UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`-------------------------------- x
`SNAP INC., : Case No.
` Petitioner : IPR2021-00987
` vs :
`PALO ALTO RESEARCH CENTER, INC., : U.S. Patent No.
` Patent Owner : 8,489,599
`-------------------------------- x
`
` Oral deposition of
` DAVID MARTIN, Ph.D.
`
` VIA VIDEO/TELECONFERENCE
` WEDNESDAY, JULY 27, 2022
` 12:48 p.m. EASTERN TIME
`
`Job No.: 455803
`Pages: 1 - 37
`Reported by: Lisa V. Feissner, RDR, CRR, CLR
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`SNAP EXHIBIT 1029
`Snap Inc. v. Palo Alto Research Center Inc.
`IPR2021-00987
`IPR2021-01271
`
`Page 1 of 39
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`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`-------------------------------- x
`SNAP INC., : Case No.
` Petitioner : IPR2021-00987
` vs :
`PALO ALTO RESEARCH CENTER, INC., : U.S. Patent No.
` Patent Owner : 8,489,599
`-------------------------------- x
`
` Oral deposition of
` DAVID MARTIN, Ph.D.
`
` VIA VIDEO/TELECONFERENCE
` WEDNESDAY, JULY 27, 2022
` 12:48 p.m. EASTERN TIME
`
`Job No.: 455803
`Pages: 1 - 37
`Reported by: Lisa V. Feissner, RDR, CRR, CLR
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`SNAP EXHIBIT 1029
`Snap Inc. v. Palo Alto Research Center Inc.
`IPR2021-00987
`IPR2021-01271
`
`Page 1 of 39
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
`
`2
`
`A P P E A R A N C E S:
`ON BEHALF OF PETITIONER:
` JOSEPH E. PALYS, ESQUIRE
` ANDERSON Y. TO, ESQUIRE
` PAUL HASTINGS, LLP
` 2050 M Street NW
` Washington, DC 20036
` 202.551.1996
` josephpalys@paulhastings.com
`
`ON BEHALF OF PATENT OWNER:
` JAMES E. QUIGLEY, ESQUIRE
` MCKOOL SMITH
` 303 Colorado Street, Suite 2100
` Austin, TX 78701
` 512.692.8720
` jquigley@mckoolsmith.com
`
`A L S O P R E S E N T:
` RACHEL CARRICK, A/V Technician
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
`
`3
`
` C O N T E N T S
`EXAMINATION OF DAVID MARTIN, Ph.D. PAGE
` By Mr. Palys 4
`
` E X H I B I T S
` (Attached to transcript)
`DEPOSITION EXHIBIT PAGE
`(None marked.)
`
` P R E V I O U S L Y
` M A R K E D E X H I B I T S
` (Attached to transcript)
`EXHIBIT PAGE
`SNAP 1005 U.S. Patent No. 7,577,522 7
`PARC 2008 Declaration of David Martin 5
` Regarding Patent Owner's Reply
` in Support of Its Contingent
` Motion to Amend
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
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`4
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` P R O C E E D I N G S
` DAVID MARTIN, Ph.D.,
`having been first duly sworn, was examined and
`testified as follows:
` EXAMINATION
`BY MR. PALYS:
` Q I guess it's still good morning for you,
`Dr. Martin. Good afternoon for me.
` A Good afternoon.
` Q Good to see you again.
` So like we just finished with the other
`deposition, I just want to confirm, you don't have
`anything else open on your computer other than the
`Zoom file, and perhaps you may also have some file
`explorer window that has copies of exhibits.
` Is that accurate?
` A That's correct. I also have a volume
`control panel open and a printout of the claims of
`the '599 patent extracted from one of my
`declarations.
` Q Thank you for confirming that, sir.
` Is there any reason you cannot provide
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
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`5
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`truthful and accurate testimony today?
` A No, sir.
` Q If you could please open your
`declaration -- your second declaration, which is
`Exhibit 2008, in the '987 matter, and let me know
`when you have that.
` A I do have it.
` (Previously marked Exhibit PARC 2008
`referenced.)
`BY MR. PALYS:
` Q Okay. And can you confirm on the last
`page, page 177, after paragraph 110, that that's
`your signature in Exhibit 2008?
` A I see it, yes.
` Q Is that your signature, sir?
