Deposition of:
`Vijay Madisetti , Ph.D.
`
`April 9, 2019
`
`In the Matter of:
`Ericsson Vs. Intellectual Ventures II
`
`Veritext Legal Solutions
`800.808.4958 | calendar-atl@veritext.com | 770.343.9696
`
`Intellectual Ventures II LLC Ex. 2009
`Ericsson Inc. v. Intellectual Ventures
`IPR2018-01380
`
`

`

`Vijay Madisetti , Ph.D.
`Ericsson Vs. Intellectual Ventures II
`
`April 9, 2019
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` _________________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _________________________________________
`
` ERICSSON INC. AND
` TELEFONAKTIEBOLAGET LM ERICSSON,
` Petitioner
` v.
` INTELLECTUAL VENTURES II LLC,
` Patent Owner
`
` _________________________________________
`
` CASE IPR2018-01380
` Patent 8,682,357
` _________________________________________
`
` DEPOSITION OF
` VIJAY MADISETTI, PH.D.
`
` April 9, 2019
` 9:02 a.m.
`
` Veritext Atlanta
` 1075 Peachtree Street, NE
` Suite 3625
` Atlanta, Georgia
`
` Marsi Koehl, CCR-B-2424
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`800.808.4958
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`Veritext Legal Solutions
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`Vijay Madisetti , Ph.D.
`Ericsson Vs. Intellectual Ventures II
`
`Page 2
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`April 9, 2019
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`Page 4
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`Page 3
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`1 P R O C E E D I N G S
`2 VIJAY MADISETTI, PH.D.,
`3 having been first duly sworn, was examined and
`4 testified as follows:
`5 EXAMINATION
`6 BY MR. DUTTON:
`7 Q. Good afternoon, Dr. Madisetti.
`8 Can you please state your name for the
`9 record.
`10 A. It's Vijay Madisetti.
`11 Q. And have you been deposed before?
`12 A. Yes.
`13 Q. About how many times have you been deposed?
`14 A. Quite a few times. I don't recall the
`15 specific numbers but quite a few times.
`16 Q. Okay. I'll -- you know, just for some quick
`17 background on today's logistics, I'll ask you
`18 questions and if you do not understand one of my
`19 questions, will you please let me know?
`20 A. I will.
`21 Q. And if you answer one of my questions, is it
`22 fair that I can assume that you understood my
`23 question?
`24 A. Yes.
`25 Q. And we can take a break, you know, as you
`
`Page 5
`1 need. I'll plan to take a break like every hour or
`2 so, but let me know if you need to take a break and
`3 we can do that. Is that okay?
`4 A. Yes.
`5 Q. Is there any reason that you can't testify
`6 truthfully today?
`7 A. No.
`8 Q. Do you understand that you are here to
`9 testify about the declaration you submitted in an
`10 inter partes review of U.S. Patent No. 8682357?
`11 A. Yes.
`12 Q. And for purposes of this deposition, is it
`13 okay if we call that U.S. patent the "357 Patent"?
`14 A. Yes.
`15 Q. Okay. I'm going to hand you a few documents
`16 that we'll be referring to today.
`17 So I'm handing you what has been marked as
`18 Exhibit 1003 in this proceeding. Do you recognize
`19 this document?
`20 A. Yes. This is my declaration.
`21 Q. I'd like you to turn to page 96. It's the
`22 last page of the declaration.
`23 Is that your signature?
`24 A. Yes.
`25 Q. Did you review this document in preparation
`
`1 C O N T E N T S
`2 E X A M I N A T I O N
`
`3 4
`
` Page
`5 Examination by Mr. Dutton..........................4
`
` E X H I B I T S
`
`Exhibit No. Description Page
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`6 7 8 9
`
`10
`
`11
`12 (None marked.)
