8/3/2021
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`Apple, Inc. v. Masimo Corp.
`
`Vijay K. Madisetti
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` APPLE INC.,
`
`Petitioner,
`
`-against-
`
` MASIMO CORPORATION,
`
`Patent Owner.
`
`Case Nos.
`
`IPR 2020-01536
`U.S. Patent 10,588,553 B2
`IPR 2020-01538
`U.S. Patent 10,588,554
`
`VIDEO-RECORDED DEPOSITION OF
`VIJAY K. MADISETTI, PH.D.
`Zoom Recorded Videoconference
`08/03/2021
`11:07 a.m. (EDT)
`REPORTED BY: AMANDA GORRONO, CLR
`CLR NO. 052005-01
`
`______________________________________________________
`DIGITAL EVIDENCE GROUP
`1730 M Street, NW, Suite 812
`Washington, D.C. 20036
`(202) 232-0646
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2021
`
`202-232-0646
`
`1
`
`APPLE 1036
`Apple v. Masimo
`IPR2021-00208
`
`
`
`Apple, Inc. v. Masimo Corp.
`
`Vijay K. Madisetti
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` APPLE INC.,
`
`Petitioner,
`
`-against-
`
` MASIMO CORPORATION,
`
`Patent Owner.
`
`Case Nos.
`
`IPR 2020-01536
`U.S. Patent 10,588,553 B2
`IPR 2020-01538
`U.S. Patent 10,588,554
`
`VIDEO-RECORDED DEPOSITION OF
`VIJAY K. MADISETTI, PH.D.
`Zoom Recorded Videoconference
`08/03/2021
`11:07 a.m. (EDT)
`REPORTED BY: AMANDA GORRONO, CLR
`CLR NO. 052005-01
`
`______________________________________________________
`DIGITAL EVIDENCE GROUP
`1730 M Street, NW, Suite 812
`Washington, D.C. 20036
`(202) 232-0646
`
`www.DigitalEvidenceGroup.comDigital Evidence Group C'rt 2021
`
`202-232-0646
`
`1
`
`APPLE 1036
`Apple v. Masimo
`IPR2021-00208
`
`
`
`8/3/2021
`
`Apple, Inc. v. Masimo Corp.
`
`Vijay K. Madisetti
`
`Page 2
`08/03/2021
`11:07 a.m. (EDT)
`
`VIDEO-RECORDED DEPOSITION OF VIJAY K.
`MADISETTI, PH.D., held virtually via Zoom
`Videoconferencing, before Amanda Gorrono, Certified
`Live Note Reporter, and Notary Public of the State of
`New York.
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`Apple, Inc. v. Masimo Corp.
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`A P P E A R A N C E S
`(Via Zoom Videoconferencing):
`ON BEHALF OF PETITIONER APPLE INC.:
` Dan Smith, Esquire
` Fish & Richardson
` 1717 Main Street
` Suite 5000
` Dallas, Texas 75201
` PHONE: 214-292-4071
` E-MAIL: Dsmith@fr.com
` -AND-
` Vivian Lu, Esquire
` Fish & Richardson
` 1000 Maine Avenue SW
` Washington, D.C. 20024
` PHONE: 202-626-7763
` E-MAIL: Vlu@fr.com
`
` -AND-
`
` Andrew B. Patrick, Esquire
` Fish & Richardson
` 1000 Maine Avenue SW
` Washington, D.C. 20024
` PHONE: 202-626-7735
` E-MAIL: Patrick@fr.com
`
` (Cont.'d)
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`Apple, Inc. v. Masimo Corp.
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`Vijay K. Madisetti
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`Page 4
`A P P E A R A N C E S (Cont.'d)
`(Via Zoom Videoconferencing):
`ON BEHALF OF PATENT OWNER MASIMO:
` Stephen W. Larson, Esquire
` Knobbe Martens
` 2040 Main Street
` Irvine, CA 92614
` PHONE: 949-721-5301
` E-MAIL: Stephen.larson@knobbe.com
`
` -AND-
`
` Jeremiah S. Helm, Ph.D., Esquire
` Knobbe Martens
` 1717 Pennsylvania Avenue N.W.