` A Yes, that is my signature.
` Q Thank you.
` Let's start with paragraph 3 of your
`second declaration, Exhibit 2008. Can you let me
`know when you're there.
` A I see it, yes.
` Q Okay, great.
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
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`6
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` And in paragraph 3 of Exhibit 2008, you
`state that you conclude that substitute claims meet
`all the statutory requirements required for
`patentability, including those of written
`description and that the substitute claims are not
`broader than the original claims.
` Correct?
` A That is what I state here based on my
`understanding of those statutory requirements.
` Q What is the standard that you applied in
`evaluating whether the substitute claims are broader
`than the original claims?
` A As I understand the law, a substitute
`claim would be considered broader than an original
`claim if there is a scenario in which the substitute
`claim is -- has all of its limitations satisfied,
`but the original claim does not have all of its
`limitations satisfied.
` Q Is a substitute claim broader than the
`original claim if it adds a narrowing limitation but
`also deletes an existing limitation, under your
`understanding of broadening statutory requirements
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
`
`7
`
`that you reference in paragraph 3?
` MR. QUIGLEY: Objection, form.
` A My understanding is that one has to
`evaluate the claim as a whole and not merely look to
`an individual piece within the claim.
` So without knowing more about the
`specific limitations in question, I don't think I
`could say whether it meets that definition of
`"broader" that I just stated.
` Q Could you please pull up a copy of
`Rosenberg, Exhibit 1005, and let me know when you
`have that, sir.
` A Yes, I have it up.
` (Previously marked Exhibit SNAP 1005
`referenced.)
`BY MR. PALYS:
` Q Awesome.
` Let's go to column 8 of Rosenberg, and
`specifically, let's start at line 51. Let me know
`when you're there.
` A I see 8, 51.
` Q Great. In column 8, line 51, starting on
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
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`8
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`line 51, Rosenberg described in Figure 1, and in
`particular, Rosenberg states, Referring to Figure 1,
`portable computing device 111 includes within it a
`number of components including a local processor, a
`local memory, a locative sensor, a display 101, a
`user interface 103, hardware and software for
`generating alerts, and reminder circuitry adapted to
`manage and trigger reminders based upon the changes
`in physical location of the user as he or she moves
`the portable computing device 111 about the
`physical -- the real physical world.
` Correct?
` A That looks correct, yes.
` Q And at column 8, around line 62,
`Rosenberg states that, The user interface 103
`includes the aforementioned display 101 in addition
`to user input devices (e.g., buttons) 105.
` Correct?
` A Yes, I see that at line 62.
` Q And if we turn to Figure 1 real quick,
`let me know when you're there.
` A Yes, I see Figure 1.
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`9
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` Q So Figure 1 here is obviously depicting
`the portable computing device 111 that's described
`in column 8 of Rosenberg, correct?
` A It looks like the column 8 passages we
`just went over do refer to this Figure 1, yes.
` Q And the portable computing device 111 of
`Figure 1 shows the user input devices 105 and the
`display 101 which are part of the user interface
`103, correct?
` A Yes. It says, The user interface 103
`includes the aforementioned display 101 in addition
`to user input devices (e.g., buttons) 105.
` Q Since we're on Figure 1, why don't we
`flip to Figure 2. And looking at Figure 2, you see
`this element labeled 111 on the bottom left of
`Figure 2, correct?
` A I do see an element labeled 111 in
`Figure 2.
` Q If we turn back to the specification of
`Rosenberg, column 12, line 64. Let me know when
`you're there.
` A Line 64, I see it.
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`Transcript of David Martin, Ph.D.
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`10
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` Q Actually, let's start at -- yeah,
`line 64, that's fine.
` Rosenberg states describing Figure 2,
`Referring to Figure 2, an exemplary configuration of
`the spatially associated personal reminder system
`includes the portable computing device 111.
` Correct?
` A I'm sorry. I might be in the wrong
`column. Could you repeat where we are?
` Q Sure. It's column 12 starting at
`line 64. And I'll repeat my question for you, sir.
` A Thanks. I'm ready.
` Q Great. And at column 12, line 64 is
`describing Figure 2, and Rosenberg states that,
`Referring to Figure 2, an exemplary configuration of
`the spatially associated personal reminder system
`includes the portable computing device 111 that is
`kept with the user 108 as he or she moves about the
`real physical world.
