CONFIDENTIAL
`C. Douglass Locke, Ph.D. - June 20, 2018
`
`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` __________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` __________
`
`SHENZHEN ZHIYI TECHNOLOGY CO. LTD., D/B/A ILIFE,
` Petitioner,
`
` v.
`
` IROBOT CORPORATION,
` Patent Owner,
`
` __________
`
` Patent No. 6,809,490 to Jones et al
` IPR Case No: IPR2017-02061
`
` __________
`
` C O N F I D E N T I A L
`
` DEPOSITION OF C. DOUGLASS LOCKE, PH.D.
`
` Washington, D.C.
`
` Wednesday, June 20, 2018
`
` 9:00 A.M.
`
` Reported by:
`
` Greg DiDonato, CSR#541, D.C. Notary Public
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`IROBOT 2015
`Shenzhen Zhiyi Technology v. iRobot
`IPR2017-02061
`
`
`C. Douglass Locke, Ph.D. - June 20, 2018
`
`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` __________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` __________
`
`SHENZHEN ZHIYI TECHNOLOGY CO. LTD., D/B/A ILIFE,
` Petitioner,
`
` v.
`
` IROBOT CORPORATION,
` Patent Owner,
`
` __________
`
` Patent No. 6,809,490 to Jones et al
` IPR Case No: IPR2017-02061
`
` __________
`
` C O N F I D E N T I A L
`
` DEPOSITION OF C. DOUGLASS LOCKE, PH.D.
`
` Washington, D.C.
`
` Wednesday, June 20, 2018
`
` 9:00 A.M.
`
` Reported by:
`
` Greg DiDonato, CSR#541, D.C. Notary Public
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`IROBOT 2015
`Shenzhen Zhiyi Technology v. iRobot
`IPR2017-02061
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`
`
`CONFIDENTIAL
`C. Douglass Locke, Ph.D. - June 20, 2018
`
`Page 2
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` 9:00 A.M.
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` JUNE 20, 2018
`
` Oral deposition of C. DOUGLASS LOCKE,
`
`PH.D., on June 20, 2018, scheduled at 9:00
`
`a.m., held at the law offices of Greenberg
`
`Traurig LLP, 2102 L Street, N.W., Suite
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`1000, Washington, D.C. 20037, pursuant to
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`37 CFR Subsection 42.53, taken by the
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`Patent Owner, before Gregory T. DiDonato,
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`CSR #541 and Notary Public in and for the
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`District of Columbia, there being present:
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`CONFIDENTIAL
`C. Douglass Locke, Ph.D. - June 20, 2018
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`Page 3
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`A P P E A R A N C E S:
`
`On behalf of the Petitioner:
`
`GREENBERG TRAURIG, LLP
`
`Four Embarcadero Center
`
`Suite 3000
`
`San Francisco, CA 94111
`
`(415) 655-1271
`
`BY: NICHOLAS A. BROWN, ESQ.
`
`brownn@gtlaw.com
`
`On behalf of the Patent Owner:
`
`FISH & RICHARDSON
`
`1425 K Street, N.W.
`
`11th Floor
`
`Washington, D.C. 20005
`
`(202) 626-7786
`
`BY: LINHONG ZHANG, ESQ.
`
`lwzhang@fr.com
`
`BY: RICK BISENIUS, ESQ.
`
`(612) 766-2048
`
`(Minneapolis Office)
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`bisenius@fr.com
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`CONFIDENTIAL
`C. Douglass Locke, Ph.D. - June 20, 2018
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`Page 4
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` I N D E X
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`WITNESS EXAMINATION BY
`
`Dr. C. Douglass Locke
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` By Mr. Zhang 5
`
` By Mr. Brown --
`
` * * *
`
` E X H I B I T S
`
` NONE
`
` * * *
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`CONFIDENTIAL
`C. Douglass Locke, Ph.D. - June 20, 2018
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` P-R-O-C-E-E-D-I-N-G-S
`
` (Commencing at 9:01 a.m.)