` Washington, DC 20006
` PHONE: 202-640-6400
` E-MAIL: Jeremiah.helm@knobbe.com
` -AND-
` Jacob Peterson, Esquire
` Knobbe Martens
` 925 4th Ave #2500
` Seattle, WA 98104
` PHONE: 206-405-2000
` E-MAIL: Jacob.peterson@knobbe.com
`
`ALSO PRESENT:
`Daniel Holmstock, Legal Video Specialist/Trial Tech,
`Digital Evidence Group
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`Apple, Inc. v. Masimo Corp.
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`Vijay K. Madisetti
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`Page 5
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` I N D E X
`
` WITNESS EXAMINATION BY PAGE
` VIJAY K. MADISETTI, MR. SMITH 8
` PH.D.
` E X H I B I T S
` EXHIBIT DESCRIPTION PAGE
` Exhibit 2004 Madisetti Declaration '553 14
` Patent.......................
` Exhibit 2004 Madisetti Declaration '554 14
` Patent.......................
` PREVIOUSLY MARKED EXHIBITS IDENTIFIED
` EXHIBIT DESCRIPTION PAGE
` Exhibit 1019 Design of Pulse Oximeters.... 14
` Exhibit 1001 United States Patent No. .... 27
` 10,588,553 B2
` Exhibit 1039 Hecht "Optics" Textbook 77
` .....
`
` R E Q U E S T S
` DESCRIPTION PAGE
` Review and Sign............................... 121
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`Page 6
` THE TECH: We are now on the record.
`This is Video No. 1 in the video-recorded deposition
`of Dr. Vijay K. Madisetti taken in the matter of
`Apple Inc., Petitioner, V. Masimo Corporation, Patent
`Owner, which is pending before the United States
`Patent and Trademark Office before the Patent and
`Trial Appeal Board for the following IPR and
`respective patent numbers: IPR 2020-01536, for
`Patent 10,588,553 B2 and IPR 2020-01539 [sic] for
`Patent 10,588,554.
` This deposition is being conducted by
`Zoom video remote conferencing with the physical
`recording of this deposition taking place at my
`location in Culpeper, Virginia.
` Today's date is August 3rd, 2021 and
`the time on the video screen is 11:07 a.m. Eastern
`Daylight Time.
` MR. LARSON: I think the second IPR
`Number should be 1538.
` Did you say 1539?
` THE TECH: Yes, I did. I believe
`that's --
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`Page 7
` MR. SMITH: You're correct, Stephen.
` THE TECH: Noted. The time on the
`video screen is 11:07 a.m. Eastern Daylight Time.
` My name is Daniel Holmstock. I'm the
`legal videographer and digital exhibit technician
`from Digital Evidence Group.
` Our court reporter today is Amanda
`Gorrono, also in association with Digital Evidence
`Group.
` And unless an objection is stated to
`the following agreement, all parties to this
`deposition are appearing remotely and have agreed to
`the witness being sworn in remotely.
` And due to the nature of remote
`reporting, please pause briefly before speaking to
`ensure all parties are heard completely.
` Counsel, would you please identify
`yourselves and whom you represent followed by the
`court reporter administering the oath.
` MR. SMITH: This is Dan Smith,
`representing Petitioner, Apple.
` And also -- sorry -- on the --
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`Page 8
`monitoring the line, is Andrew Patrick and Vivian Lu,
`also from Fish & Richardson.
` MR. LARSON: Steve Larson
`representing patent owner Masimo. Here with me are
`Jeremiah Helm and Jacob Peterson.
`VIJAY K. MADISETTI, PH.D., called as a witness,
`having been first duly sworn by a Notary Public of
`the State of New York, was examined and testified as
`follows:
`EXAMINATION
`BY MR. SMITH:
` Q. Good morning, Dr. Madisetti.
` A. Good morning, sir.
` Q. Could you please state your full name
`for the record?
` A. It's Vijay K. Madisetti.
` Q. And you're aware that you're being
`deposed in two cases today, the IPR 2020-01536 and
`IPR 2020-01538; is that correct?
` A. Yes.
` Q. Have you ever been deposed before?
` A. Yes.
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` Q. Besides the last two days?
` A. Yes.
` Q. About how many times have you been
`deposed?
` A. I don't remember the exact number,
`but quite often -- quite a bit.
` Q. During this deposition you understand
`I'm going to be asking you questions and you're going
`to be answering them under oath, correct?
` A. Yes.
` Q. And you understand that willful false
`statements made during this deposition are punishable
`by fine or imprisonment or both, correct?