` Correct?
` A That's what it states, yes.
` Q And jumping back to Figure 2, let's look
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
`
`11
`
`at portable computing device 111. Figure 2 shows
`device 111 including a display and what appears to
`be a keypad, correct?
` A I would agree that -- it's a little
`blurry and blocky in Figure 2, but it looks like 111
`depicts a device with a screen and a keypad, as I
`look at it.
` Q Go to the next page, please, sir, and
`look at Figure 3.
` And Figure 3 shows the portable computing
`device 111 similar to what you've seen in Figure 1,
`correct?
` A That's correct, Figure 3 does show an
`image similar to Figure 1.
` Q And Rosenberg describes Figure 3 in
`column 15, starting at line 8. Let me know when
`you're there.
` A I'm there.
` Q Great. So in column 15, line 8,
`Rosenberg is again describing Figure 3 and stating
`that, A portable computing device 111 that's
`configured with appropriate hardware and software to
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
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`12
`
`support embodiments of spatially associated personal
`reminder systems and methods exemplarily disclosed
`herein, may take the form of a handheld device such
`as a cell phone or PDA and includes display
`functionality and user interface controls.
` Correct?
` A Yes.
` Q So the portable computing device 111
`could be something like a cell phone or a personal
`digital assistant, correct?
` A As stated here in column 15, the portable
`computing device may take the form of a handheld
`device such as a cell phone or PDA. And so for the
`purpose of the explanation here, yes, I would agree,
`cell phone or a personal digital assistant are
`possibilities for the form of the device.
` Q And cell phones and PDAs were known at
`the time to have keypads or buttons to allow the
`user to provide input to the device, correct?
` MR. QUIGLEY: Objection, form.
` A I would agree that as of the date of the
`patent, certainly in 2009, both cell phones and
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
`
`13
`
`personal digital assistants had some form of
`communication input device. I'm sorry, I don't know
`if that was -- addresses your question or not.
` Q It did. Thank you.
` Actually, you were kind of a little
`broader than what I thought.
` My question was, would a person of
`ordinary skill in the art understand that cell
`phones and PDAs at the time to have keypads or
`buttons that would allow a user to provide input to
`the device?
` MR. QUIGLEY: Same objection.
` A I would say that a person of ordinary
`skill in the art in 2009 would understand a cell
`phone or PDA to have a user input device that can be
`used for the user to be able to provide input to the
`device.
` Q Would you agree that a person of ordinary
`skill in the art would have understood at the same
`time that the user input device that you identified
`in your answer could include a keypad or buttons
`that would allow the users to provide input to the
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`Transcript of David Martin, Ph.D.
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`
`14
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`device?
` A It's also true --
` MR. QUIGLEY: Same objection.
` A It's also true that in 2009 a person of
`ordinary skill in the art would understand that a
`cell phone or PDA may include a keypad with buttons
`that can be used to provide input to the device.
` Q And would a person of ordinary skill in
`the art also understand that at the same time frame
`that cell phones and PDAs could have as an example a
`touchscreen as an input device that would allow the
`user to provide input?
` MR. QUIGLEY: Same objection.
` A A person of ordinary skill in the art in
`2009 would also be familiar with cell phones and
`personal digital assistants that had touchscreens
`that could be used to provide input to the device,
`generally speaking.
` Q Looking back at column 15 of Rosenberg,
`specifically starting at line 18 of column 15,
`Rosenberg explains with respect to the portable
`computing device in Figure 3 that that device 111
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
`
`15
`
`also includes the user interface 103 that has a
`display 111 and user input devices 105, correct?
` A That is what it states there, yes.
` Q If we jump down to the bottom of column
`15, please, sir, around line 52. Rosenberg
`describes Figure 4 as an exemplary block diagram of
`a portable computing device 111, correct?
` A Yes, it does state that.
` Q And it refers to the portable computing
`devices 111 that includes a communication
`infrastructure 90, and moving down the line of
`around line 58, has a central processor, main
`memory, correct?
` A This passage from column 15 does mention
`each one of those elements.
` Q And if we look at Figure 4, jumping back
`up, sir, if you don't mind.
` Figure 4 showing that block diagram that
`was discussed in column 15 of Rosenberg, you see
`that Rosenberg shows the data box 111 as the
`personal computing device, correct?
