UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________
`SAMSUNG ELECTRONICS CO., LTD,
`Petitioner ,
`v.
`BROADPHONE LLC,
`Patent Owner.
`__________________________
`Case IPR2024-00153, IPR2024-00154, IPR2024-00155
`U.S. Patent No. 8,170,583; 8,594,698; 10,341,811
`__________________________
`
`Deposition of TODOR V. COOKLEV, PH.D.
`Conducted Virtually
`Tuesday, October 22, 2024
`11:03 a.m. EDT
`
`Job No.: 556957
`Pages: 1 - 155
`Stenographically reported by: Judith E. Bellinger,
`RPR, CRR, CSR-TX CCR-WA, CCR-NM
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`SAMSUNG EXHIBIT 1079
`Samsung Electronics Co., Ltd. v. Broadphone LLC
`IPR2024-00155
`
`Page 1 of 189
`
`
`__________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________
`SAMSUNG ELECTRONICS CO., LTD,
`Petitioner ,
`v.
`BROADPHONE LLC,
`Patent Owner.
`__________________________
`Case IPR2024-00153, IPR2024-00154, IPR2024-00155
`U.S. Patent No. 8,170,583; 8,594,698; 10,341,811
`__________________________
`
`Deposition of TODOR V. COOKLEV, PH.D.
`Conducted Virtually
`Tuesday, October 22, 2024
`11:03 a.m. EDT
`
`Job No.: 556957
`Pages: 1 - 155
`Stenographically reported by: Judith E. Bellinger,
`RPR, CRR, CSR-TX CCR-WA, CCR-NM
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`Samsung Electronics Co., Ltd. v. Broadphone LLC
`IPR2024-00155
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on October 22, 2024
`
`2
`
` Deposition of TODOR V. COOKLEV, PH.D., conducted
`virtually.
`
` Pursuant to notice, before Judith E.
`Bellinger, Registered Professional Reporter,
`Certified Realtime Reporter, and Notary Public in
`and for the State of Maryland.
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on October 22, 2024
`
`3
`
` A P P E A R A N C E S
`
`ON BEHALF OF THE PETITIONER:
` DANIEL ZEILBERGER, ESQUIRE
` JASON MIKUS, ESQUIRE
` PAUL HASTINGS LLP
` 2050 M Street NW
` Washington, DC 20036
` 202.551.1700
`
`ON BEHALF OF THE RESPONDENT:
` CHRISTIAN W. CONKLE, ESQUIRE
` RUSS AUGUST & KABAT
` 12424 Wilshire Boulevard
` 12th Floor
` Los Angeles, CA 90025
` 310.826.7474
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on October 22, 2024
`
`4
`
` C O N T E N T S
`EXAMINATION OF TODOR V. COOKLEV, PH.D. PAGE
` By Mr. Zeilberger 5
` By Mr. Conkle 127
` By Mr. Zeilberger 130
`
` E X H I B I T S
`
`Previously Marked:
`Exhibit:
`Exhibit 1001 United States Patent Number 32
` 8,170,583 B2
`Exhibit 1006 United States Patent Number 75
` 8,477,731 B2
`Exhibit 1011 United States Patent Number 72
` 6,944,465 B2
`Exhibit 2003 Declaration of Todor V. Cooklev, 14
` Ph.D.
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on October 22, 2024
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`5
`
` P R O C E E D I N G S
`
` TODOR V. COOKLEV, PH.D.,
` Being first duly sworn, was examined
`and testified as follows:
` EXAMINATION BY COUNSEL FOR THE PETITIONER
`BY MR. ZEILBERGER:
` Q Good morning, Dr. Cooklev.
` A Good morning.
` Q Could you, please, state your full name
`for the record.
` A My name is Todor Cooklev.
` Q Have you been deposed before?
` A Yes, I have.
` Q How many times?
` A I've been deposed more than 40 times.
` Q Okay. So, you are probably familiar
`with the ground rules and, so, I'll just remind
`you of them.
` You understand today that there is a
`court reporter who is transcribing the words that
`we say?
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on October 22, 2024
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`6
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` A Yes, I understand that.
` Q And given that the court reporter can
`only transcribe one person at a time, I would
`appreciate it if you wait for me to finish my
`questions before speaking, and I will do the same
`for you.
