throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
` _________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` __________________
`
` CSC SERVICEWORKS, INC.,
` Petitioner,
`
` v.
`
` PAYRANGE, INC.,
` Patent Owner.
` __________________
` IPR2023-01186
` U.S. Patent No. 8,856,045
`
` Tuesday, March 26, 2024
`
` Remote Zoom Deposition of CLIFFORD
`
` B. NEUMAN, PH.D., taken with the witness
`
` participating from his residence in Los Angeles,
`
` California, beginning at 9:07 a.m., PT, before
`
` Ryan K. Black, Registered Professional Reporter,
`
` Certified Livenote Reporter and Notary Public in
`
` and for the Commonwealth of Pennsylvania.
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`PayRange EXHIBIT - 2017
`CSC ServiceWorks, Inc. v. PayRange, Inc. - IPR2023-01186
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`Page 2
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` A P P E A R A N C E S:
`
` SHOOK HARDY & BACON LLP
` BY: JASON R. MUDD, ESQ. - Via Zoom
` 2555 Grand Blvd.
` Kansas City, Missouri 64108
` 816.474.6550
` jmudd@shb.com
` SHOOK HARDY & BACON LLP
` BY: EMMA MURRAY, ESQ. - Via Zoom
` 111 S. Wacker Dr., Suite 4700
` Chicago, Illinois 60606
` 312.704.7700
` aemurray@shb.com
`
` Representing - Petitioner
`
` WILSON SONSINI GOODRICH ROSATI LLP
` BY: MATTHEW A. ARGENTI, ESQ. - Via Zoom
` 650 Page Mill Road
` Palo Alto, California 94304
` 650.493.9300
` margenti@wsgr.com
` WILSON SONSINI GOODRICH ROSATI LLP
` BY: GARRETT POTTER, ESQ., PH.D. - Via Zoom
` 701 5th Ave. Suite 5100
` Seattle, Washington 98104
` 206.883.2562
` gpotter@wsgr.com
`
` WILSON SONSINI GOODRICH ROSATI LLP
` BY: WES DERRYBERRY, ESQ. - Via Zoom
` 1700 K Street NW
` Fifth Floor
` Washington, DC 20006
` 202.973.8800
` wderryberry@wsgr.com
`
` Representing - Patent Owner
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`Page 3
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` I N D E X
`
` TESTIMONY OF: CLIFFORD B. NEUMAN, PH.D. PAGE
`
` By Mr. Argenti..................................4
`
` E X H I B I T S
`
` EXHIBIT DESCRIPTION PAGE
`
` Exhibit 1001 United States Patent No.
`
` 8,856,045......................29
`
` Exhibit 1003 the Declaration of Dr. Clifford
`
` B. Neuman in the IPR2023-01186
`
` case...........................11
`
` Exhibit 1004 United States Patent No.
`
` 10,210,501.....................58
`
` Exhibit 1005 United States Patent Application
`
` Publication Number US
`
` 2009/0106160..................135
`
` Exhibit 1006 United States Patent Number
`
` 8,958,846.....................163
`
` Exhibit 1007 United States Patent Number
`
` 7,455,223.....................199
`
` Exhibit 1008 a printout of NAMA Multi-Drop
`
` Bus/Internal Communication
`
` Protocol......................200
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` CLIFFORD B. NEUMAN, PH.D.,
`
` called to testify, having been first duly sworn
`
` or affirmed, was examined and testified as
`
`Page 4
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` follows:
`
` EXAMINATION
`
` BY MR. ARGENTI:
`
` Q. Good morning, Dr. Neuman. As I
`
` mentioned before we got going, my name is
`
` Matt Argenti. I'm from the Law Firm of Wilson
`
` Sonsini, and I represent the patent owner
`
` PayRange in this case.
`
` Could you please state your name for the
`
` record?
`
` A. Yes. My name is Clifford Neuman.
`
` Q. Where are you currently located,
`
` Dr. Neuman?
`
` A. I'm currently located in Los Angeles,
`
` California.
`
` Q. Is there anyone else in the room with
`
` you today?
`
` A. No, there is not.
`
` Q. And it's my understanding that you have
`
` copies of your declarations and the exhibits that
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` it cites available to you today; is that correct?
`
` A. I have copies of various exhibits. I
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` don't know if you were planning on introducing
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` some that I might not have, but . . .
`
` Q. But at least as far as the exhibits
`
` in your declaration, hopefully you have copies.
`
` Hopefully that's included in what you have
`
` available to you. If I start referring to any
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` exhibit that you don't have available to you,
`
` please let me know. Okay?