` A In Figure 4, the large dotted box is --
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
`
`16
`
`does appear to be labeled 111, yes.
` Q You would understand, or rather a person
`of ordinary skill in the art would understand that
`that 111 is the personal computing device that's
`described by Rosenberg such as in column 15,
`correct?
` A Yes. Specifically, at line 52 and 53, it
`refers to portable computing device 111.
` Q And the portable computing device 111 of
`Figure 4 also includes a block labeled user input
`devices 105, correct?
` A Yes, there is an element called user
`input devices labeled 105 there.
` Q And if we could jump back to the
`specification, please, sir. At column 16, and in
`column 16, Rosenberg's continuing discussion of
`Figure 4 and in particular in line -- starting at
`line 34, Rosenberg explains that, The user input
`devices 105 employed on the portable computing
`device 111 may include a pointing device (not shown)
`such as a mouse, thumbwheel or track ball, an
`optional touchscreen (not shown); one or more
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
`
`17
`
`pushbuttons (not shown); one or more sliding or
`circular rheostat controls (not shown), one or more
`switches (not shown), and/or a tactile feedback unit
`(not shown); or the like; or combinations thereof.
` Correct?
` A I see that passage, yes.
` Q And Rosenberg further explains in line 40
`of column 16 that, One skilled in the art will
`appreciate that the user input devices 105, which
`are not shown, are well known and understood.
` Right?
` A That was starting at line 40. Yes, I see
`that.
` Q Would you agree with Rosenberg's
`statement there that, oNE skilled in the art will
`appreciate that the user input devices 105, which
`are not shown -- as exemplified above -- are well
`known and understood?
` MR. QUIGLEY: Objection, form.
` A If that passage stating one skilled in
`the art will appreciate that the user input devices
`105, which are not shown here, are well known and
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
`
`18
`
`understood, if that passage refers specifically to
`the variants of the input device that are described
`earlier in the paragraph, then I would agree that a
`person of ordinary skill in the art would have at
`least a superficial image or impression of what each
`one of those descriptions would mean.
` Q And the user input devices 105 of the
`personal computing device 111 could include a
`touchscreen, correct?
` A Yes, one of the items recited earlier in
`the paragraph is an optional touchscreen.
` Q Would you mind, sir, if we jump back up
`to the figures and let's go to Figure 5. Let me
`know when you're there.
` A I see Figure 5.
` Q Figure 5 depicts the portable computing
`device 111; that's similar to that shown in Figures
`3 and 1, correct?
` A Yes, there are definitely similarities
`between the depiction of Figure 5 and those of
`Figure 3 and Figure 1.
` Q So like Figures 3 and 1, Figure 5 shows
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
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`19
`
`portable computing device 111 including the user
`interface 103 that includes the input devices 105
`and display 101, correct?
` A I'm going back to the column 8
`description of Figure 1 where it does identify
`element 101 as a display, 103 as a user interface,
`and user input devices, e.g., buttons, as 105.
` Q In looking at Figure 5 again, sir,
`there's a -- one of the buttons that are included or
`one of the buttons in the portable computing device
`111 is labeled 502.
` Do you see that?
` A I do see a 502 on Figure 5.
` Q If we could turn back to the
`specification and column 17. Let's go to starting
`at line -- look at 65.
` And column 17, line 65, Rosenberg's
`describing Figure 5 and Rosenberg states, As shown,
`a reminder reset button 502 is included as part of
`the user input devices 105, correct?
` A It does state that, yes.
` Q And Rosenberg continues on line 66 and
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`20
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`into the next column, The reset button 502 may be
`engaged (e.g., pressed) by the user to select a
`reset reminder option, wherein the reset reminder
`option is adapted to reset a reminder.
` Correct?
` A It does state that, yes.
` Q So when a user presses the reset button
`502, you understand that that would engage the reset
`reminder option that is adapted to reset a reminder
`in the portable computing device, correct?
` MR. QUIGLEY: Objection, form.
` A I would agree that the embodiment being
`discussed here starting at the bottom of column 17
`with respect to Figure 5 includes a reset button
`that may be engaged or pressed by the user, which is
`used to select a reset reminder option, and this
`option is adapted to reset a reminder.
