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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________________
`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC.,
`SAMSUNG RESEARCH AMERICA, INC.
`Petitioner
`v.
`DYNAMICS INC.,
`Patent Owner
`_________________________________
` Case No. IPR2020-00499 – U.S. Patent No. 8,827,153
` Case No. IPR2020-00502 – U.S. Patent No. 10,032,100
` Case No. IPR2020-00504 – U.S. Patent No. 10,223,631
` Case No. IPR2020-00505 – U.S. Patent No. 10,255,545
`____________________________________
`
` REMOTE DEPOSITION OF STEPHEN GEOFFREY HALLIDAY
`Wednesday, October 21, 2020; 9:37 a.m. EST
`Job No.: 647554
`Pgs. 1 - 231
`Reported by: Cindy L. Sebo, RMR, CRR, RPR, CSR, CCR,
`CLR, RSA, Remote Counsel Reporter, LiveDeposition
`Authorized Reporter
`MAGNA LEGAL SERVICES
`(866) 624-6221
`
`Dynamics Inc. - EX. 2030
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`INDEX OF EXAMINATION
`
`STEPHEN GEOFFREY HALLIDAY
` EXAMINATION BY
` Mr. Morris
`
`8, 115
`
`PAGE
`
`- - -
`INDEX TO EXHIBITS
`- - -
` (Exhibits Attached to the Original Transcript.)
` HALLIDAY
` DEPOSITION
` EXHIBIT NUMBER DESCRIPTION PAGE
` 1 Patent Owner Dynamics Inc.'s
` Notice of Deposition of
` Stephen G. Halliday
`
`14
`
` 7 Declaration's of Stephen G.
`
` Halliday In Support of Petition
`
` for Inter Partes Review of U.S.
`
` Patent No. 10,032,100 38
`
`1
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`Deposition of STEPHEN GEOFFREY
`HALLIDAY taken by Patent Owner, held remotely before
`Cindy L. Sebo, Registered Merit Court Reporter,
`Certified Real-Time Reporter, Registered Professional
`Reporter, Certified Shorthand Reporter, Certified
`Court Reporter, Certified LiveNote Reporter,
`Real-Time Systems Administrator, Remote Counsel
`Reporter, LiveDeposition Authorized Reporter and
`Notary Public, beginning at approximately 9:37 a.m.
`EST, when were present on behalf of the respective
`parties:
`
`Page 3
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`Page 5
`
`A P P E A R A N C E S:
` (All via Zoom Video Communications.)
` Attorney for Petitioners:
` KIRKLAND & ELLIS LLP
` ALAN RABINOWITZ, ESQUIRE
` JAMES E. MARINA, ESQUIRE
` 601 Lexington Avenue
` New York, New York 10022
` 212.446.4800
` alan.rabinowitz@kirkland.com
` james.marina@kirkland.com
`
` Attorney for Patent Owner:
` ECKERT SEAMANS CHERIN & MELLOTT, LLC
` ROBERT W. MORRIS, ESQUIRE
` 10 Bank Street, Suite 700
` White Plains, New York 10606
` 914.286.6440
` rwmorris@eckertseamans.com
`
` ALSO PRESENT:
` TAERA FRANKLIN, Paralegal, Eckert Seamans
`
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`- - -
` INDEX TO EXHIBITS (Continued)
`- - -
`
` HALLIDAY
` DEPOSITION
` EXHIBIT NUMBER DESCRIPTION PAGE
` 9 Declaration of Stephen G.
` Halliday In Support of Petition
` for Inter Partes Review of U.S.