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
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`1 APPEARANCES OF COUNSEL
`2 On behalf of the Petitioner:
`3 JOHN RUSSELL EMERSON
` ADAM C. FOWLES
`4 Attorneys at Law
` HAYNES AND BOONE, LLP
`5 2323 Victory Avenue
` Suite 700
`6 Dallas, Texas 75219
` (214) 651-5328
`7 russ.emerson@haynesboone.com
`8 On behalf of the Patent Owner:
`9 TYLER J. DUTTON
` BYRON L. PICKARD
`10 Attorneys at Law
` STERNE KESSLER GOLDSTEIN & FOX
`11 1100 New York Avenue, NW
` Washington, D.C. 20005
`12 (202) 371-2600
` tdutton@sternekessler.com
`
`13
`14 Also present telephonically:
`15 James Hietala
`16
`17 (Pursuant to OGCA 15-14-37 (a) and (b) a
`18 written disclosure statement was submitted by the
`19 court reporter and is attached hereto.)
`20
`21
`22
`23
`24
`25
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`Vijay Madisetti , Ph.D.
`Ericsson Vs. Intellectual Ventures II
`
`Page 6
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`April 9, 2019
`
`Page 8
`
`1 for today's deposition?
`2 A. I reviewed it. Yes.
`3 Q. I'm handing you what has been marked as
`4 Exhibit 1001.
`5 Do you recognize this document?
`6 A. I do.
`7 Q. And what is this document?
`8 A. This is the 357 Patent.
`9 Q. Did you review this for today's deposition?
`10 A. Yes.
`11 Q. I'm handing you what has been marked as
`12 Exhibit 1005.
`13 Do you recognize this document?
`14 A. I do.
`15 Q. What is this document?
`16 A. This is Exhibit 1005. It's the CATT
`17 reference, C-A-T-T.
`18 Q. Did you review this in preparation for
`19 today's deposition?
`20 A. I did.
`21 Q. I'm handing you what has been marked as
`22 Exhibit 1006.
`23 Do you recognize this document?
`24 A. Yes. This is Exhibit 1006, which I call as
`25 the LG reference.
`
`1 qualification there?
`2 A. No.
`3 Q. So you did not review any other documents
`4 besides the exhibits that have been presented to you,
`5 the petition and the institution decision?
`6 A. I don't recall doing so.
`7 Q. Did you meet with anyone in preparation for
`8 today's deposition?
`9 A. Yes.
`10 Q. Who did you meet with?
`11 A. I met with the counsel.
`12 Q. Which counsel did you meet with?
`13 A. With Mr. Emerson and Mr. Knowles [sic].
`14 MR. EMERSON: Fowles.
`15 THE WITNESS: Knowles. Is it Knowles?
`16 MR. EMERSON: Fowles.
`17 THE WITNESS: Fowles. Okay. Sorry
`18 about that.
`19 BY MR. DUTTON:
`20 Q. Is there anyone else that you met with?
`21 A. No.
`22 Q. Did you speak to anyone in preparation for
`23 today's deposition?
`24 A. I did not.
`25 Q. And how long did you meet with counsel?
`
`Page 7
`
`Page 9
`
`1 Q. Did you review this in preparation for
`2 today's deposition?
`3 A. I did.
`4 Q. I'm handing you one more here, Exhibit 1007.
`5 Do you recognize this document?
`6 A. Yes. Exhibit 1007 is the CATT 2 reference,
`7 C-A-T-T 2 reference.
`8 Q. And that's because this is the second CATT
`9 reference?
`10 A. Yes.
`11 Q. Have you reviewed this document in
`12 preparation for today's deposition?
`13 A. I did.
`14 Q. Did you review any other documents in
`15 preparation for today's deposition?
`16 A. I reviewed the petition as well as the
`17 institution decision.
`18 Q. Any other documents?
`19 A. Not specifically.
`20 Q. And what did you do to prepare for today's
`21 deposition?
`22 A. I reviewed my declaration and, as I said,
`23 the exhibits and the documents I mentioned.
`24 Q. When you said that you did not review any
`25 other documents specifically, was there some
`
`1 A. A few hours.