` Is that okay?
` A Yes.
` Q And if at any point today you don't
`understand a question that I ask, please, let me
`know; otherwise, I'll assume you understood the
`question.
` Is that fair?
` A Yes.
` Q Do you understand that you're under
`oath today?
` A I do.
` Q Is there any reason you cannot testify
`completely, truthfully, and accurately today?
` A I'm not aware of a reason.
` Q Who first contacted you about this
`case?
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on October 22, 2024
`
`7
`
` MR. CONKLE: You can answer.
` A To the extent that I recall, it was
`probably counsel for Broadphone.
` Q And when you say "counsel for
`Broadphone," are you referring to an attorney from
`Russ, August & Kabat?
` A Yes.
` Q When were you retained for these
`proceedings?
` A I do not remember, Counsel. It was at
`least sometime before I submitted the
`declarations.
` Q Was it after the IPR petitions were
`filed?
` A I do not recall that detail.
` Q What is your hourly rate for these
`proceedings?
` A And just for the record, I'm looking at
`my declaration.
` My declaration, paragraph 2, states
`that I'm compensated, my standard hourly rate. I
`think it is 700.
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on October 22, 2024
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`8
`
` Q And just to orient me, what materials
`do you have in front of you today?
` A Yes, Counsel, thank you for the
`question.
` I received instructions from counsel
`for Broadphone and the counsel defending me today,
`I received instructions to have some documents
`printed, which I did.
` So, at the moment, around me, I have, I
`believe, everything that I was asked to print,
`that it might facilitate the deposition today.
` Just generally, here in the office and
`on my desk, there are some -- there are a few
`things that you would find in an office, but they
`have no relation to the case. That's what I have.
` So, the only thing that is relevant to
`the IPR, or the three IPRs, the only thing is the
`three patents that have been challenged, the prior
`art, and my three declarations.
` Q Understood.
` So you have six documents with you
`today; is that right?
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`Conducted on October 22, 2024
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`9
`
` A Six -- I think there are a little bit
`more than six. I can count.
` Q I apologize, that's my mistake. I
`hadn't heard that you also had referenced the
`prior art, which would be the additional
`documents. Okay.
` A Yes.
` Q Do you have -- well, I guess, let me
`take a step back.
` Could you, please, list out what
`documents you are referring to when you are
`referring to the prior art, which documents do you
`have with you today?
` A Yes, certainly.
` So, I have, and let me put this on the
`side, this is one of the patents.
` So I do have the Blomqvist, Houri,
`Damarla patents.
` I have Spain, the Spain reference,
`Nanda, Hunzinger.
` And I think this is it.
` I mean, if I've missed something, maybe
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on October 22, 2024
`
`10
`
`I can get it electronically, but I don't think I
`have.
` Q Do you have any means of communication
`open today, besides this Zoom connection?
` A No. And I'm actually closing my email
`window, which I had open just for the link, for
`the deposition link. But that's closed.
` So no means for communication in the
`office where I am.
` Q Do you understand you're here today
`regarding three proceedings that you submitted
`declarations in, IPR 2024-00153, 00154, and 00155?
` A Yes. Yes.
` Q Would it be fair to say that your
`opinions regarding any particular reference that
`is common among the proceedings would be the same
`for each proceeding?
` A Well, I think we have to be careful
`about this. And so, I'm not sure that one answer
`would apply. That some things could be common,
`but some things could be different. And since
`today is -- we're talking about three IPRs, I will
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`Conducted on October 22, 2024
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`11
`
`try to be clarifying in the context of which IPR
`is my answer. And if I don't understand in the
`context of which IPR is the question, I hope that
`I can ask for you, Counsel, to clarify.
` Q Are you saying that there are some
`references that you have interpreted one way for
`one proceeding and a different way for a different
`one of these proceedings?
` A I don't think that's quite what I am
`saying.
` I don't think I can just agree that I
`am interpreting a reference one way or a different
`way.
` First, my declarations are in response
`to the declaration submitted by Dr. Kevin
`Almeroth. And so, that is what I am responding
`to, and these are -- and those were the arguments
`that I considered. And so, I will leave it at
`that.