` Patent No. 10,223,631 159
`
` 11 U.S. Patent Number 10,032,100 39
`
` 13 U.S. Patent Number 10,223,631 159
`
` 20 U.S. Patent Number 4,701,601 224
`
` 21 U.S. Patent Number 7,114,652 82
`
` 22 U.S. Patent Number 7,097,108 102
`
` 23 U.S. Patent Application
` Publication Number
` US 2007/0034700 Al
`
`91
`
`
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`2 (Pages 2 to 5)2 (Pages 2 to 5)
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`P R O C E E D I N G S
`
`Remote Deposition
` Wednesday, October 21, 2020; 9:37 a.m. EST
`- - -
` STEPHEN GEOFFREY HALLIDAY,
` after having been first duly sworn remotely
` by the certified stenographer, was examined
` and testified remotely as follows:
`- - -
` CERTIFIED STENOGRAPHER: Thank
` you.
` The witness is sworn, and I'll go
` on mute now.
`- - -
` EXAMINATION BY COUNSEL FOR PATENT OWNER
`- - -
` BY MR. MORRIS:
`Q. Good morning, Mr. Halliday.
`A. Good morning.
`Q. Have you ever been deposed before?
`A.
`I have.
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` INDEX TO EXHIBITS (Continued)
`- - -
`
` HALLIDAY
` DEPOSITION
` EXHIBIT NUMBER DESCRIPTION PAGE
` 26 U.S. Patent Application
` Publication Number
` US 2006/0161789 Al
`
`139
`
` 43 Prosecution History, Part 1 59
`
` 44 Prosecution History, Part 2 59
`
` 56 Construing Terms of the Asserted
`
` Claims 154
`
`Page 7
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`Page 9
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` S T I P U L A T I O N S
`
` IT IS HEREBY STIPULATED AND AGREED
` by and between counsel no party to the litigation
` will object to the remote deposition on the grounds
` that the certified stenographer may not have the
` legal authority to swear in the witness.
`
` FURTHER STIPULATED AND AGREED
` that in lieu of the oath administered in person,
` the witness declares the testimony in this matter
` under the penalty of perjury.
`
` FURTHER STIPULATED AND AGREED
` that the certified stenographer is not physically
` present in the deposition room and will be
` reporting this deposition remotely.
`
` FURTHER STIPULATED AND AGREED
` all parties and their counsel consent to this
` arrangement and waive any objections to this manner
` of reporting.
`
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`Q. And how many times, roughly?
`A.
`Two.
`Q. When was the most recent time you
` were deposed before?
`A. Oh, maybe 18 months, two years.
`Q. And what was that in connection with?
`A.
`That would be -- that case
` involving -- boy, I'm having trouble remembering
` here now.
` It was a magnetic stripe case, but I
` can't actually remember the details, to be
` perfectly honest with you. It was about two
` years ago.
`Q. Do you remember either of the parties
` or any of the parties?
`A. One of the parties was Honeywell.
`Q. And how long before that on the other
` case that you were deposed?
`A. Probably another two years before
`that. And I don't remember when that one was.
`Q. And have you ever testified in court?
`A. No.
`
`
`
`3 (Pages 6 to 9)3 (Pages 6 to 9)
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`Page 10
` Q. Have you ever testified in front of
` the Patent Office?
` A. No.
` Q. Okay. I'm just going to go over some
` basic ground rules to try to make sure we're all
` on the same page.
` A. Sure.
` Q. Basically, all of your answers have
` to be oral, as I've -- as I've said --
` A. Yep.
` Q. -- and, as Alan confirmed, we are not
` recording this. So the only thing that's
` happening with all of the questions and all the
` answers is the court reporter is going to
` transcribe them in written form, and that's all
` we'll have --
` A. Okay.
` Q. -- so nods of the head or -- or
` things like "uh-huh" or "oh," or answers like
` that they just can't be recorded. And as the
` court reporter said, the goal of this is just to
` get an accurate record, a nice clean record, and
`Page 11
` that will be the best we can. So that's what
` we're looking for.
` Okay? Do you agree to that?
` A. I do.
` Q. Another -- never fun question, but
` I've got to ask it anyway.
` Are there any medical-related
` conditions, for example, that would prevent you
` from giving true and accurate testimony today?