`
` A. Okay. I'm sorry. Your audio just
`
` dropped a little bit.
`
` Q. I was -- I said if I refer to any
`
` exhibit that you do not have available to you
`
` today, please let me know. Okay?
`
` A. I will let you know if I do not have one
`
` available.
`
` Q. And the copies of your declaration
`
` and the exhibits that you have available to you
`
` today, are those electronic copies or hard
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` copies?
`
` A. Those are primarily electronic copies.
`
` I did print out at least two pages of the table
`
` of contents from my declaration just to avoid
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` scrolling as we go through things.
`
` Q. Other than those two pages of the table
`
` of contents, do you have any other hard copy
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` documents, like notes, with you today?
`
` A. Other than a blank notepad where I'm
`
` just noting start times and end times, I do not
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` -- well, I do not have immediately in this area
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` of the desk. Obviously, in my office I've got
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` -- you can see my whole book case behind me,
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` but . . .
`
` Q. Understood. If at any point you refer
`
` to any notes, please let me know. Okay?
`
` A. I will let you know if I refer to any
`
` notes.
`
` Q. Okay. This is not your first
`
` deposition, correct, Dr. Neuman?
`
` A. No, it is not. I have been deposed many
`
` times.
`
` Q. About how many times have you been
`
` deposed?
`
` A. Probably on the order of 20 or 30.
`
` But, you know, it could be even higher than that.
`
` They blend together sometimes over the years.
`
` Q. Over the years.
`
` Were any of those in the last year or
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` so?
`
` A. In the last year or so, I believe that
`
` -- I believe I had a couple of depositions last
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`Page 7
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` summer. So, yes, some of those -- maybe two or
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` three -- would have been within the past year.
`
` Q. Got it.
`
` So I'm sure you're familiar with how
`
` things work in a deposition, but I'm going to go
`
` through some of the ground rules just so we cover
`
` them for this one. Do you understand you're
`
` providing your testimony under oath and you're
`
` expected to tell the truth?
`
` A. I understand that.
`
` Q. Is there any reason that you cannot
`
` provide complete and accurate testimony today?
`
` A. There is no reason.
`
` Q. Hopefully my questions today will be
`
` clear. But if you do not understand any of my
`
` questions, you have to let me know that it's not
`
` clear. Okay?
`
` A. I will let you know if I do not
`
` understand one of your questions.
`
` Q. If you don't tell me otherwise, I'm
`
` going to assume that you understand the question.
`
` Okay?
`
` A. I would expect you would, yes.
`
` Q. Please provide verbal answers, rather
`
` than nodding your head, for the benefit of the
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` record and the court reporter. Okay?
`
` A. I will do that.
`
` Q. And we can take a break at any time
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` that you would like one as long as there is not
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` a question pending. If there is a question
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` pending, you must answer the question before we
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` take a break. Do you understand?
`
` A. I understand that.
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` Q. And we'll probably take a break every
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` hour or so, is my plan. But if you need one
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` before I throw the possibility of a break out
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` there, just let me know.
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` A. I will.
`
` Q. Are you being compensated for your
`
` testimony in this proceeding?
`
` A. I am.
`
` Q. What is your hourly rate?
`
` A. Were you asking what my hourly rate was?
`
` Q. Yes.
`
` A. My hourly rate in these proceedings, I
`
` believe, is $750 per hour.
`
` Q. Who is providing your compensation?
`
` A. The compensation is provided to me
`
` through the law firm that I'm working with. I do
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` not know for certain how those funds are provided
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` to the law firm.
`
` Q. And is all of your compensation in this
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` matter being paid at that $750 hourly rate?
`
` A. All of my compensation in this
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` particular matter is at that particular rate.
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` Q. How much have you billed the law firm to
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` date for your work in this matter?
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` A. For my work in this matter, I believe
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` that the total is on the order of about $17,000.
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` That includes, by the way, not just the
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` deposition, but the drafting of the reports and
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` the preliminary discussions and everything that
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` went on.
`
` Q. You mentioned that you've been deposed
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` quite a number of times. Were those all in the
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` context of patent litigation and you working as
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` an expert witness?
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` A. Most of my depositions is in patent
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` matters.
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` There was one case that was a contract
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` dispute on technical issues. And then a long,
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` long time ago there was one instance where I was
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` a witness to a vehicle accident.
`
` Q. In those depositions -- or, sorry, just
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` -- strike that.
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` In the cases where you served as an
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` expert in patent matters, were they primarily on
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` behalf of a party accused of infringement?
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` A. In most of the matters where I consulted
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` on patent matters, it has been in support of the
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` party that was accused of infringing. There is
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` one matter that was otherwise.