`2 Q. Is that yesterday?
`3 A. Yes.
`4 Q. Did you take any notes?
`5 A. No.
`6 Q. I'd like you to turn to paragraph three of
`7 your declaration.
`8 A. So I have a copy in the binder and it may be
`9 convenient sometimes to just go through it, but I
`10 will use your exhibits for now.
`11 So you said page 3?
`12 Q. Yes -- or paragraph three.
`13 A. Paragraph three. Yes.
`14 Q. Paragraph three includes a list of
`15 references that you reviewed for your declaration?
`16 A. Yes.
`17 Q. Did you review any other references that are
`18 not listed?
`19 A. No.
`20 Q. Let's turn to Exhibit 1001, the 357 Patent.
`21 What's the 357 Patent about?
`22 MR. EMERSON: Object to the form.
`23 THE WITNESS: The 357 Patent is U.S.
`24 Patent 8682357. It is related to paging in
`25 a wireless network.
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`Vijay Madisetti , Ph.D.
`Ericsson Vs. Intellectual Ventures II
`
`April 9, 2019
`
`Page 10
`
`1 BY MR. DUTTON:
`2 Q. And what is paging in a wireless network?
`3 MR. EMERSON: Object to the form.
`4 THE WITNESS: As the 357 describes it in
`5 column one, lines 30 to 32, paging involves
`6 waking up the mobile terminal from the sleep
`7 state.
`8 BY MR. DUTTON:
`9 Q. Okay. What is the sleep state?
`10 A. The sleep state or the sleep mode is the
`11 state in which the mobile terminal stays in to reduce
`12 power consumption, for example, column two, lines
`13 five through seven.
`14 Q. So the mobile terminal isn't always
`15 connected to the network and so it periodically wakes
`16 up?
`17 A. I did not specifically understand the
`18 question.
`19 Q. What didn't you understand?
`20 A. I mean, what was the question? You said
`21 "periodically"?
`22 Q. So the mobile terminal isn't always
`23 connected to the network, so it periodically wakes
`24 up?
`25 A. So it -- when we talk about network, there
`
`Page 12
`1 A. Node Bs are equipment that reside in the
`2 access network domain, the radio access network
`3 domain. And they are -- Node Bs and eNode Bs are
`4 examples of equipment that assists the UE and the
`5 core network.
`6 Q. Is Node B a base station?
`7 A. A Node B can be called in some cases as a
`8 base station in a very general manner.
`9 Q. You referenced an eNode B. Is that a
`10 particular Node B?
`11 A. ENode B is, again, a type of Node B that is
`12 called an evolved Node B.
`13 Q. Is that used in LTE?
`14 A. It can be used in LT.
`15 Q. What is in the core network domain?
`16 A. The core network domain would include, for
`17 example, portions towards the right of Figure 1.
`18 They include the access gateway and other types of
`19 equipment for processing various types of
`20 functionalities that are needed to operate the
`21 wireless network.
`22 Q. What types of other equipment other than the
`23 access gateway is --
`24 A. You have -- for example in column four, in
`25 the description of Figure 1, it is stated in lines 53
`
`Page 11
`
`1 is an access network and then there is a core
`2 network.
`3 In the case of, for example, 357, in the
`4 sleep mode or in the idle mode, the mobile device may
`5 be still connected to the core network. However, it
`6 may not have a connection to the radio access
`7 network, or the RAN.
`8 Q. Got it.
`9 So if we turn to Figure 1, the figure shows
`10 different domains and you mentioned the core network
`11 and the RAN. Is this what you were referring to?
`12 A. This is an example in the 357 specification
`13 of the UE domain, the radio access network, or the
`14 RAN domain, and the core network domain.
`15 Q. So let's start with the UE domain.
`16 "UE" stands for user equipment?
`17 A. Yes.
`18 Q. And what is user equipment?