` A. There are not.
` Q. And as we go through the day, I'm --
` I -- I'm sure at least one or two of my
` questions, you -- may not be clear. And if
` they're not clear to you and you don't understand
` what the question is, I would ask that you point
` that out to me and -- and let me know what --
` what you don't understand. And I'll follow that
` up or try to clarify my question to -- because,
` again, we're just trying to have a clean record,
` and that's -- that's all we're heading for.
` Okay?
` A. Okay. Yep. That's good.
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` Q. The other thing is that you -- this
` is your show, not my show. And so if you need a
` break for any reason at any time, just let us
` know. All I ask is that if it's in the middle of
` a pending question -- I just ask that we finish
` that question.
` I'll try to shoot out for a break
` about every hour or so. It sounds like we're
` shooting to have lunch at about noon. We'll
` figure out, close to that time, about how long
` we need, and we'll try to get this done as -- as
` efficiently as possible.
` A. Okay.
` Q. We've got it scheduled for today and
` tomorrow. Right now it's scheduled for two full
` days, and all of us hope that we don't need all
` that time.
` A. Okay.
` Q. So, with that -- or if you're ready
` to proceed with actual questions, we're ready to
` get started.
` A. Okay. I'm ready.
`
`Page 13
`
` Q. Okay. The way -- have you been
` deposed remotely, using Zoom?
` A. No. No --
` Q. Okay.
` A. -- this is new.
` Q. Yes, I -- I've been through this
` already too many times.
` The way that we're going to give you
` exhibits, since I can't actually hand them to
` you and I can't hand the court reporter them, is
` we've uploaded a whole bunch of documents, some
` of which we may or may not use, to the system.
` And what we will do is -- we'll at
` least start off trying to upload those documents
` to the Chat area. And there should be a link.
` And then you can just click on it and download
` it, so you'll be able to manipulate it on your
` computer as you see them come in.
` A. Okay.
` Q. If that's difficult and that's not
` working, please let us know.
` The other thing that we can do is
`
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`Page 14
` one of us can share our screen and we can put it
` up on the screen. That's especially easy to do
` in this situation where we're not trying to
` record the witness, or anything like that.
` And so whichever -- whichever one of
` those things works better for you, that's fine.
` If you have a clean paper copy of
` your four declarations, feel free to rely on
` those. I -- I ask if you have a copy with notes
` that you put that away, because you're not
` supposed to be relying on your notes.
` And -- and with that, we're ready to
` go.
` A. Okay. Thank you. I have clean
` copies of my reports in front of me.
` Q. So we'll start off by using as --
` designated as Exhibit Number 1, the deposition
` notice.
` - - -
` (Halliday Deposition Exhibit Number
` 1, Patent Owner Dynamics Inc.'s
` Notice of Deposition of Stephen G.
`Page 15
`
` Halliday, marked for
` identification, as of this date.)
` - - -
` MR. MORRIS: TaeRa, if you could
` provide that.
` BY MR. MORRIS:
` Q. And that's right there, if you want
` to click on it in the Chat window. It's a PDF
` you can download that should download relatively
` quickly.
` Just let me know when you have it.
` A. Yeah. My computer is taking a while.
` Yeah, there we go.
` Q. Not a problem.
` Have you seen this document before?
` If you take a second --
` A. I'm still trying to open it. Hang
` on.
` Q. Sure.
` (Pause.)
` THE WITNESS: There we go.
` (Whereupon, the witness reviews the
`
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`Page 16
`
` material provided.)
` THE WITNESS: Yes, I have it open.
` I don't think I've seen this particular
` document.
` BY MR. MORRIS:
` Q. Okay. Well, this is the deposition
` notice that we served on the Samsung parties, the
` Petitioner in the four different IPRs. And it's
` for today's deposition, which is supposed to be a
` consolidated deposition that's covering
` IPR2020-00499 on the '153 patent. That's
` U.S. Patent Number 8,827,153.