` A. Yes, I do.
` Q. And you understand that every answer
`you give needs to be verbal, correct?
` A. Yes.
` Q. Is there any reason such as being
`under stress or physical or mental condition or being
`under the influence of any substance that would
`prevent or limit you today from giving truthful
`answers to my questions?
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` A. No.
` Q. Okay. We will be providing you with
`different exhibits from the case throughout the
`deposition and we have electronic copies of all the
`documents for both cases available. So if you would
`like to refer to a particular exhibit, let us know
`and we'll provide it to you. Okay?
` A. Okay.
` Q. And please do not consult documents
`or other information sources beyond those we provide
`during the course of this deposition. Okay?
` A. Sounds good.
` Q. Okay. What did you do to prepare for
`this deposition?
` A. I reviewed my Declarations.
` Q. Did you re- -- review any documents?
` A. No. No. None. I reviewed I think
`the patent, I reviewed the patent and -- yeah,
`nothing much.
` Q. About how long did you spend, did you
`spend preparing for this deposition?
` A. About three or four hours.
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`Page 11
` Q. Other than counsel, did you speak to
`anyone else to prepare for this deposition?
` A. No.
` Q. So you said you reviewed the patent,
`and your Declaration, are you familiar with the other
`documents and exhibits in this proceeding?
` A. Yes.
` Q. Okay. I'd like to, I'd like to have
`you look at Exhibit 2004 for the 1536 case?
` THE TECH: '553 or '554? I have no
`way to distinguish.
` MR. SMITH: Sorry. Let me set that
`up just real quick.
` Q. Dr. Madisetti, is it okay if I refer
`to the case IPR 2020-01536 as the '553 case?
` A. Okay.
` Q. And then is it okay --
` THE TECH: And --
` MR. SMITH: Yeah. Hold on just a
`second. I just want to set them both up so we can
`just say '553 and '554.
` Q. For the IPR 2020-01538 proceeding, is
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`Page 12
`it all right if I refer to that as the '554 case?
` A. Sounds good.
` Q. Okay. Let's look at Exhibit 2004 in
`the '553 case.
` A. Counsel, is it on the exhibit site?
` THE TECH: It's uploaded now, Doctor.
`You can refresh the screen and you can see it.
` Q. Are you still not seeing it,
`Dr. Madisetti?
` A. I see it. I'm downloading it. I'm
`creating a --
` Q. Okay. Cool.
` A. -- installing them on a separate
`location.
` Q. Okay. Just let us, let us know when
`you, when you have the document up?
` A. Yes, I've opened the document.
` Q. Okay. What is this document?
` A. This document is my Declaration, on
`the -- on this IPR, IPR 2020-01536.
` Q. And that is -- and that is the '553
`case, correct?
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`Page 13
`
` A. Yes.
` Q. Okay. Did you prepare this document?
` A. Yes.
` Q. Did you prepare it on your own or in
`coordination with counsel?
` A. The document -- the reports are mine.
`The declaration is mine. The opinions are mine. The
`counsel provided some -- some help -- editorial help.
` Q. And let's look briefly at the
`Exhibit 2004 for the '554 case.
` A. Okay.
` Q. Just let me know when you've got that
`as well.
` A. I can see that. It's downloading.
`Yes, I've opened it.
` Q. And what is this document?
` A. It's my Declaration on the U.S. IPR
`2020-01538 or the '554 case.
` Q. And was the process by which you
`prepared the declarations in the '553 and '554 cases
`both Exhibit 2004, was the process the same by which
`you prepared those declarations?
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` A. Yes.
` Q. Okay.
` (Whereupon, Exhibit 2004, Madisetti
`Declaration '553 Patent was marked for
`identification.)
` (Whereupon, Exhibit 2004, Madisetti
`Declaration '554 Patent was marked for
`identification.)
` Q. I'm going to be referring mostly to
`the '553, Exhibit 2004. So let's go back to that.
` A. Okay.
` Q. Okay. And is it okay if I refer to
`this as the '553 declaration?
` A. Yes.
` Q. Okay. Actually let's go to -- let me
`get one more exhibit out of the way here.
` Could we bring up Exhibit 1019 in the
`'553 case.
` (Whereupon, Exhibit 1019, Design of
`Pulse Oximeters was identified.)
` Q. And let me know when you -- this one
`may take a second to download, but let me know when
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`you've got it.