`
` Q. You understand that you're here today
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` with regard to an IPR proceeding, right?
`
` A. I am aware that I am here with respect
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` to an IPR proceeding.
`
` Q. And that IPR proceeding is
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` IPR2023-01186, right?
`
` A. Well, I'd need to look at the cover of
`
` the document to -- if you want me to, I will, --
`
` Q. Sure.
`
` A. -- but I don't memorize the numbers.
`
` Q. I was just about there anyway. Why
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` don't you pull out your declaration for this
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` case, please.
`
` A. Okay. Let's see.
`
` Okay. So I'm pulling up my declaration,
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` which I believe is Exhibit 1003 of this matter.
`
` Q. That sounds correct to me.
`
` A. And if you read back to me that IPR
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` number, I will confirm if that's what's on this
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` document.
`
` (Exhibit No. 1003, the Declaration of
`
` Dr. Clifford B. Neuman in the IPR2023-01186 case,
`
` was introduced electronically.)
`
` BY MR. ARGENTI:
`
` Q. So the IPR that you are here to testify
`
` about today is IPR2023-01186, correct?
`
` A. That is correct.
`
` Q. And that's related to U.S. Patent Number
`
` 8,856,045; is that right?
`
` A. That is correct.
`
` Q. If I refer to that as the '045 patent
`
` today, will you understand that's what I'm
`
` talking about?
`
` A. I will understand. That's how I've been
`
` referring to it for quite some time.
`
` Q. Great.
`
` Can you turn to Page 104 of your
`
` declaration, please? That's the last page.
`
` A. Okay. Okay.
`
` Q. Is that your signature on this page?
`
` A. That is my signature on this page.
`
` Q. How is it entered into this declaration?
`
` A. Once I had the final version of the
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` declaration, I printed the final page. Then I
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` signed the paper copy; I scanned the paper copy
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` of that page and sent it back to the attorneys.
`
` Q. Got it.
`
` Prior to signing your declaration, did
`
` you carefully review it to ensure its accuracy?
`
` A. I did carefully review it to ensure its
`
` accuracy prior to signing the declaration.
`
` Q. Sitting here today, do you believe the
`
` declaration's accurate?
`
` A. I believe this declaration is accurate.
`
` Q. So there's nothing about the declaration
`
` that you'd like to modify or correct before we
`
` get started on questioning?
`
` A. There is nothing within the declaration
`
` that I have observed that I feel needs to be
`
` changed.
`
` Q. About how many hours did you spend
`
` preparing this declaration?
`
` A. In the preparation for the declaration,
`
` I spent on the order of about 23 or 24 hours.
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` But when I say "in preparation for the
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` declaration," this involved a lot of discussion
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` back and forth even during the time when the
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` attorneys were working on their petitions.
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` So not all of that time was specifically
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` on the document of the declaration, but all of
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` that time was informing the opinions that
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` ultimately went into that declaration.
`
` Q. Did you do anything to prepare for this
`
` deposition?
`
` A. Yes, I did.
`
` Q. What did you do?
`
` A. I reviewed quite a number of documents
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` in the case; certainly my declaration. I
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` reviewed the petition. I reviewed your parties'
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` POPR, I think it's called. I reviewed the
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` institution decision. And I went back in my
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` review of my report and did additional review of
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` some of the source documents, the documents on
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` which my --
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` THE REPORTER: I'm sorry. You broke up
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` there. The documents on which you what?
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` THE WITNESS: On which my opinions were
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` formed, --
`
` THE REPORTER: Thank you.
`
` THE WITNESS: -- the exhibits.
`
` BY MR. ARGENTI:
`
` Q. Okay. Did you meet with anyone to
`
` prepare for your deposition?
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` A. Yes, I did.
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` Q. Who did you meet with?
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` A. Primarily with Jason Mudd. And Emma
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` Murray was on some of those discussions. And
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` there was one other attorney from their firm
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` which popped in on some of the discussions.
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` Q. About how many discussions were there?
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` A. I believe -- the discussions that
`
` we're talking about now in preparation for the
`
` deposition? I believe that I had two Zoom calls.
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` There may have been three, but I believe it was
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` two.
`
` Q. And when did those Zoom calls take
`
` place?
`
` A. One of those occurred yesterday. The
`
` other about maybe a week-and-a-half ago, I think,
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` thereabouts.
`
` Q. Dr. Neuman, as I ask the questions,
`
` I'm noticing that there's some lag and there have
`
` been times when you've frozen up. So I just want
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` to make sure you're responding -- it does sound
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` like you're responding to the questions I ask, so
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` I think I'm coming through clearly. And as long
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` as it works for the court reporter, I think we
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` can proceed with this.