`19 A. It's a description -- a descriptor for a
`20 mobile device that is -- that is part of the wireless
`21 network.
`22 Q. And the RAN domain includes Node Bs?
`23 A. Examples of equipment in the RAN, radio
`24 access network domain, includes Node Bs.
`25 Q. What are "Node Bs"?
`
`Page 13
`1 to 58, The core network 116 includes in this example
`2 an access gateway, aGW, 118, a serving GPRS support
`3 node SGSN 120 and a gateway GPRS support node GGSN.
`4 Q. You said this is an example. Are there
`5 other examples?
`6 A. There can be other examples of types of
`7 building blocks that are used in the core network.
`8 Q. In those other examples, what building
`9 blocks are in the core network?
`10 A. As I said, it depends on the type of system.
`11 You can have other blocks such as MMEs and other
`12 types of functional blocks which are more described
`13 in standards such as the TS 23.246.
`14 Q. What's an "MME"?
`15 A. I think it's mobile management entity, but
`16 I'm not exactly sure whether that's completely
`17 correct. It's mobile management entity, I believe.
`18 Q. What role does that node play in the core
`19 network?
`20 A. Again, if you look at the standard, it
`21 provides a variety of functionalities. They include
`22 managing resources, managing various types of
`23 communications, managing things like various types of
`24 features, for example, multicast and other types of
`25 features that are offered by the core network,
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`Vijay Madisetti , Ph.D.
`Ericsson Vs. Intellectual Ventures II
`
`April 9, 2019
`
`Page 14
`
`1 including access to the packet network.
`2 Q. When you say managing resources, is that
`3 involved with the control plane?
`4 A. Both control plane, the transport plane,
`5 both for data as well as for control.
`6 Q. What is the control plane?
`7 A. The control plane is essentially a way by
`8 which you provide control functionality over the
`9 network; things like signaling and other types of
`10 protocols.
`11 Q. So the MME would be part of the control
`12 plane function of the network?
`13 A. As I said, the MME, the RRM and other
`14 features have different descriptions that are to do
`15 with various aspects of both control and transport
`16 for the wireless network.
`17 Q. In Figure 1, what is the role of the access
`18 gateway?
`19 A. As described in section -- in column two,
`20 lines 60 to 65, the access gateway initiates the
`21 connection. So the network, e.g., an access gateway,
`22 initiates the connection by transmitting a paging
`23 message to Node Bs in the UE register tracking area.
`24 Q. Does the access gateway initiate the
`25 connection by transmitting that message on the
`
`Page 15
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`1 control plane?
`2 A. You need to be more specific as to your
`3 question. Are you referring to -- to what particular
`4 portion of the 357 specification?
`5 Q. The 357 specification says that the access
`6 gateway transmits a paging message to the Node B;
`7 right?
`8 A. Again, we have to use specific terms as
`9 described in the 357 specification.
`10 My understanding is that in the context of
`11 the 357, a paging signal is sent as per claim 11.
`12 And that's the first paging signal.
`13 Q. And is an access gateway an example of a
`14 device that sends that first paging message?
`15 A. As I described earlier, as described in
`16 357 specification, for example, the embodiment shown
`17 in Figure 9 -- so there is a paging signal that is
`18 sent from the access gateway to the second network
`19 device which is a Node B.
`20 Q. And going back to Figure 1, there's a line
`21 connecting the access gateway to the Node B.
`22 Do you see that?
`23 A. I do.
`24 Q. And what does that line signify?
`25 A. Maybe you ought to be clearer in your
`
`Page 16
`1 question. It's called the S1 plane, so I am not sure
`2 as to your question.
`3 Q. What is the S1 plane?
`4 A. I think we ought to refer to the standard
`5 document, but it's sort of one of the many specified
`6 interfaces between the core network and the random
`7 access network.
`8 Q. What other interfaces are between the core
`9 network and the random access network?
`10 A. I think we ought to refer to the standard to
`11 be precise. I don't think I discuss them in my
`12 declaration.