`
` THE REPORTER: Raise your right
`
` hand, please.
`
` Do you solemnly swear that the
`
` testimony you will give today will be
`
` the truth, the whole truth, and
`
` nothing but the truth, so help you
`
` God?
`
` THE WITNESS: I do.
`
` WHEREUPON,
`
` C. DOUGLASS LOCKE, Ph.D.,
`
` c/o Locke Consulting LLC, PMB 141, 516
`
` River Highway, Suite D, Morresville,
`
` North Carolina 28117, called as a
`
` witness, and having been first duly
`
` sworn, was examined and testified as
`
` follows:
`
` EXAMINATION BY COUNSEL FOR PATENT OWNER
`
`BY MR. ZHANG:
`
` Q. Good morning, Dr. Locke.
`
` A. Good morning.
`
` Q. Could you tell me how you came
`
` to be involved in this IPR matter?
`
` A. I was called by one of the
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`CONFIDENTIAL
`C. Douglass Locke, Ph.D. - June 20, 2018
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`Page 6
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` Greenberg Traurig attorneys. They got my
`
` name from another case that I was doing with
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` Greenberg Traurig.
`
` Q. And roughly what time was that?
`
` A. I would have to check my records.
`
` it's probably somewhere around July or August
`
` of 2017, I believe.
`
` Q. In terms of forming your opinions
`
` for this matter, could you tell me how you
`
` went about doing so?
`
` A. I got a list in my report, I
`
` think I have a list of things, materials
`
` that I considered, I reviewed those
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` materials, I discussed with the counsel,
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` specifically, read overall the prior art
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` that had been identified at that point, and
`
` I wrote the declaration from there.
`
` Q. Did you search for the prior art
`
` yourself?
`
` A. I did not.
`
` Q. So, is it fair to say that the
`
` prior art that you relied on for this matter
`
` was given to you?
`
` A. It was supplied by Greenberg
`
` Traurig attorneys; yes.
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`CONFIDENTIAL
`C. Douglass Locke, Ph.D. - June 20, 2018
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` Q. And then in terms of the
`
` grounds, did you formulate those grounds
`
` yourself?
`
` A. Partially, yes, partially, no.
`
` Again, we had lots of discussions about what
`
` the grounds would be, I made some suggestions,
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` and they had some ideas; and from that, we
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` came to the grounds.
`
` Q. In terms of the ground of Ueno,
`
` and the Bissett reference, were you the one
`
` who identified that ground?
`
` A. I don't believe I was initially,
`
` because both of those were preexisting prior
`
` art that they had supplied to me. By the
`
` time I was involved in the case, I think
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` they've identified that as a reasonable
`
` combination.
`
` I, of course, looked at all of
`
` the prior art that I had access to to verify
`
` whether that was a reasonable combination or
`
` not.
`
` Q. And in terms of the declaration
`
` you provided, did you prepare that yourself?
`
` A. I wrote the initial draft, and I
`
` then had many discussions with counsel, and
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`CONFIDENTIAL
`C. Douglass Locke, Ph.D. - June 20, 2018
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` from that a number of revisions were made.
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` I believe I wrote pretty much all of it in
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` that process.
`
` Q. I just want to make sure I
`
` understand. You said you wrote the initial
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` draft. Did counsel make edits to it?
`
` A. I believe they did. It's been
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` almost a year, so I don't remember all the
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` details. The way I've usually done these
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` things, counsel has the opportunity to edit
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` it, and I think they did some editing, and
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` they would identify the change bars and
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` identify what's been changed, and I would go
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` over it, and I did the same.
`
` Q. How long did it take you to
`
` prepare your declaration?
`
` A. I don't recall. I believe the
`
` first draft that I produced was somewhere
`
` around the second of August or early August,
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` at least; but how long I had actually spent
`
` at that time preparing it, I can't be
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` certain, probably was at least a few days.