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`Page 15
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` I just want to make sure that my
`
` questions are coming through clearly to you.
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` Is there any issue on your end?
`
` A. There's a little bit of stutter
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` that's there, but they're understandable. And if
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` there's any question where it's breaking up or I
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` can't understand, I will pause and ask you to say
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` it again.
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` Q. Okay. Thanks.
`
` You have a bachelor's, a master's and a
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` doctorate degree in computer science, right?
`
` A. Yes. I have those three degrees in
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` computer science, or computer science and
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` engineering.
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` Q. And you received your Ph.D in 1992 from
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` the University of Washington. Do I have that
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` right?
`
` A. That is correct.
`
` Q. So if we turn to Paragraph 9 of your
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` declaration -- that's on Page 6 --
`
` A. I have Paragraph 9 in front of me.
`
` Q. -- you say that you've devoted your
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` career to the field of distributed computer
`
` systems development and research, right?
`
` A. That is correct.
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`Page 16
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` Q. What does that term mean, "distributed
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` computer systems"?
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` A. Distributed computer systems are
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` computers working together to complete an
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` operation. So you're going to have multiple
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` computers that are working one way or another.
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` And, in fact, if you look today -- I
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` mean, you look recently, probably most of the
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` computers that we use would be described as
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` distributed computer systems. So, for example,
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` if you're going to the web, you've got your local
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` either desktop PC or laptop. That is one
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` component in a system. You've got the web server
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` on another component of the system. So that
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` would be a distributed computer system.
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` If you go back to, maybe, the, you know,
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` 1980s, maybe, when I started to use the first
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` computers when I went to the Radio Shack store
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` and played around with their TRS-80s, that was
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` not a distributed computer. Everything that was
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` being done was on that one particular device.
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` So that's what is meant by distributed
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` computer systems.
`
` Q. Could you turn to the next couple of
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` pages, Pages 8 and 9 of your declaration where
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`Page 17
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` you address the level of ordinary skill in the
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` art. Do you see that section?
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` A. I'm at that section now. Paragraph 18.
`
` Q. And in Paragraph 19 you say in the
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` second sentence there that, "A POSITA would have
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` had approximately three years of experience with
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` electronic payment systems, vending machine
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` technologies or distributed network systems."
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` Do you see that?
`
` A. I do see that.
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` Q. When you refer to "distributed network
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` systems" there, is that the same thing as
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` distributed computer systems?
`
` A. Well, distributed computing systems
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` do utilize networks. So in some sense I'd say
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` they're pretty closely aligned.
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` Technically, if you look at the -- sort
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` of, the fields of distributed computing systems,
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` you're looking more at the distribution of the
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` functions across the computers, where, when you
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` look at networking systems, you're looking maybe
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` a little bit more at the communications between
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` the components.
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` But the two fields are very closely
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` related. And you could say that most individuals
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`Page 18
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` that had experience in distributed network
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` systems -- is that the line which -- distributed
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` network systems would also have that familiarity
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` in the endpoints; that is, the dist --
`
` (Whereupon witness's Zoom feed froze.)
`
` THE REPORTER: Did he freeze for you
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` guys?
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` MR. ARGENTI: Yes.
`
` MR. MUDD: Yes.
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` THE WITNESS: Okay. You just froze.
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` MR. ARGENTI: And you were -- I think we
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` lost the end of your answer.
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` Maybe, Mr. Black, if you could read back
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` how far you heard.
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` (Referred-to testimony read back.)
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` THE WITNESS: Okay. So that was
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` endpoints which constitute distributed computer
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` systems.
`
` BY MR. ARGENTI:
`
` Q. So it sounds like they are very closely
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` related. How much of your experience with
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` distributed computer systems has involved
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` distributed network systems?
`
` A. Well, the division at the Information
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` Sciences Institute, where for a while I was the
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`Page 19
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` associate division director, was the computer
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` networks division.
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` So, certainly, almost all of my work in
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` distributed computer systems has used networks.
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` And, you know, a lot of the papers or standards
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` that I've been involved with have been in what's
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` called the Internet Engineering Task Force.
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` And the Internet Engineering Task Force is
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` technically, sort of, computer networking.
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` Although because of the closely-related aspects,
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` you tend to move into distributed computer
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` systems, as well.
`
` Q. Is the Internet an example of a
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` distributed network system?
`
` A. The Internet is clearly an example of a
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` distributed network.
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` And you just froze a moment ago, so you
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` might have said something that I didn't hear.