` And -- and going forward, can -- can
` we agree that we'll just refer to that as the
` "'153 patent"?
` A. We can.
` Q. And -- and it's also the -- this
` deposition also applies to IPR2020-00502, as it
` relates to U.S. Patent Number 10,032,100.
` And -- and it would be good if we
` could agree that we'll refer to that as the
` "'100 patent"?
`
`Page 17
`
` A. Yep.
` Q. Thank you.
` It also refers to IPR2020-00504.
` And that refers to U.S. Patent Number
` 10,223,631, which -- if we could agree to refer
` to it as the "'631 patent"?
` A. Yep.
` Q. And, finally, the fourth IPR that's
` involved in today's consolidated deposition is
` IPR2020-00505, as it relates to
` U.S. Patent Number 10,255,545, which we're going
` to refer to as the "'545 patent," if that's okay
` with you.
` A. Okay.
` Q. Great.
` Another bookkeeping question is:
` What's your home address?
` A. My home address is 123 Rooftop
` Court -- one word, Rooftop. That's in
` Stephenson, Virginia 22656.
` Q. And is that the location where you're
` being -- where you are sitting for the deposition
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`Page 18
`
` right now?
` A. It is indeed.
` Q. Okay. Now, what we're going to do is
` upload your CV, because I'd like to go over that.
` And that's going to be Exhibit Number 2.
` A. Can I close Exhibit 1?
` Q. You can. We won't be going back to
` that one.
` A. I have it open.
` Q. All right. And is this a familiar
` document to you?
` A. It is.
` Q. Is there anything -- if I was to get
` your CV today, would it have any changes to it,
` or is this the -- the -- basically the most
` current version?
` A. I think this is basically the most
` current version just checking. I don't see
` anything . . .
` (Whereupon, the witness reviews the
` material provided.)
` THE WITNESS: Yep.
`
`Page 19
`
` BY MR. MORRIS:
` Q. And if you could turn to Page 3, what
` we'll do is we'll kind of go through it briefly.
` And we'll go through it backwards so it's sort of
` in chronological order.
` A. Okay.
` Q. If you want to describe to me,
` briefly, your undergraduate -- your university
` education.
` A. University of Manchester in the
` United Kingdom. I have a B.Sc. in electrical and
` electronic engineering. It's -- in the UK,
` degrees are three-year courses. And I have a
` certificate for that.
` Q. And what was the first thing that --
` I noticed that during the time when you were at
` university, you also seemed to be working at --
` at a high-energy physics lab at Rutherford.
` A. Right.
` Q. Could you just give me a brief
` description about that?
` A. Sure. So Rutherford is a Government
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` lab. They sponsor students -- they used to
` sponsor students every year to go to university.
` I competed against 60 other students and won one
` of those sponsorships.
` That sponsorship involved me working
` all summers during the -- for a year before and
` for all of the summers during the degree process
` in different areas of the lab on different
` things that I did.
` It's a high-energy physics lab, so
` they are splitting atoms and doing all those fun
` things.
` Q. That does sound like fun. And, yet,
` you ended up getting into magnetic --
` A. Yeah.
` Q. Your first job was with Wolfson.
` Can you briefly describe what you
` did there at Wolfson?
` A. Yes. Wolfson is a unit inside of a
` university. It's a fairly common thing inside --
` in the UK for universities to have Wolfson units.
` It's a foundation from a gentleman who wanted to
`Page 21
` foster better relationships between universities
` and industry.
` So the unit is a small unit that
` spends its time taking jobs from industry and
` interfacing with the academic staff to provide
` expertise to do things. Several projects there
` involved noise-reduction headsets.
` Today, we go out and buy a pair of
` Bose noise-reduction headsets without even
` thinking about it. Back then, no such thing was
` available. And we had a contract from the UK
` Ministry of Defense to develop something for
` aircrew.