`
` Q. I've handed to you your
`
` declaration, which is Shenzhen Zhiyi 1003.
`
` Do you recognize this document?
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`CONFIDENTIAL
`C. Douglass Locke, Ph.D. - June 20, 2018
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` (Pause.)
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` A. Yes, it appears to be my
`
` declaration.
`
` Q. If you could turn to paragraph 4
`
` of your declaration. It's found on page 6.
`
` In it you talk about navigation
`
` systems for helicopters and surface ships
`
` that you've worked on?
`
` Do you see that?
`
` A. Yes.
`
` Q. Do those involve using sensors
`
` to avoid obstacles?
`
` A. They use sensors for lots of
`
` things. For example, in the navigation, the
`
` first helicopter that I worked with, the
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` first aircraft I used was called a Doppler
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` net, for example, which actually bounces
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` signals off of whatever is below the
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` aircraft.
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` So, one could certainly view
`
` that as obstacle detection or obstacle
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` sensing. There are many other different
`
` kinds of things that I had to deal with that
`
` could be classified as obstacles. It was
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` more concerned at first with keeping track
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`CONFIDENTIAL
`C. Douglass Locke, Ph.D. - June 20, 2018
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` of where the aircraft was.
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` Q. Was there any actual collision
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` avoidance that was built into the navigation
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` systems you worked on as a result of
`
` feedback from sensors?
`
` A. Later on, I don't know if I
`
` mentioned it in here, but later on I worked
`
` with a number of aircraft that used systems
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` such as TCAS, for example, which detect the
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` presence of other aircraft in close vicinity
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` that could avoid a collision.
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` So, I certainly worked with
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` aircraft systems that had to deal with
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` possible obstacle detection and collision
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` avoidance.
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` I should also mention -- again,
`
` I'm not sure if I put everything in here, I
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` think my CV covers some of these that I have
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` dealt with -- navigation of tanks, for
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` example, which definitely has to have
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` sensors for collision detection, collision
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` avoidance.
`
` Q. What are the automatic collision
`
` detection and collision avoidance?
`
` A. They were manned vehicles; so,
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`CONFIDENTIAL
`C. Douglass Locke, Ph.D. - June 20, 2018
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` the collision avoidance would normally give
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` indications to the operator; the operator
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` then hopefully will avoid them; that would
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` be up to the operator.
`
` Q. How about for the helicopter and
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` surface ship navigation, were those also
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` manned vehicles?
`
` A. They both were manned vehicles.
`
` Q. In terms of collision avoidance,
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` would it also just be up to the operator to
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` avoid the obstacle?
`
` A. It depends. In some cases, yes,
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` some cases, no. In case of ships, I think
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` it would be up to the operator; they don't
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` operate a sense as fast.
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` In the case of aircraft, there
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` are a number of systems that would do
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` automatic avoidance, for example, a train
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` following radar would move the aircraft so
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` as to avoid a collision with that train.
`
` Q. In paragraph 5, you talk about
`
` RF applications.
`
` Do you see that?
`
` A. Yes.
`
` Q. What is that?
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`C. Douglass Locke, Ph.D. - June 20, 2018
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` A. Now, just filling in the
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` background, since most of what I've done is
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` really in the software, that indicates that
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` I also have some hardware background and,
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` specifically, with respect to radio sensors
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` and radio devices; very early on, I had a
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` first-class radiotelephone license.
`
` Q. Do the RF applications have any
`
` relevance to your opinion here?
`
` A. I don't think that any of the
`
` sensors I was dealing with here involved
`
` radio frequency applications; they could
`
` have, but they didn't.
`
` At the time I wrote this
`
` declaration, I hadn't decided all the issues
`
` and hadn't looked at everything.
`
` Q. Now, as part of rendering your
`
` opinions in your declaration, you had to
`
` look at claims instructions; is that right?
`
` A. Yes.