` A. I can see it now. Let me download
`that. Okay. I have opened Exhibit 1019, in the '553
`case.
` Q. Okay. And do you recognize this
`document?
` A. Yes.
` Q. And what is this document?
` A. This is the Webster reference.
` Q. And is the Webster reference a --
` MR. SMITH: Strike that.
` Q. Do you see the title on Page 1 of the
`Webster reference, the title that says "Design of
`Pulse Oximeters."
` Do you see that?
` A. I do.
` Q. Okay. And is it all right if I refer
`to this document as "Webster"?
` A. Okay.
` Q. Okay. Let's turn to page, PDF
`Page 96 and that would be the page labeled "79" in
`Webster.
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` A. Yes. I am at PDF Page 96.
` Q. Okay. And I want to direct you to
`the Section 6.3.2 titled "Optical interference."
` Do you see that?
` A. I do.
` Q. Are you familiar with this section?
` A. I think we discussed it in the
`previous day.
` Q. And what is your understanding of
`this section?
` A. My understanding of this section, it
`is a section in 6.3.2 titled "Optical interference,"
`within a broader Section 6.3, "Optical Concerns."
` Q. And is it fair to say that it's, it's
`related to the concept of optical interference?
` A. It's titled as "Optical
`interference," if that's your question.
` Q. Okay. Looking at the, at the second
`paragraph in that section --
` A. Yes.
` Q. -- the first two sentences say,
`"There are two types of optical interference that may
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`Page 17
`cause problems for the photodiode. The first is
`excessive ambient light."
` Do you see that?
` A. I see that on Section 6.3.2, the
`second paragraph describes two types of optical
`interference. And you read, you read it correctly.
` Q. Would you agree that ambient light is
`a type of optical interference that can cause
`problems for a photodiode?
` A. Would I agree with, with what?
` Q. With what I just, just stated.
` Would you agree that ambient light is
`a type of optical interference that may cause
`problems for a photodiode?
` A. Again, it's, it's a very general
`question. And it does not appear to be related to
`the IPRs at issue. Unless you can point to a
`particular portion of my Declaration.
` So as a general high-level response
`to your question, it can be, depending on the
`context.
` Q. Okay. What is ambient light?
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`Page 18
` A. Again, it's a very general term. It,
`again, depends on the context.
` Q. In the context of this case, what is
`ambient light?
` A. Again, it depends on the type of
`system, the type of devices, the type of sensors, the
`type of interference. It could be many things
`depending on the context.
` Q. Can you provide me with an example of
`ambient light in any context?
` A. An exemplary nonlimiting ambient
`light in certain types of contexts could be
`fluorescent lights.
` Q. Sorry. I didn't -- were you done
`with your answer there?
` A. Yeah.
` Q. Okay. So would, would surgical lamps
`be an example of ambient light in some context?
` A. In some context, depending on the
`type of system, depending on the type of use. Again,
`a nonlimiting exemplary example could be surgical
`lamps.
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`
` Q. Would sunlight be an example of
`ambient light in some context?
` A. Again, in certain contexts, in
`certain types of sensors, certain types of these
`cases, sunlight could be a nonlimiting example of
`ambient light.
` Q. So could ambient light be considered
`a form of optical interference?
` A. Again, it depends on the context, it
`depends on the type of use, it depends on the type of
`sensors, it may or may not be.
` Q. What is optical interference?
` A. Optical interference is a type of
`interference and it depends, again, on the context
`the type of use, the type of measurements, the type
`of parameters, the type of sensors.
` Q. Could you give me an example of
`optical interference in any context?
` A. Again, an exemplary nonlimiting
`example of optical interference could be, in certain
`context, certain use cases, could be fluorescent
`light.
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` Q. Could you give me an example of how
`optical interference can lead to problems in the
`detection of light signals in any context?
` A. Again, it's a very general question.
`And it depends on the context, the type of system,
`the type of measurements, the type of interference,
`interference could interfere with the accuracy, for
`example, of measurements. It could create noise, for
`example.
` But all of these are based on the
`context that I perfuse and these are not applicable
`in all cases.
` Q. Could ambient light interfere with
`the operation of a pulse oximeter in the way that you
`just described?
` A. Again, that depends on the context,
`the use case, the particular type of design, the
`particular constraints. It may or may not. It
`could. It may not. It depends, again, on the
`specifics of the design, the measurement, the type of
`measurement, et cetera. It could be or it could not.