`
` Q. I did not. I was waiting to hear the
`
` end of your answer there.
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` MR. ARGENTI: Why don't we go off the
`
` record for a second?
`
` (Brief pause in proceedings.)
`
` BY MR. ARGENTI:
`
` Q. Dr. Neuman, thank you. I appreciate
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`Page 20
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` you adjusting your position in your office so
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` that hopefully we can resolve some of these
`
` connectivity issues that we've had, so we'll go
`
` forward. And if it looks like we're still having
`
` issues, we can maybe figure out another solution,
`
` but hopefully this works.
`
` So my next question was going to be is a
`
` client server arrangement a distributed network
`
` system?
`
` A. So a client server arrangement is
`
` clearly a distributed computer system.
`
` I do need to adjust one more thing to
`
` get my second screen working again.
`
` (Brief pause in proceedings.)
`
` BY MR. ARGENTI:
`
` Q. Okay. So when you say that "a client
`
` server arrangement is clearly a distributed
`
` computer system," is it also a distributed
`
` network system?
`
` (Whereupon witness's Zoom feed froze.)
`
` A. By the way, did we just lose --
`
` Q. Yeah. We did not get your answer to
`
` that question.
`
` A. So a distributed -- so a client server
`
` relationship describes the --
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`
`

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`Page 21
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` (Whereupon witness's Zoom feed froze.)
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` Q. Dr. Neuman, I think we probably need --
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` A. -- all of the in between; client and a
`
` server. That is a network, so it's a --
`
` (Whereupon witness's Zoom feed froze.)
`
` MR. ARGENTI: I don't want to cut off
`
` his answer, but I think we probably need to get a
`
` better resolution to the connection issue here.
`
` So we can go off the record?
`
` (Brief pause in proceedings.)
`
` (Discussion off record.)
`
` BY MR. ARGENTI:
`
` Q. All right. So if we're back on
`
` the record, I'm just going to reask the last
`
` question, Dr. Neuman, because I don't think we
`
` were able to capture your answer. And the
`
` question was, is a client server arrangement a
`
` distributed network system?
`
` A. So a relationship between a client
`
` server -- what we refer to as a client server
`
` model encompasses two components: Really, the
`
` distributed system; one client talking to a
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` server. And that communication is occurring over
`
` a network. And in most cases over the Internet,
`
` that's going to be a distributed network.
`
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`

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` Q. So it sounds like distributed network
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` systems is a very broad term. Would you agree?
`
` A. I would agree that distributed network
`
` systems is a broad term.
`
` Q. Are all distributed network systems used
`
` for electronic commerce?
`
` A. Are all distributed network systems used
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` for electronic commerce? Was that your question.
`
` Q. Right.
`
` A. Certainly not. I mean, some are.
`
` But distributed network systems are used for a
`
` lot of things: For scientific research. For
`
` just browsing the web. So certainly it's not
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` only used for electronic commerce.
`
` Q. And so it's also true, I would gather,
`
` that all distributed network systems do not
`
` necessarily involve vending machine technologies;
`
` is that right?
`
` A. Certainly there are distributed network
`
` systems that do not involve vending machines.
`
` Q. Okay. If we turn back to Paragraph 9
`
` of your declaration on Page 6, you go on to say
`
` in that paragraph that a significant portion
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` of your experience has been in the area of
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` electronic commerce and Internet payments.
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` Do you see that?
`
` A. I do see that. Yes.
`
` Q. And I think some examples of that are
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` mentioned in Paragraph 13; for example, where
`
` you mentioned NetCheque, all one word,
`
` N-e-t-C-h-e-q-u-e. Do you see that?
`
` A. I do see that.
`
` Q. What is NetCheque?
`
` A. NetCheque was a very early electronic
`
` payment system that provided a method to exchange
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` funds over the Internet between clients and,
`
` well, servers, in essence, using
`
` infrastructure --
`
` (Whereupon witness's Zoom feed froze.)
`
` THE WITNESS: -- that we had
`
` developed.
`
` BY MR. ARGENTI:
`
` Q. Was --
`
` A. Did you hear that?
`
` Q. I think we did capture it, yes. There
`
` was a -- there was a brief lag, but I think we
`
` got the end of your answer. Looks like it was
`
` captured, as well. It was "a method to exchange
`
` funds over the Internet between clients and,
`
` well, servers, in essence, using infrastructure
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`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
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`

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` that we had developed." Was that your whole
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` answer?
`
` A. That was my whole answer.
`
` Q. Was NetCheque ever on the market?
`
` A. NetCheque was not used in actual
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` commerce. It was a research prototype that we
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` had developed.
`
`

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