`
` Q. And do you understand what
`
` broadest reasonable interpretation means?
`
` A. I believe so. I have a layman's
`
` understanding of that. I'm not an attorney,
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` of course.
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`CONFIDENTIAL
`C. Douglass Locke, Ph.D. - June 20, 2018
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` Q. And what is your understanding
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` of broadest reasonable interpretation?
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` A. It would be to look at the
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` interpretation of each of the terms using
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` the broadest interpretation that one of
`
` ordinary skill in the art might use to
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` interpret it.
`
` Q. And is that what you implied as
`
` part of rendering your opinion here?
`
` A. Yes.
`
` Q. And did you apply broadest
`
` reasonable interpretations to all of the
`
` claims limitations for the '490 patent?
`
` A. It was certainly my intention to
`
` do so; yes.
`
` Q. And if you look at paragraph 25
`
` of your declaration, you rely on a number of
`
` constructions that were submitted in the ITC
`
` investigation.
`
` Do you see that?
`
` A. There's a reference to some
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` specific construction from the ITC
`
` investigation. I don't think I actually
`
` mention them in there, other than that they
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` exist.
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`C. Douglass Locke, Ph.D. - June 20, 2018
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` Q. So, why did you mention them in
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` paragraph 25?
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` A. Again, I was trying to determine
`
` what constructions had already been agreed
`
` to by the parties or appeared to have been
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` agreed to by the parties.
`
` Q. Do you understand that those
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` constructions are under a different standard
`
` than that which would be applied in the IPR
`
` proceeding?
`
` A. Again, this is something that I
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` discussed with attorneys, and we determined
`
` these were the easiest, these instructions
`
` would have been as broad as, they would have
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` been the same under that standard that I
`
` established my opinion at the time.
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` Q. So, it's your opinion that the
`
` construction submitted in the ITC
`
` investigation would have comported with the
`
` broadest reasonable interpretation that
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` would be applied for purposes of this
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` petition?
`
` A. I believe so.
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` Q. As far as rendering your opinion
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` for the petition, are you relying on any of
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` the construction that was submitted by the
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` parties in the ITC investigation?
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` A. I'll have to refer to what I
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` said in my report. I don't remember exactly
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` which construction I was relying on.
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` Q. Sure. Feel free to look at your
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` report.
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` A. Can you state the question
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` again.
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` Q. Yes. I had asked you, are you
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` relying on any of the construction submitted
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` by the parties in the ITC investigation in
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` terms of rendering your opinions here in
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` this matter?
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` A. I believe I did, as long as they
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` were consistent with the broadest reasonable
`
` interpretation in my opinion.
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` Q. Is there any construction that
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` was submitted in the ITC matter that is not
`
` consistent with the broadest reasonable
`
` interpretation?
`
` A. I would have to, again, I would
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` have to read the whole report, but I believe
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` that my determination was that the proposed
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` construction by the parties were intended to
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`C. Douglass Locke, Ph.D. - June 20, 2018
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` be consistent with the broadest reasonable
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` interpretation, as well as being in the
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` constructions to be used by the ITC
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` proceeding.
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` Q. In paragraph 26, that's what you
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` did, you applied the agreed-on construction
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` from the ITC in this investigation; is that
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` right?
`
` A. Yes. As I state in 26, it was
`
` my opinion that the agreed constructions are
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` consistent with the broadest reasonable
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` interpretation of the terms.
`
` Q. Now, if you look at paragraph 30
`
` and 31, you provide an opinion in terms of
`
` means-plus-function for the claims of the
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` control system to configure and operate the
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` robot.
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` Do you see that?
`
` A. Yes.
`
` Q. It's your opinion that that term
`
` should have been subject to means-plus-function
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` treatment; is that right?
`
` A. I think I noted here that patent
`
` owner contends that it was a
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` means-plus-function term, that it was
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` related to a means-plus-function claim, and
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` identified the function and the structure.