` I was involved in a buoy system for
` trawlers in the North Sea, a distress
` signal system to help alleviate the loss of
` trawlers in the North Sea.
` And I was involved in a -- a piece
` of test equipment to test magnetic stripes as
` they're laid on film in the first process of
` making the stripes for credit cards.
` Q. Okay. And then it looks like you
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`Page 22
` spent, what, roughly three years or so there, and
` then you moved on to Thorn?
` A. Yeah.
` So Thorn EMI is a big
` multinational -- most people know EMI from
` EMI Music. Thorn EMI was a joint of Thorn and
` EMI at some point, where they manufactured
` almost everything from white goods,
` refrigerators, washing machines, all the way
` through to very high-tech equipment.
` The particular division I was in
` made magnetic tape, credit cards, card readers,
` that kind of thing. So I started off there in
` the UK working for them, and they transferred me
` to their U.S. division in 1982, where I stayed
` for another five years.
` Q. So -- so that 1982 is -- basically,
` '82 to '87, you were in the U.S.?
` A. Yep.
` Q. You were a manager in charge of a
` group, I assume?
` A. Yes, I was. My primary
`
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`
` responsibilities were the development of
` semicustom integrated circuits to read magnetic
` stripes on credit cards.
` Q. And what were those circuits for?
` They would go into point-of-sale terminals?
` A. So Thorn EMI had developed a
` high-security magnetic stripe, something that
` could not be copied. We spent a long time trying
` to convince Visa and Mastercard, American Express
` that they needed to improve the security of
` magnetic stripe.
` So I developed readers -- ICs to go
` into readers to read the high-security property.
` We spent, as I said, a lot of time doing that.
` Visa and Mastercard hacked our system and agreed
` that it was almost impossible to counterfeit,
` but then in the way these things happened,
` decided that they were not going to use it
` because the problem was only a $2 billion
` problem, and they didn't see it as being
` important. So . . .
` (Laughter.)
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`
` BY MR. MORRIS:
` Q. Yes. Yes. Dealing with my own
` issues like that right now.
` All right. And then you returned to
` the UK for a couple of years?
` A. No. I'm then -- now in the U.S.
` completely. From 1982 onwards, I'm in the U.S --
` Q. Okay.
` A. -- I left Thorn EMI to go and work
` for GFI Genfare in Chicago. Genfare is a company
` that makes fare-collection equipment for buses
` and trains. So if you've ever been on a bus and
` seen the fare box on the bus where you put your
` money, they make that. They also make turnstile
` systems and ticket vending machines, and so
` forth.
` At that time, they were a -- they
` only accepted cash in their equipment, so they
` wanted somebody with mag stripe expertise to
` come onboard to help them move all of their
` equipment into a card-based system so that they
` could accept mag stripe cards on buses and in
`Page 25
`
` turnstiles, and things.
` Q. And then did -- did your work involve
` anything in the transition from a lot of these
` places to actual fare cards that had their own
` little mag stripes?
` A. Right. So that was what we did.
` We -- we changed -- we built GFI's equipment to
` be able to accept all of those fare cards. We
` built a vending machine that vended those
` systems.
` It's a very strange industry:
` fare-collection equipment industry. Almost
` every contract that goes out goes out to the low
` bidder. So there are only a few companies that
` are involved in making fare boxes or making
` turnstiles.
` So, inevitably, you were always in a
` low-bid-type situation. So we would bid for
` contractors around the world, mostly the U.S.,
` but some of them around the world. And that
` would then be -- the low bidder would win and
` install all of the equipment.
`
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` So, typically, when you go to a
` town, a city, you'll find all of their fare
` collection equipment comes from one vendor
` because it all came in one contract as a low-bid
` contract.
` Q. And then because it was the
` low-bidder contract, at least 25 percent of it
` doesn't really work in the end?