` That's the gist of the explanation at the
`bottom of column 17 going into the first couple
`lines of column 18.
` Q If you could please turn to column 19,
`specifically start at line 24.
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`Transcript of David Martin, Ph.D.
`Conducted on July 27, 2022
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`21
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` There, Rosenberg is explaining, referring
`back to Figure 5, that the, Embodiments exemplarily
`described herein provide additional reminder options
`(e.g., a terminate reminder option, a defer reminder
`option, a last chance reminder option, an edit
`reminder option, et cetera) that are selectable by
`the user upon the display of a triggered reminder.
` Correct?
` A I see that text, yes.
` Q And Rosenberg further explains with
`respect to Figure 5 that these, additional reminder
`options may be enabled through a variety of
`different user interface elements and/or controls.
` And Rosenberg states that in column 19,
`lines 29 through 31, correct?
` A It does include that sentence at that
`area.
` Q Looking down at line 34, as shown in
`Figure 5, Rosenberg is explaining in column 19,
`lines 34 to 35 -- I'm sorry, 33 to 34, An exemplary
`presentation of such information is shown enlarged
`at 501.
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`22
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` And that's labeled in Figure 5, correct?
` A I see that sentence, yes.
` Q And in Figure 5 you see the reference to
`501 in the figure of those four reminder options?
` A Figure 5 does include 501 enlarged, yes.
` Q And those reminder options as explained
`in column 19, starting at line 34 of Rosenberg, may
`include one or more of a terminate reminder option
`505, a defer reminder option 506, a last chance
`reminder option 507, and an edit reminder option
`508, and they may be selected upon the user's
`engagement with the user interface, correct?
` A That's what this passage states, yes.
` Q And in column 19, line -- starting on
`line 38 through 41, Rosenberg explains that, When
`selected by the user via the user interface 103,
`each of these reminder options causes the reminder
`circuitry supported by the portable computing device
`111 to take certain actions.
` Correct?
` A Yes, I see that passage.
` Q So if we look back at Figure 5,
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`Transcript of David Martin, Ph.D.
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`23
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`Rosenberg's portable computing device has a number
`of buttons which could be selected -- the reminder
`options could be selected from, to select that
`particular reminder option, whether it's 505, 506,
`507, or 508, correct?
` MR. QUIGLEY: Objection, form.
` A Well, as we discussed, there is this
`section of column 19 that discusses options 505,
`506, 507, 508 that may be selected upon the user's
`engagement with the user interface 103.
` Q Right. And the user interface 103
`includes those buttons 105 that you see in Figure 5.
` Do you understand that, Rosenberg to
`engage or select one of these reminder options,
`whether it's 505, 506, 507, or 508, would select one
`of these plurality of buttons that are in the 105,
`correct?
` MR. QUIGLEY: Objection, form.
` A I guess what -- I'm not sure I understand
`your association of the options 505 through 508 as
`shown within element 501 as -- how that relates to
`the element 105 that you're talking about.
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`24
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` Q Well, I think you even point this out in
`your declaration, how the -- and we just read from
`column 19, how Rosenberg is explaining that these
`reminder options are selectable by the user through
`the -- via the user interface 103, correct?
` A Having mentioned my declaration, I'm not
`sure what part you're referring to. Can you direct
`me to that?
` Q I will. Let me just go back to what we
`just -- I'll repeat what we just read.
` Column 19 around lines 33 to 41, again,
`Rosenberg is explaining that those reminder options,
`505, 506, 507, 508, may be selected upon the user's
`engagement with the user interface 103. And when
`selected by the user via the user interface 103,
`each of these reminder options causing the reminder
`circuitry supported by the portable computing device
`111 to take certain action.
` Correct?
` A Yes, that's what it says.
` Q So how would a user select one of those
`reminder options using user interface in the
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`25
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`portable computing device Figure 5?
` MR. QUIGLEY: Objection, form.
` A This passage in column 19, starting at
`line 24 and going through 41, essentially refers to
`the selection by the user without providing more
`detail on the specific mechanics required here.
` However, the diagram in Figure 5, I would
`say most readily brings to mind the impression of a
`touchscreen set of options, because if you look in
`Figure 5 at the items labeled 505, 506, 507, 508,
`they're circled as if they are buttons on the
`display.