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` I don't know that I commented --
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` I will have to check, again -- I'm not sure
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` whether I commented on whether that was
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` correct or not.
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` Q. But you have no opinion as to
`
` whether the patent owner's claim construction
`
` is correct?
`
` A. Let me review what I wrote.
`
` (Pause.)
`
` In my commentary on what a
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` patent owner had suggested as construction,
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` I didn't comment on the means-plus-function
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` aspect of that. I did say that I felt that
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` the patent owner's construction was slightly
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` broader than the petitioner's proposed
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` construction; and that I was using the
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` petitioner's more narrow construction for
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` the purpose of determining whether or not
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` the prior art met the requirements of each
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` claim under the understanding that the
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` slightly broader interpretation would have
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` also made that same, would have met that
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` same criteria.
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`C. Douglass Locke, Ph.D. - June 20, 2018
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` Q. I see. Do you have any sense of
`
` which construction comports with the
`
` broadest reasonable interpretation that you
`
` should apply here to this matter?
`
` A. Given that the patent owner is
`
` slightly broader, it would not be
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` unreasonable to use that one. I think either
`
` way my analysis would have been correct.
`
` Q. In terms of providing your
`
` opinion, you were relying on Ueno as one of
`
` the prior art references; is that right?
`
` A. That's correct.
`
` Q. Well, I'll hand you the Ueno
`
` reference.
`
` Now, you'd agree with me that
`
` the Ueno reference discloses a number of
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` sensors that are used?
`
` A. Yes.
`
` Q. And, as part of those, that
`
` includes infrared sensors; is that right?
`
` A. Yes, I believe it does.
`
` Q. And, in particular, it includes
`
` infrared sensors 26R, 26L, 26MR, 26ML, 26RR,
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` 26RL, and 25L; is that right?
`
` A. That certainly sounds familiar.
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` Q. For purposes of time, I can
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` refer you to paragraph 47 of your report, if
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` you want, which cites to paragraph 16 of
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` Ueno.
`
` A. Yes.
`
` Q. So, is it fair to say that 26R,
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` 26L, 26MR, 26ML, 26RR, 26RL and 25L are
`
` infrared sensors?
`
` A. Yes.
`
` Q. And what are infrared sensors?
`
` A. An infrared sensor is a sensor
`
` that uses infrared light as light that is
`
` below the frequency of visible light to look
`
` for obstacles, look for, really look for any
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` object.
`
` Q. Are infrared sensors contact
`
` sensors?
`
` A. No.
`
` Q. Why not?
`
` A. An infrared sensor sends out a
`
` signal, and looks at the response from that
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` signal; it does not require contact.
`
` Q. Now, will you turn to paragraph
`
` 50 of your report.
`
` A. Yes.
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` Q. In paragraph 50, you talk about
`
` cliff sensors.
`
` Do you see that?
`
` A. Yes.
`
` Q. What is a cliff sensor?
`
` A. It's a sensor that is looking
`
` for the presence or absence of a floor
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` usually just in front of the wheels.
`
` Q. In terms of the '490 patent, how
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` is the cliff sensor implemented?
`
` A. I would have to refer to the
`
` '490 patent to refresh my memory on exactly
`
` how it was implemented.
`
` Q. You've been handed Exhibit 1001,
`
` which is U.S. Patent 6,809,490.
`
` A. Yes. (Pause.) The preferred
`
` embodiment uses an infrared sensor.
`
` Q. Now, can you implement cliff
`
` sensors using something other than infrared?
`
` A. Certainly.
`
` Q. What other ways can you use to
`
` implement a cliff sensor?
`
` A. You can create a mechanism that
`
` would remain in contact with the floor, and
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` would detect it's no longer there, that is,
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` it would drop to a certain level.
`
` Q. Any other ways?
`
` A. To some extent, you can do it by
`
` looking for wheel drop, and how far the
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` wheel goes down; some of these, of course,
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` will work better than others.