` A. Well, that may be true. I don't
` know. Yeah.
` Q. And so what caused you to leave -- to
` leave GFI?
` A. So, with GFI, I had been, obviously,
` very involved with magnetic stripes and how they
` work, and so forth. It became very obvious,
` during the work at GFI, that we needed to set
` some quality standards and understand the quality
` of magnetic stripe's tickets that we were
` purchasing.
` I had been involved in
` Thorn EMI Malco with test equipment that tested
` stripes, so we had got -- bought some of that
`Page 27
`
` equipment to test things.
` I had become increasingly involved
` in the AIM trade association, sitting on their
` technical committee for magnetic stripes. I was
` already involved in the ISO world for magnetic
` stripes. And AIM came to me and -- let's say
` they offered me a job I couldn't refuse.
` Q. Okay. And you've been in Pittsburgh
` ever since then?
` A. So I was in Pittsburgh until about
` three years ago. Three years ago, we moved to
` Virginia. I worked for AIM for 10 years and then
` went out to be a consultant on my own.
` I apologize. The phone is ringing
` here, and I can't turn it off, so it'll have to
` ring itself out.
` I left AIM to go out and be a
` consultant and have been doing that ever since.
` When my children left home, we
` decided it was time to -- they say downsize,
` don't they? I'm not sure that really happened.
` But, anyway, we moved --
`
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` Q. Okay.
` A. -- I'm now in Virginia.
` Q. You are still with High Tech Aid?
` A. Yes. That's my company.
` Q. And then what's the
` RAIN RFID Alliance that you seem to be involved
` with as well?
` A. So that's a client. The RAIN RFID
` Alliance is an association of companies involved
` in passive UHF RFID. Back in 2014, four
` companies that were involved with the technology
` came to me and said could I help them set up a
` trade association to help market their
` technology. We worked together to find a way to
` set up that association.
` We chose to go back to my former
` employer, which is AIM, and become a part of
` AIM -- separately governed our own board of
` directors -- our own dues structure, and run it
` inside of AIM.
` I was then asked to be -- if I would
` be the president -- staff person president and
`Page 29
` run the organization, which I have done since
` 2014.
` We have some other people on staff
` here with me. It's a part-time thing so that
` they don't have to pay for full-time staff. And
` we are a part of AIM and use AIM's nonprofit
` license and accounting facilities and all of
` those things to help minimize our costs to our
` members.
` We currently have about 160
` companies worldwide who are members of the
` association, of the four that originally formed
` it.
` Q. Okay. And what kind of work do you
` do for the association?
` A. So the association is primarily a
` marketing organization. Our job is to increase
` adoption of the technology. So my particular job
` is to recruit members, to organize events, to
` represent the alliance in various other events
` around the world.
` So, in normal times, I would be
`
`
`
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`Page 30
` traveling around the world, going to different
` trade shows or conferences and speaking for the
` alliance about the technology and the benefits
` that the technology brings.
` Q. And what technology is that these
` days that you're trying to market?
` A. It's passive UHF RFID. So RFID comes
` in many different flavors. UHF RFID, which is
` the type of RFID that works at the 900 --
` 900-megahertz point that secure technology is
` being adopted by many, many companies as the RFID
` technology outside of point of sale.
` And if you go to a -- a JCPenney or
` a Kohl's or a Macy's or a -- even Sears,
` they -- they tag many of the items in the store
` with one of those tags, and they use it for
` inventory control, for locating things.
` So the technology is a long-distance
` technology. You can read the tags up to 10,
` 15 meters. And it's gaining a lot of acceptance
` in the retail world right now.
` There have been several major
`
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`
` announcements recently about healthcare
` companies, pharma companies beginning to use it.
` IATA, which is the industry association for the
` airlines, has announced that all baggage tags
` will include passive UHF in the future. That
` was supposed to have started this year.
` Needless to say, the airlines don't
` have any money anymore, so that's been delayed.