` Q So in that understanding that you just
`described, the user could use display 101 as a
`touchscreen to select the portion of the display
`portion 501 to select either the terminate, defer,
`the last chance, or the edit reminder options by
`using their finger and selecting them, correct?
` A That is one thing that comes to mind. I
`think it comes to mind most naturally for me. There
`are other possibilities for a user selecting. But
`that's what I see first when I look at this.
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`26
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` Q And 103, you recall, includes both the
`display 101, which we just talked about, and one
`example could be a touchscreen, and also the buttons
`105, right?
` A While the scope of the brackets displayed
`in Figure 5 is a little unclear about user interface
`103, I think it is intended to include both the
`screen and the user input devices within the user
`interface as a whole.
` Q So if the personal -- or the portable
`computing device 111 didn't use a touchscreen, would
`the user use the buttons 105 to select any one of
`the reminder options 505, 506, 507, 508?
` MR. QUIGLEY: Objection, form.
` A I'm not sure I understood the question.
`Could you please repeat?
` Q If the use of a touchscreen -- we talked
`about this earlier -- was one of the options of the
`user input devices for the user interface, and if --
`where portable computing device 111 is not using a
`touchscreen, would a user use the buttons 105 to
`select one of the reminder options like you see here
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`27
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`in Figure 5, reminder option 505, 506, 507, or 508?
` MR. QUIGLEY: Same objection.
` A In a realization of Rosenberg that does
`not use a touchscreen for input of those options 505
`through 508, it certainly would be possible to use
`the other user input devices depicted in element 105
`to provide the mechanism for communicating back to
`the device.
` Q If you could turn, please, back to the
`specifications, sir, in column 21. Let me know when
`you're there. I'm looking at lines 28 through 30 in
`particular.
` A Yes, I see it.
` Q In lines 28 through 30 of column 21,
`Rosenberg's describing Figure 6, which is explained
`as, one embodiment of an exemplary process for
`facilitating execution of the reminder options
`selectable via the user interface shown in Figure 5.
` Correct?
` A That's what it says, yes.
` Q And in column 22, starting at line 14,
`it's describing this process in Figure 6, Rosenberg
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`28
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`explains that, The process then proceeds to 660
`where the user is given the opportunity to provide
`input through the user interface.
` Correct?
` A It does state that.
` Q And the opportunity to provide input
`through the user interface would be through the user
`interface 103 like we've seen in Figure 5, correct?
` A I would agree that the reference in this
`sentence to the user interface likely corresponds to
`element 103.
` Q By the way, on Figure 5, just to jump
`back up here, sir, where the user interface is using
`a touchscreen, and we were talking about how the
`user could select one of these options 505, 506,
`507, 508 on a touchscreen, what would happen in
`Rosenberg if the user selected the portion of the
`screen, let's say, in the area where it says
`"pickup" in the shopping list?
` MR. QUIGLEY: Objection to form.
` Q Would that engage any of the -- sorry.
` Would that -- would touching that portion
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`29
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`of the screen engage any of the reminder options
`505, 506, 507, or 508?
` MR. QUIGLEY: Same objection.
` A I'm not aware of Rosenberg having any
`teaching related to that specific scenario.
` Q Let's go back to specification again,
`sir. And column 12. And specifically, I'm going to
`start down at the bottom, in column 12, line 67.
`Let's start right at the bottom. We talked about
`this section earlier about how it's describing
`Figure 2.
` And in line 67 of column 12, Rosenberg
`continues and says that, The portable, and it
`extends to column 13, The portable computing device
`111 has a locative sensor within it (or connected to
`it) such that it can track its current location
`within the physical world with accuracy.
` Right?
` A Yes.
` Q And in column 13, lines 3 through 6,
`Rosenberg explains, In many embodiments, that
`locative sensor is a GPS transducer, and that the
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`30
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`GPS transducer determines spatial location by
`receiving data from a plurality of satellites 120
`orbiting the earth.
` Correct?
` A That's what it states, yes.
` Q Can we look at the bottom of column 13,
`starting on line 63. Rosenberg continues and says,
`To perform the reminder triggering functions
`described herein, the portable computing device 111
`contains within it and/or is connected to one or
`more locative sensors.
` Correct?
` A I see that.
` Q And so the portable computing device 111
`can include more than one locative sensor, right?
` MR. QUIGLEY: Ob
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