`13 Q. Do you know any other interface between the
`14 core network and the random access network?
`15 A. As I said, I don't recall the specifics. I
`16 believe there are a number of interfaces based on XR
`17 and so on. I don't remember the specific names.
`18 Q. I'd like you to turn to page 40 of your
`19 declaration.
`20 And on the next page, there's a figure from
`21 the standard. Do you see that? Paragraph 40, sorry.
`22 A. Yes.
`23 Q. Does this figure show the S1 plane or the
`24 S1 interface?
`25 A. This is Figure 5.1 from the technical report
`
`Page 17
`1 25.813 page 10. So it's an older report and it is
`2 the figure that is in that older report.
`3 At that time, this is how they show the
`4 S1 plane by the dotted line in the time frame at
`5 which the document was written.
`6 Q. When you say "older report," does that mean
`7 older than the 357 Patent?
`8 A. Yes. I believe so. This is probably prior
`9 to the 2006 or early 2006 time frame.
`10 Q. So the S1 interface in the 357 Patent would
`11 be similar to the S1 interface in the specification?
`12 A. Specification of what?
`13 Q. Of 3GPP, this TR 25.813.
`14 A. It is not a specification. It's a technical
`15 report. A specification means it stays TS. This is
`16 TR.
`17 Q. Understood.
`18 So is the S1 interface in the 357 Patent
`19 similar to the technical report S1 interface shown in
`20 your declaration?
`21 A. Again, this is an example of the types of
`22 functionalities that could be assigned to the core
`23 network or the eNode B. This is one such example
`24 description.
`25 The S1 still represents the interface
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`Vijay Madisetti , Ph.D.
`Ericsson Vs. Intellectual Ventures II
`
`April 9, 2019
`
`Page 20
`
`Page 18
`1 between the first network device and the second
`2 network device, though some of the functionality may
`3 have changed.
`4 Q. Do the -- does the first network device and
`5 second network device communicate over the
`6 S1 interface using different protocols?
`7 MR. EMERSON: Object to the form.
`8 THE WITNESS: I understand that in the
`9 claim 11, it is just required that -- for
`10 example, in the exemplary claim 11, that you
`11 send via a first network device a paging
`12 signal to the second network device.
`13 And that is what I referenced in my
`14 declaration. The exact protocol is not, to
`15 my understanding, part of the claim.
`16 BY MR. DUTTON:
`17 Q. What types of protocols were used at the
`18 time of the 357 Patent?
`19 MR. EMERSON: Object to the form.
`20 THE WITNESS: As I said, I have not
`21 specifically described in my declaration the
`22 specific types of protocols other than what
`23 I have included in my declaration. And I
`24 have shown that, for example in the CATT
`25 reference, that there is the transmission of
`
`1 different protocols.
`2 BY MR. DUTTON:
`3 Q. So I'm not asking about what claim 1
`4 recites. I guess maybe we can go to this figure in
`5 your declaration on page 21.
`6 Does this figure show any protocols?
`7 A. This figure is a technical report that
`8 describes one exemplary partition of functionality
`9 between the core network on the right and the radio
`10 access network on the left. It shows that there is
`11 an S1 plane just like the embodiment of the figure in
`12 the 357 specification.
`13 What is confirmed through CATT is that the
`14 core network sends the paging signal over a wireless
`15 network to the second network device that's part of a
`16 radio access network.
`17 Q. What is "RRC" in the figure on page 21?
`18 A. RRC, in general and in the example of a
`19 network architecture in TR 25.813, usually stands for
`20 radio resource control in some cases in that
`21 particular example.
`22 Q. RRC is a protocol; right?
`23 A. Again, I am not sure as to your definition
`24 but radio resource control is a form of -- is a layer
`25 that allows in this particular realization looking at
`
`Page 19
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`Page 21
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`1 the claimed paging signal to the Node B or
`2 the eNode B.