` But that's the kind of thing that I
` do. I meet with organizations like that,
` groups, and try and get the technology adopted
` for the use in their -- their particular arena.
` Q. And that technology has nothing to do
` with the tap-to-pay that goes on payment cards,
` right?
` A. No. That's a -- an HF technology, a
` 13.56 megahertz technology, and it works in a
` completely different way.
` Q. Completely different way and much
` short distances, et cetera?
` A. Absolutely, yes.
` Q. When was the last time you did any of
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` the design work-type tasks that you used to do in
` the old days?
` A. Many, many years ago. Yes.
` Q. Okay. Do you have any patents?
` A. I do not.
` Q. Has any of the work you've ever been
` working on either through yourself or
` companies -- did anybody file a patent
` application for anything you've done?
` A. Not that I'm aware of.
` Q. For both of the cases that you have
` been deposed on, were they both patent
` infringement cases?
` A. They were.
` Q. And -- and up until that point in
` time, had you ever seen a patent application file
` history?
` A. I do not believe so, no.
` Q. And you know what I referred to --
` what I mean --
` A. I do.
` Q. -- and just so the record's clear,
`
`Page 33
` what would you say the patent application file
` history is?
` A. It gives the complete history from
` once -- when the patent is first filed, how it's
` assessed by the Patent Office, with any comments
` that they may have and requirements for changes
` or suggestions for changes, followed by anything
` that subsequently happens, through to the final
` acceptance or rejection of the patent.
` Q. Okay. And with regard to this case
` specifically, do you remember the first time you
` were contacted about this case?
` A. Sometime around mid last year, I
` think. I don't have the date.
` Q. And I'm going to ask you a couple
` other questions. I don't want you to reveal the
` content of any communications that you may have
` had with counsel. So I'm just trying to get some
` factual questions.
` For example, who contacted you?
` Like, was it -- was it Mr. Rabinowitz?
` A. It may have been. I don't actually
`
`
`
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` remember.
` Q. Okay. And could you just confirm
` what your hourly wage is for this case?
` A. Three hundred dollars an hour.
` Q. And do you get paid that amount for
` all the time that you bill and you don't -- do
` you get paid anything extra?
` A. If there was such a thing as travel
` and in-face depositions and court time, I would
` get a higher rate.
` Q. Okay. But there's no bonus if -- if
` Samsung --
` A. Absolutely not, no.
` Q. And with regard to -- you're aware
` that there's another action going on between the
` two parties at the International Trade
` Commission?
` A. Counsel made me aware of that, yes.
` Q. And -- and have you talked with any
` of the witnesses in that action?
` A. I have not.
` Q. Have you spoken with any of the
`Page 35
`
` experts in that case?
` A. I have not.
` Q. Have you read any materials from that
` case?
` A. I have not.
` Q. There are a couple of documents that
` you actually refer to, and I guess what I'm
` really just trying to make sure -- and we can go
` over those later. You don't have to just
` remember off the top of your head. So I'll bring
` those to your attention. I'll try to make a note
` and remind you of that.
` A. Okay.
` Q. With regard to your work in this
` case, did you go off and conduct a prior art
` review?
` A. Yes, I did.
` Q. And did you do that search yourself?
` A. I did some searching myself, yes.
` Q. And did you hire a search company to
` do any kind of searching?
` A. I did not.
`
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` Q. In addition to the prior art that you
` found on your own, was -- was additional prior
` art, without revealing what was -- what may or
` may not have been given to you -- but was
` additional prior art provided to you over and
` above what you found on your own?
` A. It was.
` Q. And prior to your involvement in this
` case, had you ever heard of Dynamics?
` A. I had not, no.
` Q. While you were in Pittsburgh, did you
` have any involvement with Carnegie Mellon in any
` way?
` A. Only on the periphery. I -- one of
` the companies that I owned, RFIDTraxx --
` Carnegie Mellon had