`in this IPR proceeding. It's the first one
`that's --
` A Sorry. The first one in which folder?
`Sorry. Oh, 1010, found it.
` Q Got it?
` A Yes.
` Q So you understand that a patent has
`various claims at the end of it, correct, and that
`you're challenging -- your declaration asserts
`that various claims in the Moon patent are
`invalid?
` MR. MAYLE: Objection to form.
` Q That's correct?
` A Could you say that again?
` Q You understand that your declaration
`asserts that various claims in the Moon patent are
`invalid, correct?
` MR. MAYLE: Objection to form.
` A In this declaration, my declaration says
`that some claims are anticipated by some previous
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`Conducted on June 12, 2020
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`27
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`art.
` (Court reporter interrupts for
`clarification.)
` A Previous art.
` MR. McELHINNY: "Previous art" is what
`she's saying.
` Q So, Dr. Soljanin, do you understand that
`the University of Minnesota has disclaimed certain
`claims in connection with this proceeding and is
`now -- so that the only claims that are really at
`issue are Claims 13, 14, and 17?
` A I do.
` Q Okay. And if you take a look at the table
`of contents of Exhibit 1010, is it correct to say
`that as to Claims 13, 14, and 17, you assert only
`that they are anticipated by the Okada reference
`and the Tsang reference, correct?
` A In the table of contents, that is what it
`says.
` Q Okay. And you say that those claims are
`"anticipated by Okada" and "anticipated by Tsang."
`Do you have an understanding as to what it means
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`28
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`to say that a claim is anticipated by a prior art
`reference?
` A So here it's -- in the table of contents
`on page 8, I have used certain standards that I
`learned about, about anticipation, and that is my
`understanding.
` Q So as you refer to page 8, let me ask you
`this question: Aside from what you've been told
`from counsel, do you have an independent
`understanding as to what it means when you say
`that a claim has been anticipated by a prior art
`reference?
` MR. MAYLE: Objection to form.
` A So my understanding is that there is a
`previous paper, a paper or a patent or some single
`document which teaches exactly what the patent is
`trying to -- patent being -- being anticipated is
`trying to teach.
` Q Okay.
` A Or not quite exactly, but once understood,
`by the -- by a person of ordinary skills, there is
`nothing that can be taught further about the
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`Conducted on June 12, 2020
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`29
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`patent being anticipated.
` Q All right. And then anticipation involves
`looking at a single prior art reference and
`comparing it to the claims of the challenged
`patent, correct? That's you're understanding?
` A My understanding is that anticipate -- for
`anticipation, a single is needed...
` (Court reporter interrupts for
`clarification.)
` A My understanding is that for anticipation,
`a single reference is needed of prior art. That
`may have changed since last time I looked into --
`since this filing of the -- that was four years
`ago. But I don't know if law changed since then.
`But at that time, my understanding was that the
`single is required.
` Q And you referred -- you used the phrase
`"by prior art." What is your understanding of the
`phrase "prior art"?
` A A previous patent or a paper, something
`that has been disclosed anywhere in the world.
` Q And when you say "previous," previous to
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`30
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`what? Do you have an understanding as to previous
`to what?
` A That there was a disclosure -- which was
`publication, a talk, a patent, or just a filed
`patent, not necessarily granted -- that preceded
`the patent that is anticipated.
` Q Okay. Do you have any independent
`knowledge of when Drs. Moon and Brickner made the
`invention that is disclosed in the '601 Patent?
` A Independent of what is written in the
`patent itself?
` Q Correct.
` A I don't remember at this point.
` Q Okay. So let me turn your attention to
`paragraph No. 35 in Exhibit 1010, which is your
`declaration.
` A 35 on page 11, yes.
` Q Okay. And you say there that determining
`whether a patent claim is anticipated "requires a
`comparison of the properly construed claim
`language to the prior art on an element-by-element
`basis."
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`31
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` Is that what you wrote there?
` A That's what I wrote there.
` Q And when you say "properly construed claim
`language," that's -- is the construction of the
`claim language something that was the subject of
`your declaration in the District Court litigation?
` MR. MAYLE: Objection; form.
` A Could you say that again?
` Q Is the construction of the claim language
`of the '601 Patent something that was the subject
`of your declaration in the District Court
`litigation?
` MR. MAYLE: Objection to form.
` A I'm sorry. I'm not sure that I can
`follow, but in the District Court litigation --
`I'm not sure -- I'm not sure I understand that
`question. I'm sorry.
` Q So in the -- in your District Court
`litigation, did you offer opinions regarding the
`claim construction standard and the construction
`of the claims in the '601 Patent?
` MR. MAYLE: Objection to form.
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`32
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` A I looked into claims and found multiple
`meanings that could be assigned to them in the
`litigation case.
` Q And -- all right. We'll get to that.
` So just following up on that, when you say
`you "looked into the claims and found multiple
`meanings," that means you were trying to construe
`those claims in that declaration, correct?
` MR. MAYLE: Objection to form.
` A I was looking at it -- at what it means,
`sure.
` (Court reporter interrupts for
`clarification.)
` A I was looking at what claims mean.
` MR. McELHINNY: She's looking at what the
`claims mean, I think is what she --
` A Yes. Thank you.
` Q And in the Exhibit 1010, which is your IPR
`declaration, you included that -- you also
`included a section about claim construction,
`correct?
` A Could you tell me where that is?
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`33
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` Q Well, I mean, you can -- why don't you
`take a look at page 25 of Exhibit 1010.
` A Section VI.
` Q Yes.
` A I can see Section VI.
` Q And so in -- Section VI of Exhibit 1010 is
`titled Claim Construction, correct?
` A It's titled Claim Construction.
` Q And you go on for several numbered
`paragraphs construing various claim elements in
`that declaration, correct?
` A Correct.
` Q Paragraphs 63 through 75, correct?
` A That's that entire section, it looks like.
` Q Pardon?
` A The entire Section VI.
` Q Yeah, Section VI is paragraphs 63 through
`75.
` A Correct.
` Q And you included that section in your
`declaration because you wanted to be clear on the
`meaning that you were using to determine whether
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