` Q Did you spend any time preparing for
`today's deposition?
` A Yes, I have.
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`Conducted on October 22, 2024
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`12
`
` Q How much time?
` A I think on the order of a couple of
`days.
` Q When you say "on the order of a couple
`of days" was that a couple of full days or a
`couple of hours for a couple of days?
` A No, I meant, generally, what would be
`considered around two full days.
` Q What did you do to prepare for today's
`deposition?
` MR. CONKLE: Caution the witness not to
`reveal the substance of attorney-client
`communications or work product.
` But you can answer -- if you can answer
`generally, without getting into that, you may.
` A Oh, I reviewed the patents; I certainly
`reviewed my three declarations; I had some
`discussions with counsel.
` Generally, that's about what I did.
` Q When you say "generally," that's about
`what you did, is there anything else you did to
`prepare for the deposition today?
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`Conducted on October 22, 2024
`
`13
`
` A Well, I also reviewed the -- I reviewed
`the prior art references.
` Now, the difference -- at the different
`level of detail, I reviewed them. But I took a
`look, also, at the prior art references.
` Q Anything else?
` A I don't recall anything else.
` Q You mentioned having spoken to people
`to prepare for today's deposition. I do not want
`to know the substance of any communications you
`had, but can you, please, identify who you spoke
`to, to prepare for today's deposition?
` A I spoke to counsel for Broadphone
`that's defending me today. And I also spoke with
`another lawyer from the same law firm. I spoke
`briefly.
` Q Did you speak to anybody that is not
`from Russ, August & Kabat, in preparation for
`today's deposition?
` A No, I did not.
` Q Did you review any materials that are
`not presently of record in these IPR proceedings
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on October 22, 2024
`
`14
`
`to prepare for today's deposition?
` MR. CONKLE: Just an objection.
`Privileged and work product.
` But, Dr. Cooklev, if you can answer
`without getting into materials prepared by or for
`attorneys, or other privileged material, feel free
`to do so.
` A I don't think I did. I don't recall at
`the moment.
` Q Can you, please, pull out Exhibit 2003
`from the 00153 proceeding, which is your
`declaration directed to the '583 patent.
` (Exhibit 2003 previously marked for
`identification and attached to the transcript.)
` A I'm looking at it.
` Q If I refer to this today as your '583
`patent declaration or 153 proceeding declaration,
`will you understand what I'm referring to?
` A Yes.
` Q And if you turn to page 15, the last
`page of this declaration, is that your signature
`provided?
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`Conducted on October 22, 2024
`
`15
`
` A Yes. That's correct.
` Q Did you prepare this declaration?
` A Well, if you mean whether I wrote it
`from start to finish without any help from
`counsel, no.
` Counsel did help properly format my
`opinions. And together, with that, maybe some
`general tutorial editing.
` The opinions, though, were my opinions.
` Q And is it fair to say that you reviewed
`and signed off on the final version of this
`declaration that was submitted to the patent
`office?
` A Yes.
` Q If you can, please, pull out your
`declaration Exhibit 2003 in the '154 proceeding,
`which is directed to the '698 patent.
` A I'm looking at it.
` Q And, similarly, if I refer to this
`declaration as your '698 patent declaration or the
`'154 proceeding declaration, will you understand
`what I'm referring to?
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`16
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` A Yes.
` Q And if you turn to the last page, is
`that, similarly, your signature?
` A Yes. That's correct.
` Q And would the answers you provided as
`to the 153 proceeding declaration, in terms of
`your process for preparing the declaration, also
`apply to this '154 proceeding declaration?
` A Yes.
` Q If you can, please, open up your third
`declaration, Exhibit 2003, in the 155 proceeding.
` A Yes. I'm looking at it.
` Q And if I refer to this declaration as
`the 155 proceeding declaration, or the '811 patent
`declaration, will you understand what I'm
`referring to?
` A Yes.
` Q And if you turn to the last page of
`this declaration, is that your signature?
` A Yes.
` Q And, similarly, to the previous
`declaration, would the answers you provided
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`Conducted on October 22, 2024
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`17
`
`regarding the process of preparing the declaration
`for the 153 proceeding declaration also apply to
`your process for the 155 proceeding declaration?