`3 BY MR. DUTTON:
`4 Q. Were there standard protocols at the time of
`5 the invention?
`6 A. Again, this is a topic that is outside my
`7 declaration. To my understanding, there were
`8 protocols by which you send information such as the
`9 claimed paging signal from the core network to the
`10 radio access network.
`11 Q. Were there standard protocols at the time of
`12 the invention?
`13 MR. EMERSON: Object to the form and
`14 scope.
`15 THE WITNESS: As I said, I mean, you
`16 have to look at -- my understanding of the
`17 claim is that the claim requires that a
`18 message be sent.
`19 And I've shown, for example, that the
`20 CATT reference, Exhibit 1005, discusses on
`21 page 2 that there is a message which
`22 corresponds to the claimed paging signal
`23 from the first network device to the second
`24 network device. Depending on the types of
`25 systems, my understanding is you may have
`
`1 radio resource control.
`2 Q. Is RRC is protocol?
`3 A. Again --
`4 MR. EMERSON: Object to the form.
`5 THE WITNESS: Again, as I said, I mean,
`6 this is a -- the term "protocol" does not
`7 appear, I believe, in the claims or in my
`8 declaration. It's a very high level term.
`9 What I've shown here is that, as part of
`10 my analysis, that there is a paging signal
`11 sent from a first network device to a second
`12 network device.
`13 BY MR. DUTTON:
`14 Q. How would a person of ordinary skill define
`15 a protocol?
`16 MR. EMERSON: Object to the form, scope.
`17 THE WITNESS: As I said, this is not
`18 something I have discussed in my declaration
`19 and is not something that is part of the
`20 claim. And if you want a general answer
`21 outside the context of this matter, of this
`22 IPR, a protocol is generally a framework by
`23 which you exchange messages.
`24 BY MR. DUTTON:
`25 Q. Does the access gateway and the Node B
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`Vijay Madisetti , Ph.D.
`Ericsson Vs. Intellectual Ventures II
`
`April 9, 2019
`
`Page 22
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`1 exchange messages using a framework?
`2 A. As I said, the claim does not require the
`3 use of a particular framework or a particular
`4 protocol. All it requires is that there is a core
`5 network, which I've identified as the access gateway
`6 of CATT just like the specification of 357. And just
`7 like the specification of the 357, I've identified
`8 the Node B of CATT as the second network device that
`9 receives the paging signal.
`10 Q. So -- but, generally speaking, the access
`11 gateway and the Node B do exchange messages using a
`12 framework; right?
`13 A. As I said, that is your opinion. In my
`14 understanding with respect to my declaration and my
`15 analysis of the 357 Patent, in the light of the
`16 product references, I have used the terms the first
`17 network device and the second network device to refer
`18 to a portion of the core network and a portion of the
`19 radio access network respectively as shown in CATT,
`20 C-A-T-T.
`21 Q. So how does an access gateway transmit a
`22 paging message to a Node B?
`23 MR. EMERSON: Object to the form.
`24 THE WITNESS: As I said, the claim does
`25 not require a description of the type of
`
`Page 23
`1 protocols used between the first and the
`2 second network device. It just requires
`3 that the first -- the first network device
`4 sends a paging signal to a second network
`5 device and that's where I've shown through
`6 CATT, C-A-T-T, that the first network
`7 device, which in CATT is described as an
`8 access gateway, sending signal to the eNode
`9 B. And that's shown on page 205 of Exhibit
`10 1005.
`11 BY MR. DUTTON:
`12 Q. Would CATT use a certain protocol to
`13 transmit that message?
`14 MR. EMERSON: Object to the form and
`15 scope.
`16 THE WITNESS: As I said, if you're
`17 referring to a portion of my declaration, I
`18 would be glad to provide a specific answer.
`19 My understanding is that the paging control
`20 procedure of CATT, page 2 in section three
`21 on page 205 of Exhibit 1005, describes
`22 explicitly and discloses that there is a
`23 first paging signal coming from the access
`24 gateway and going to the eNode B.