`
` Q. Suffice it to say, you could
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` detect whether there's a drop-off on the
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` floor using many different mechanisms; is
`
` that fair?
`
` A. Several. I'm not sure how many
`
` but, yes.
`
` Q. And you can also prevent a robot
`
` from tumbling down the stairs by using a
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` virtual wall; is that right?
`
` A. Yes. By virtual wall, you're
`
` referring to a device that would create a
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` barrier from the point of view of the device
`
` that would be considered to be a barrier.
`
` Q. A virtual barrier?
`
` A. Yes.
`
` Q. It might be light or sound or
`
` something that prevents the device from
`
` going past the particular boundary?
`
` A. You could do that, although that
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` would require having an external device to
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` provide that barrier.
`
` Q. Other than the infrared space
`
` cliff sensor, does the '490 patent say
`
` anything else about any other way to prevent
`
` a robot from tumbling down a flight of
`
` stairs?
`
` A. I guess I would probably have to
`
` review the whole patent to see if it ever
`
` mentioned any other way of doing that.
`
` I just noticed in one particular
`
` paragraph, it talks about the IR. It may
`
` have other ways that it talks about it, as
`
` well, but I don't remember.
`
` Q. Please take your time and look
`
` through it. We have a lot of time today.
`
` A. Okay. (Pause.)
`
` Based on this brief review of
`
` the patent, I believe the only things that
`
` it identifies for identifying a cliff is the
`
` IR cliff sensor, one or more, and the wheel
`
` drop sensor.
`
` Q. Now, let's move on to paragraph
`
` 73 and 74 of your report.
`
` A. Okay.
`
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` Q. Do you see in those paragraphs
`
` you talk about the spot-coverage mode?
`
` A. Yes.
`
` Q. And, in particular, you're
`
` relying on the spiral-travel mode of Ueno to
`
` satisfy the spot-coverage mode of the '490
`
` patent; is that right?
`
` A. Yes.
`
` Q. In terms of the spiral-travel
`
` mode of Ueno, how does Ueno describe how the
`
` spiral-travel mode to be exited?
`
` A. It offers various ways to exit
`
` in Ueno but, basically, looking for an
`
` obstacle.
`
` Q. So, if it detects an obstacle,
`
` the robot would exit spiral-travel mode; is
`
` that right?
`
` A. Yes.
`
` Q. Are you aware of any other ways
`
` that Ueno describes for exiting the
`
` spiral-travel mode?
`
` Feel free, I think you
`
` referenced paragraphs 28 through 30 and 38
`
` to 43 of Ueno as part of your analysis here.
`
` A. It can leave based on the spiral
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` getting sufficiently large, so that can
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` cause it to leave the spiral mode.
`
` We talked about, it can leave if
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` it hits an obstacle; or, when I say hit the
`
` obstacle, I really mean hit within a planned
`
` distance of the obstacle.
`
` Q. Where does it say it can leave
`
` spiral mode when the spiral gets sufficiently
`
` large?
`
` (Pause.)
`
` A. I may have misspoken. I don't
`
` see that in here. So, it appears the spiral
`
` mode will just go until it encounters an
`
` obstacle.
`
` Q. Now, let's turn to paragraph 79
`
` and 80 of your declaration, please.
`
` A. Yes.
`
` Q. In paragraph 79 and 80, you
`
` provide analysis for balance mode; is that
`
` right?
`
` A. Yes.
`
` Q. And to satisfy balance mode,
`
` you're relying on the random-travel mode of
`
` Ueno; is that right?
`
` A. Yes, that's correct.
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` Q. In paragraph 80, in particular,
`
` you say, "The robot will drive straight, hit
`
` an obstacle, then turn away before driving
`
` straight again."
`
` Do you see that?
`
` A. Yes.
`
` Q. And your describing what Ueno
`
` discloses; is that right?