` A Yes.
` Q Just to orient us on one particular
`declaration, if you pull back up the
`153 proceeding declaration --
` A Yes.
` Q -- Exhibit 2003.
` And let us know when you have it.
` A I have it here.
` Q And can you, please, turn to paragraph
`18.
` A I'm looking at it.
` Q You indicate, in paragraph 18, that you
`have reviewed materials, and then you provide a
`list of several materials -- several specific
`documents, correct?
` A Yes, this is the section "Materials
`Considered."
` Q And you have a similar section in your
`other two declarations, correct?
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`Conducted on October 22, 2024
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`18
`
` A Yes.
` Q Did you review any documents, besides
`those listed in your materials considered section,
`to prepare your declaration for these IPRs?
` A Well, I know that there is a list here
`in paragraph 18, the last item says "other
`documents cited herein."
` So, even if I've missed something on
`this list, I think the declaration is correct.
`But I do not recall -- I do not recall the
`reviewing any other document in preparation for
`these declarations.
` Q How much time did you spend preparing
`your declarations for these IPRs?
` A I don't remember, but I didn't spend
`that much time, which, when you look at the
`declarations, they are not that long, which is
`basically what I was asked to do for these
`declarations.
` So, I don't remember exactly how much
`time, but I don't think it was a lot.
` Q Was it more than a day?
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`Conducted on October 22, 2024
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`19
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` A Perhaps it was.
` Q What do you mean when you say "perhaps
`it was"?
` A I mean that I don't exactly remember,
`but maybe it was more than a day. If you mean for
`all three declarations.
` Q Let's say for each particular
`declaration.
` A Well, there's quite a bit of overlap,
`and I don't think the priorities, to begins with,
`there are any differences. So it's a little
`difficult to separate the time spent for one IPR
`from the time spent in connection with another
`one.
` Q Would it be fair -- oh, I'm sorry. Go
`on.
` A No, that was my answer, basically.
` Q So would it be fair to say that for all
`three proceedings, you collectively spent,
`approximately, one day of time for the
`declarations?
` A Well, I think I said perhaps more than
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`Conducted on October 22, 2024
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`20
`
`a day. I didn't say approximately a day.
` Again, I don't exactly remember. I
`would say it was more than a day.
` Q Was it more than two days?
` A And now we are getting close to a point
`where I just have to guess. Even if it were more
`than two days, not much more, I think, again, to
`the best of my recollection right now.
` Q In the qualification section of each of
`your declarations, you indicate that you were a
`professor at Purdue University, Fort Wayne,
`correct?
` A Yes.
` Q Is that a position that you still hold
`today?
` A Yes.
` Q In paragraph 5 of each of your
`declarations, you said you obtained a Ph.D. in
`electrical engineering, correct?
` A Yes.
` Q Did your undergraduate or graduate
`coursework relate to mobile device location
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`21
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`systems?
` A I think the answer to that -- you said
`"relate to."
` And I think the answer is yes because I
`studied advanced signal processing techniques for
`communication systems.
` And including mobile communication
`systems that were emerging at the time.
` So, the mobile communication systems
`that were emerging, they do relate to, generally,
`positioning techniques.
` Q Are you saying that you studied how
`mobile communication systems relate to positioning
`techniques for your Ph.D. coursework?
` A I'm not sure that -- I mean, the
`phrasing of the question, how do mobile systems
`relate to positioning or how does positioning
`relate to mobile systems?
` So I'm -- most positioning techniques
`in mobile communication systems, most of them
`came -- I think most of them would develop later.
`So, after, I took a course related to TDMA and
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`Transcript of Todor V. Cooklev, Ph.D.
`Conducted on October 22, 2024
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`22
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`then the GSM second-generation system, which was
`state of the art in the -- basically, in the early
`1990s, and it was state of the art throughout the
`1990s.
` So, yes, I think most positioning
`techniques would develop -- were developed after
`that. But even after my coursework, I have
`attended -- for example, I've attempted --
`attended a number of tutorials, and other
`presentations at international conferences,
`tutorials at standards committee meetings, which
`I've attended a significant number.
` So, in these tutorials, there have been
`discussions of positioning techniques in mobile
`communication systems.