`25 BY MR. DUTTON:
`
`Page 24
`1 Q. So going to page 1 of CATT, CATT references
`2 TR 25.813; right?
`3 A. In page 1 of 5 of Exhibit 1005 in the
`4 section called, Mapping of PCH, it describes TR
`5 25.813 which is a technical report or a technical
`6 requirements documents to provide a generic
`7 description of what a paging channel is categorized
`8 by.
`9 Q. Okay. So going -- so CATT does reference
`10 TR 25.813; right?
`11 A. It does only to describe what are the
`12 characteristics of a paging channel in the context of
`13 LTE. It is not a specification. It's just a high
`14 level technical requirements document.
`15 Q. Is this the same report that you referenced
`16 on page 21 of your declaration?
`17 A. On page 21 with reference to the figure, I
`18 describe the -- an example of how TR 25.813, page 11
`19 of -- EXTRN, page 11, and EXTRN reference page 39.40
`20 illustrates some aspects of radio interface protocol
`21 between the eNode B and access gateway.
`22 And this is again referring to the issue
`23 with respect to 25.813, which is one of the technical
`24 reports referred to -- in CATT.
`25 Q. So what aspects of the radio interface
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`1 protocol is shown in this Figure 5.1?
`2 A. The only aspect is that there is a core
`3 network and then there is a radio access network and
`4 that they send signals back and forth.
`5 Q. How do they send signals back and forth?
`6 A. As I said, the specific discussion of the
`7 signals is not subject to the claim to my
`8 understanding. In my report, I show that the signals
`9 are sent as per explicit disclosure in CATT LG and
`10 CATT 2.
`11 Q. So as an expert in the field, how are these
`12 signals sent in Figure 5.1?
`13 MR. EMERSON: Object to the form and
`14 scope.
`15 THE WITNESS: This is not part of the
`16 claim and this is not part of my declaration
`17 nor does the claim require a specific means
`18 or way of sending the paging signal. My
`19 understanding is that different types of
`20 protocols, different types of functional
`21 partitioning would still satisfy the claim.
`22 BY MR. DUTTON:
`23 Q. Okay. So setting the claim scope aside,
`24 what protocols are shown in Figure 5.1 between the
`25 access gateway and the eNode B?
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`Vijay Madisetti , Ph.D.
`Ericsson Vs. Intellectual Ventures II
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`Page 26
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`April 9, 2019
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`1 A. As I said --
`2 MR. EMERSON: Object to the form and
`3 scope.
`4 THE WITNESS: As I said, I have not
`5 provided any discussion of the specific
`6 protocols. The architecture of 25.813 is
`7 exemplary. It is just to show one possible
`8 partitioning of functionality between the
`9 core network and the radio access network.
`10 BY MR. DUTTON:
`11 Q. So what is this one partitioning shown in
`12 Figure 5.1?
`13 A. It is, again, a high level conceptual
`14 architecture of Figure 5.1 and part of 25.813 that
`15 shows that there's an access gateway on right just
`16 like Figure 1 and there is an eNode B on the left
`17 just like Figure 1 as part of the radio access
`18 network.
`19 Q. So Figure 5.1 shows an eNode B on the left
`20 side of the figure; right?
`21 A. Yes, just like Figure 1 of the 357.
`22 Q. And figure 5.1 shows an access gateway on
`23 the right side of the figure; right?
`24 A. Yes, just like Figure 1 of 357.
`25 Q. And Figure 5.1 shows the S1 interface
`
`1 A. Again, this is a high level description that
`2 shows one possible demarcation of the radio access
`3 network and the core network. So I'm not sure what
`4 you mean by connection here.
`5 There is a message that is sent from the
`6 access gateway, just like in Figure 1 of 357, to the
`7 eNode B of Figure 5.1 just like in Figure 1 of the
`8 357.
`9 Q. And in Figure 5.1, what protocol is being
`10 used to send a message between the access gateway and
`11 the eNode B?