`
` A. Although, I would note that "hit
`
` an obstacle" refers to having a sufficiently
`
` small distance from the obstacle.
`
` Q. So, it actually doesn't contact
`
` the obstacle?
`
` A. I don't know that a Ueno says
`
` whether it contacts or not, but it is
`
` certainly reasonable to assume that it might
`
` not.
`
` Q. That was actually the point I
`
` was trying to get at.
`
` So, if you could look at the
`
` paragraphs and figures you cite in Ueno,
`
` could you tell me whether any of those
`
` paragraphs discuss the Ueno robot actually
`
` contacting the obstacle and changing its
`
` direction as part of the random-travel mode?
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`C. Douglass Locke, Ph.D. - June 20, 2018
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` (Pause.)
`
` A. Okay. The answer is, it does
`
` talk about the possibility of hitting an
`
` obstacle.
`
` Q. Where does it say that?
`
` A. Specifically, in paragraph 25,
`
` the fifth line down, it says, "At Step S75,
`
` it is decided if the front-end contact
`
` sensor 5A detects the boundary such as a
`
` wall, and if the decision is negative,"
`
` etcetera.
`
` The corresponding flow chart in
`
` figure 4 also has a decision box near the
`
` bottom of figure 4 that says, "Contact
`
` wall?", question, and comes out either a yes
`
` or no. And, in the case of, yes, it does a
`
` retreat, and then a turn.
`
` Q. But you didn't cite paragraph 25
`
` as part of your declaration; is that right?
`
` A. I would have to review my whole
`
` report to see if I ever referenced 25. I
`
` didn't reference it in this particular
`
` paragraph.
`
` Q. And, in particular, I'm
`
` referring to paragraph 79 and 80, you did
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` not reference paragraph 25?
`
` A. I did not.
`
` Q. And you said the corresponding
`
` disclosure for paragraph 25 is figure 4; is
`
` that right?
`
` A. I believe so; yes.
`
` Q. And that's not discussing
`
` random-travel mode, is it?
`
` A. I believe it is. Oh, I take it
`
` back. I apologize. Figure 4 is discussing
`
` the wall following mode.
`
` Q. And paragraph 25 is not
`
` discussing random-travel mode, is it?
`
` A. That's correct. But it does,
`
` the robot does have that sensor, so it could
`
` do a contact sensing, but...
`
` Q. But nothing in Ueno itself is
`
` discussing using the contact sensor as part
`
` of the random-travel mode; is that right?
`
` A. I don't recall that it does.
`
` Q. And you haven't identified
`
` anything based on your review here today; is
`
` that right?
`
` A. Let me just check someplace.
`
` (Pause.)
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` I have not identified anything
`
` today.
`
` Q. Let's move on to paragraph 82 of
`
` your declaration.
`
` Paragraph 82 appears as part of
`
` your analysis for the obstacle-following
`
` mode; is that right?
`
` A. In paragraph 82, I am discussing
`
` the border-following or the wall-following
`
` mode; yes.
`
` Q. You'd agree with me that the
`
` Ueno reference does not discuss anything
`
` about the work width of the robot; is that
`
` right?
`
` A. It does not use that term. I
`
` didn't see anything in there that
`
` specifically talks about the work width.
`
` Q. And what is the work width, as
`
` you understand based on the '490 patent's
`
` disclosure?
`
` A. I think the '490 patent
`
` describes the work width as the width of the
`
` brush or opening that is doing the cleaning.
`
` Q. And the Ueno reference says
`
` nothing about how long you would
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`28
`
`
`
`CONFIDENTIAL
`C. Douglass Locke, Ph.D. - June 20, 2018
`
`Page 29
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` border-follow as a function of the work
`
` width; is that right?
`
` A. That's correct, it does not
`
` connect those two together. It merely
`
` identifies that you would, the designer or
`
` the user would specify a maximum and perhaps
`
` minimum distance that it would border-follow.
`
` Q. Would you
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