` So I think that one -- from attending a
`tutorial like that, I think one would get,
`especially after having the background, I think
`one would learn quite a bit.
` Q But you would agree that to prepare --
`or to obtain your Ph.D., you did not study
`positioning techniques in mobile communication
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`Conducted on October 22, 2024
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`23
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`systems, correct?
` A With that statement, with that question
`as phrased, I wouldn't quite agree. I mean, I
`studied what -- generally what existed at the
`time. And since mobile communications were
`rapidly being developed at the time, a number of
`things, indeed, would develop later; however, the
`foundation for these things, including
`positioning, I think I was familiar with.
` Q What sort of positioning techniques in
`mobile communication systems did you study while
`you were working on your Ph.D.?
` A For example, one technique is the angle
`of arrival estimation, that I think I knew how
`it -- I studied that algorithm.
` Q What is the angle of arrival
`estimation?
` A Well, it's an algorithm to determine if
`there is a wireless transmission towards you, to
`determine the angle that it's coming from.
` Q And that is an algorithm that's used to
`determine mobile device location?
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`Conducted on October 22, 2024
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`24
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` A When you say it's "used," what do you
`mean?
` Q You identified this algorithm as
`something you studied during your Ph.D. education
`as a positioning technique of mobile communication
`systems. That is the context I'm using it in.
` A Well, still, when you say "used," I
`mean, this algorithm can be used in mobile
`communication systems.
` Q Did you understand this algorithm to be
`one that was used to determine mobile device
`location in a mobile communication system when you
`were obtaining your Ph.D.?
` A Well, you said that "was used," which I
`want to understand better. You know, by this, you
`mean whether base stations were using -- all of
`the base stations were using this method at the
`time?
` Q I want to understand why you identified
`this algorithm, when I asked you about whether you
`studied coursework relating to mobile device
`location systems.
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`Conducted on October 22, 2024
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` A Well, all I did was I gave you an
`example of one algorithm that is related -- it is
`one of the -- just in general, one of the location
`estimation techniques.
` Q And so, you understood, when you were
`obtaining your Ph.D., that that algorithm could be
`used to estimate a mobile device's location; is
`that correct?
` A Yes. I also note, if I may, Counsel,
`that you asked me about the -- to some extent, the
`state of the art in the mid-1990s. But the
`priority date of these patents is September of
`2006, as I also describe in paragraph 19 of my
`declaration for the '583 patent. And my
`perspective in this declaration is a person of
`ordinary skill in the art as of that time, which
`is September 2006.
` Q Are you saying that the knowledge in
`the field further developed between when you
`obtained your Ph.D. and September of 2006?
` A Absolutely. Mobile communication has
`been, it was during the periods, mid-1990s to
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`Conducted on October 22, 2024
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`26
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`December 2006, and has remained, since, a field
`that has seen very significant development.
` Q And you would agree that it's seen very
`significant development because there has been
`tremendous interest in this field, in the
`industry?
` A I mean, I would agree with that. I'm
`not sure which one is first. Is it the
`development or the interest in the industry? But
`both have been very significant. I mean, the
`market opportunity has been very significant,
`which probably comes first.
` Q In paragraph 6 of your declarations,
`you state that you teach several courses related
`to the hardware and software architectures of
`wireless systems and wireless devices, correct?
` A Yes.
` Q Do any of your courses cover systems or
`methods from locating mobile devices?
` A Yes.
` Q Which ones?
` A So, first, I teach a course on -- I
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`Conducted on October 22, 2024
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`27
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`teach a course on communication systems, in which
`I go over, starting with first-generation
`satellite systems to -- all the way to the
`fifth-generation satellite systems.
` And so, as part of that, there's
`some -- I do mention my location estimation. But
`I also do research, I've -- and I also teach about
`some of the things that I do research on and, so,
`for example, I think I have contributed
`significantly to one standard for -- it's just,
`primarily, in signal intelligence, but it is,
`generally, a softer or defined radio standard.
`And as part of that standard, there is position
`estimation used and positioned data is part of
`that interface standard.
` I mean, these are some examples.
` Q For the standard that you're
`referencing, did you work on the portion of the
`standard relating to position estimation?
` A Well, I've worked on the entire
`standard, including that portion.