`12 A. As I said, the protocol is not part of my
`13 declaration nor is it part of the claim.
`14 Q. But what figure -- what protocol does
`15 Figure 1 use between the access gateway and eNode B?
`16 MR. EMERSON: Object to the form and
`17 scope.
`18 THE WITNESS: As I said, I mean, we have
`19 to -- in that particular example of
`20 Figure 5.1, we may have to refer to the
`21 document to see what they have actually
`22 considered.
`23 Again, it's not a standard. It's a high
`24 level conceptual document that outlines in
`25 the tradition of the 3GPP certain
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`Page 27
`1 between the eNode B and access gateway; right?
`2 A. Again, these are high level examples and
`3 this is not a specific standard. This is, again, a
`4 conceptual architecture insofar as the core network,
`5 which I've identified as the first network -- the
`6 first network -- the first network device of claim 11
`7 being an access gateway and the eNode B being a
`8 second network device that supports a draw from
`9 C-A-T-T, or CATT, which is Exhibit 100...
`10 Q. What is shown in the bottom left blue box
`11 labeled "PHY" --
`12 A. Of which figure?
`13 Q. -- of Figure 5.1.
`14 A. Yes. Please re-ask your question.
`15 Q. What is the "PHY" showing in the eNode B of
`16 Figure 5.1?
`17 A. It is showing a block that is an exemplary
`18 description of some of the functionality in that
`19 particular embodiment of the TR 25.813 as a part of
`20 the physical layer.
`21 Q. What functionality is it showing?
`22 A. It's showing some physical layer
`23 functionality.
`24 Q. And that physical layer is connected to the
`25 access gateway?
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`1 requirements from standards as opposed to
`2 being specifications themselves. And that
`3 is evident from the name TR 25.813 which is
`4 not a TS.
`5 BY MR. DUTTON:
`6 Q. So it would be in the document?
`7 A. No. As I said, we don't have -- as I said
`8 it's a high level architecture and it is not part of
`9 my -- the specific protocol is not part of the claim
`10 and it's not part of the network -- it's not part of
`11 my I declaration.
`12 In my declaration, I show that CATT, which
`13 is the reference I rely upon, explicitly discloses on
`14 page 2 as part of section three the message that is
`15 sent which is the claim paging signal.
`16 THE WITNESS: Are these mine?
`17 MR. DUTTON: I think now is a good time
`18 for a short break.
`19 (Recess from 9:51 a.m. to 10:02 a.m.)
`20 BY MR. DUTTON:
`21 Q. Welcome back.
`22 Let's turn to the 357 Patent, Figure 2.
`23 What is shown in Figure 2 of the 357 Patent?
`24 A. Figure 2, as described in column three, at a
`25 high level describes an embodiment that illustrates
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`Vijay Madisetti , Ph.D.
`Ericsson Vs. Intellectual Ventures II
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`Page 30
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`April 9, 2019
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`1 network initiated connection establishment.
`2 Q. Figure 2 shows an access gateway at the top
`3 of the figure?
`4 A. As described in column five, in the
`5 embodiment of Figure 2, there's a network controller,
`6 e.g., an access gateway, 118 in a core network.
`7 Q. So an access gateway is an example of a
`8 network device in a core network in Figure 2?
`9 A. Yes.
`10 Q. And Figure 2 itself shows an access gateway
`11 at the top of the figure?
`12 A. Figure 2 shows a network controller, an
`13 example of which is an access gateway in a core
`14 network which is block 118.
`15 Q. So 118 includes the label "aGW." Is that an
`16 access gateway?
`17 A. "AGW" stands for an access gateway and as
`18 described in column five, it's a network controller
`19 and an example of which is the access gateway.
`20 Q. So you said that Figure 2 shows a network
`21 initiated connection; right?
`22 A. I was reading from the specification that
`23 describes Figure 2 as an illustration of an
`24 embodiment of a network in