` Q. Would a person designing a pulse
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`oximeter take into account the effect of ambient
`light on from the design of their system --
` MR. SMITH: Actually, strike that.
` Q. Would a person designing a pulse
`oximeter, consider the effect ambient light might
`have on detected signals?
` A. You have to be more specific. The
`question is very vague and very general. It refers
`to a hypothesis. I'm unsure if you're referring to a
`particular reference or a particular statement in my
`Declaration or a particular document.
` Q. What does it mean to saturate a
`photodiode?
` A. Again, it's a very high-level
`question, it depends on the type of diode, the type
`of characteristics it may have, the type of signals
`it is measuring.
` So, do you have something specific in
`mind? Are you referring to the Webster reference?
` Q. I am. Do you see in the third
`sentence, the third sentence of the paragraph we've
`been discussing, where it talks about -- it says
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`"usually this type of interference will saturate the
`photodiode so that no pulse can be distinguished."
` A. That's an example of a -- nonlimiting
`example of saturation. So with respect to Webster,
`it is one example, certainly not the only kind of
`example that may saturate a photodiode.
` Q. In that example, what does it mean to
`saturate the photodiode?
` A. In the example of Webster, again, a
`nonlimiting example, it describes -- Webster
`describes, I think, in this example, that when -- in
`this example of Webster, he describes it as a case
`where no pulse can be distinguished.
` Q. And in that example why can no pulse
`be distinguished, in your opinion?
` A. As I said, it's a very general
`question. Webster, I would have to review this
`paragraph in the specific context of this paragraph.
`I believe that he does not go into details. He
`simply says that a pulse cannot be distinguished by
`the photodiode in this nonlimiting example of
`interference that cases saturation.
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` Again, there are many reasons --
` Q. Can you give me -- sorry.
` A. -- there are many reasons, I guess,
`but I don't see something here to, to discuss that
`Webster discusses or provides.
` Q. Can you give me an example of a
`situation where a --
` MR. SMITH: Strike that.
` Q. Can you give me an example of
`saturation of a photodiode?
` A. Again, as Webster describes in this
`document, a nonlimiting example of saturation would
`be due to ambient light such as a fluorescent light.
` Q. And that ambient light would saturate
`the photodiode and effectively drown out the pulse
`signal so that it could not be detected by the
`photodiode; is that correct?
` A. I mean, that's your language. I see
`the language here, according to Webster. So my
`testimony is that Webster, in Section 6.3.2 discloses
`examples -- nonlimiting examples of interference in
`certain contexts. And Webster describes that certain
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`types of interference can saturate the photodiode so
`that no pulse can be distinguished.
` So that's, again, a nonlimiting
`example that Webster discloses which applies to
`certain use cases and certain scenarios. And by no
`-- and it's certainly a nonlimiting description.
` Q. In the example Webster gives, where
`the photodiode is saturated by interference so that
`no pulse can be distinguished, would that be an
`example of a low signal-to-noise ratio condition?
` A. Again, this is an exemplary
`nonlimiting example. There is no description of the
`type of sensor, the type of interference. It's a
`very high, high-level description so there is no
`additional information provided here. All I can say
`is maybe, maybe not. It depends on the context.
` Q. What would signal-to-noise ratio mean
`in the context of the example we're discussing in
`Webster?
` A. I don't think Webster describes,
`describes a signal-to-noise ratio. All Webster
`describes is a very high-level description that
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`depends on the type of context, the type of use, and
`all that is not described.
` Q. Can you give me an example of a
`signal-to-noise ratio?
` A. Again, that's not disclosed here as
`being relevant to this particular paragraph. All it
`says here is that it provides a specific nonlimiting
`example of what Webster calls in Section 6.3.2 as
`optical interference in certain contexts.
` Q. Would signal-to-noise ratio be
`something that a designer of a pulse oximeter would
`consider?
` A. Again, I cannot -- it depends on the
`context. It depends on the type of design. It
`depends on the context of use, the type of parameters
`being measured. So it all depends. They may, they
`may not. It all depends on the particulars of the
`design. And --
` Q. Are you familiar with the concept of
`signal-to-noise ratio?
` A. Again, you have to be more specific,
`what do you mean by concept of signal-to-noise ratio.