` Q Were you the sole contributor to the
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`standards discussion of position estimation?
` A No. I don't -- and standards are
`normally a -- they normally are not developed by
`one person. Although, for that standard, I
`believe I have done significant work, but others
`also contributed.
` Q And which standard are you referring
`to?
` A I was referring to the Vita 49
`standard.
` Q And so, you contributed to the Vita 49
`standard's discussion of position estimation?
` A Excuse me?
` Q You contributed to that standard's
`discussion of position estimation?
` A Well, I said that I worked on the
`entire standard. The discussion of how position
`data is represented and encoded in that standard.
`The infused part of that standard.
` Q Could you, please, spell the standard
`that you're referring to? Because I don't believe
`you refer to it, expressly, in your declaration.
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` A Of course I can. This may be in my CV,
`there is, somewhere, something like that is
`mentioned. It's spelled V-I-T-A 49.
` Q And do you -- strike that.
` Can you, please, explain how position
`estimation is used in the Vita 49 standard?
` A Well, I have to -- we have to look at
`the standard.
` Q Okay. So sitting here today, you don't
`recall what contributions you made to the Vita 49
`standard's use of position estimation?
` A Well, I recall working on that entire
`standard. And just what I said, working on the
`entire standard is what I recall.
` Q In paragraph 8 of your declaration, you
`say that a list of your publications and patents
`appears in your curriculum vitae, attached as
`Appendix 1, correct?
` A Yes.
` Q Do you understand that your
`declarations do not actually have any appendices?
` A Oh. I mean, I -- I think I will take
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`your word, Counsel, for this.
` Up to this moment, I was not
`understanding that.
` Q Are the versions of your declaration
`that you signed off on, did they have appendices?
` A No, probably what I signed off was this
`version. And maybe when I signed off, I was
`thinking that the CV would be attached as
`Appendix 1. But I just have to acknowledge that
`due to oversight, that maybe it wasn't.
` MR. CONKLE: Counsel, obviously, if you
`want a copy of the CV, we can make that happen.
`My apologies.
` MR. ZEILBERGER: Thank you for that,
`Counsel.
` Q Dr. Cooklev, are you receiving
`compensation from Broadphone for any work, other
`than the work you're performing for these IPRs?
` A No, I'm not.
` Q If you could turn to paragraph 26 of
`your 153 proceeding declaration.
` A Paragraph 26?
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`Conducted on October 22, 2024
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`31
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` Q Yes.
` A Yes. I'm looking at it.
` Q In paragraph 26, you describe what you
`believe is taken into account for an obviousness
`analysis, correct?
` A In paragraph 26, which is part of the
`section, with my understanding of the legal
`standards that govern here, I describe my
`understanding of obviousness analysis.
` Q If you go to the next page, paragraph
`27, you state that specific teachings,
`suggestions, or motivations to combine any first
`prior art reference with the second prior art
`reference must have existed before the date of
`purported invention.
` Do you see that?
` A Yes, I see it.
` Q What does that mean?
` A There is a general idea. What this
`means is that the motivation to combine any two
`references should not be based on -- entirely on
`hindsight.
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`32
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` And so, the -- so that's why I state
`the teaching, suggestions, or motivations
`should -- must have existed before the date of the
`invention.
` Q Can you, please, pull out Exhibit 1001,
`in the 153 proceeding, which is the '583 patent?
` (Exhibit 1001 previously marked for
`identification and attached to the transcript.)
` A Yes, I have the '583 patent here,
`convenient hard copy.
` Q And, can you, please, turn to the
`claims.
` A Yes. I'm looking at the claims.
` Q Claim 1 of the '583 patent is directed
`to a method of location determination, correct?
` A Claim 1 is a little bit long, and
`claim 1 recites the location-determining method --
`actually, it recites a signal comparison based
`location-determining method, and continues.
` So, if this is what you mean by
`"location-determination method," yeah, that's
`what, generally, claim 1 is about.
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`Conducted on October 22, 2024
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`33
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` Q Claim 1 of the '583 patent includes
`first portable RF communications device, correct?
` A Yes. There is a first portable RF
`communications device?
` Q Is claim 1 limited to methods that make
`use of
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