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`I understand signal-to-noise ratio as being the ratio
`of signal to noise.
` Q. So what's the signal? What's an
`example of a signal? Sorry.
` A. Again, a nonlimiting example of a
`signal could be something that you want to measure.
` Q. And what would be an example of noise
`in that, in that same context?
` A. As I said, again, it's a nonlimiting
`description, at a very high level and I'm connected
`to the patents or the IPR or my testimony in this
`Declaration. All I can say in response to your
`question is noise could be something in certain
`cases, a nonlimiting example of noise could be
`something that could be something like interference.
` Q. Could ambient light be an example of
`noise?
` A. Again, it's a very high-level
`question. It can be. It may not be. It depends on
`the type of instrument, the type of context, the type
`of use, types of experimental design, how the
`experimenter -- how the designer viewed as what they
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`wanted to measure so the answer is it depends on the
`context.
` Q. In a reflectance pulse oximeter,
`would reflected light from the tissue be an example
`of a signal?
` A. Again, it's a very general question.
`And it depends on the use, the type of context, the
`type of measurement, the type of site, all of those
`come into play. It, it may or may not be.
` Q. In the '553 patent, would light that
`has been reflected or attenuated or scattered by the
`tissue be an example of the signal?
` A. Could I look at the '553?
` Q. Sure.
` MR. SMITH: That would -- Daniel, if
`you want to put that up, that's Exhibit 1001.
` (Whereupon, Exhibit 1001, United
`States Patent No. 10,588,553 B2 was identified.)
` A. I see that. I'm downloading. So I'm
`looking at the U.S. Patent 10,588,553 which you
`referred to as the '553 patent and would you please
`ask me a question again about the '553.
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`
` Q. Give me just 2 seconds here.
` So my previous question was: In the
`context of the '553 patent, would light that has been
`reflected or attenuated or scattered by the tissue be
`an example of a signal?
` A. I'm going through the specification.
`In the '553 patent, in certain nonlimiting
`embodiments, the light reflecting can be a signal.
`Light reflected from the measurement area can be a
`signal.
` Q. And what would be an example of
`noise, in the context of the '553 patent?
` A. Just let me look through that.
` Q. Okay.
` A. An example of -- again, a nonlimiting
`example of noise could be interference due to light,
`due to ambient light as an example, a nonlimiting
`example.
` Q. Okay. Let's go back to Webster.
`This was again Webster, Page 79 of the -- of -- yeah,
`Page 96 of the PDF, Page 79, labeled "Page 79" in the
`book at the references.
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`
` A. Exhibit 1019?
` Q. That's correct. Sorry. I -- yeah,
`I'll -- I can refer to it by exhibit number. Let me
`know when you're, when you're there.
` A. I am there.
` Q. Okay.
` A. I'm on Page 96 of the PDF of the
`Exhibit 1019.
` Q. Okay. So back to -- I want to turn
`back to the section we were discussing previously,
`6.3.2 titled "Optical interference."
` Do you see that?
` A. I see that. I'm looking at Section
`6.3.2 of Exhibit 1019, which is the Webster
`reference.
` Q. Okay. And do you see the first -- in
`the first paragraph there, do you see the first
`sentence says, "To minimize errors, a pulse oximeter
`designer must attempt to limit the light reaching the
`photodiode to" what "has travelled through tissue
`containing arterial blood."
` Do you see that sentence?
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` A. In Section 6.3.2 in the section
`titled "Optical Interference" in Webster, the first
`sentence describes what you just read, and it also
`attributes it to Nellcor 1993.
` Q. So do you agree with that statement
`that I just read from Webster?
` A. It's a very general question and are
`you referring to something in my Declaration or my
`report?
` Q. Do you think that the statement I
`just -- I read from Webster is relevant to the '553
`and '554 patents?
` MR. LARSON: Objection; vague.
` A. I'm, I'm not sure as to your answer,
`Counsel. I was asking if you were referring to a
`portion of my Declaration. Is that a new question or
`are you referring to something in my Declaration or
`are you referring -- asking me to comment on the
`disclosure of Webster Section 6.3.2, the first
`sentence you read in?
` Q. I was asking you to comment on the
`disclosure of Webster. I was asking if you agreed
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`with the statement Webster makes that I read as part
`of my question.
` A. Again --
` MR. LARSON: Sorry, same objection.
` Go ahead.
` A.
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