Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 1 of 284 PageID #: 52477
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`Exhibit 1
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`Exhibit 1
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`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 2 of 284 PageID #: 52478
`Dey, Anind
`2019-11-12
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`______________________________________________________
`ARENDI S.A.R.L., )
`) Plaintiff, )
`) v. )C.A. No. 12-1595-LPS
`) LG ELECTRONICS, INC., LG )
`ELECTRONICS USA, INC. and LG ) ELECTRONICS MOBILECOMM )
`U.S.A., INC., ) )
`Defendants. ) ____________________________ )
`ARENDI S.A.R.L., ) )
`Plaintiff, ) )C.A. No. 12-1596-LPS
`v.
`) )
`APPLE INC., ) )
`Defendant. ) ____________________________ )
`ARENDI S.A.R.L., ) )
`Plaintiff, ) )
`v.
`)C.A. No. 12-1597-LPS )
`BLACKBERRY LIMITED and ) BLACKBERRY CORPORATION, )
`) Defendants. )
`____________________________ ) ARENDI S.A.R.L., )
`) Plaintiff, )
`) v. )C.A. No. 12-1599-LPS
`) MICROSOFT MOBILE, INC., )
`) Defendant. )
`____________________________ ) )
`
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` ) )
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`ARENDI S.A.R.L.,
`Plaintiff, ) )
`v.
`)C.A. No. 12-1601-LPS )
`MOTOROLO MOBILITY LCC f/k/a ) MOTOROLA MOBILITY, INC., )
`) Defendant. )
`____________________________ ) ARENDI S.A.R.L., )
`) Plaintiff, )
`) v. )C.A. No. 12-1602-LPS
`) SONY MOBILE COMMUNICATIONS )
`(USA) INC., f/k/a SONY ) ERICSSON MOBILE )
`COMMUNICATIONS (USA) INC., ) SONY CORPORATION and SONY )
`CORPORATION OF AMERICA, ) )
`Defendants. ) ____________________________ )
`ARENDI S.A.R.L., ) )
`Plaintiff, ) )
`v.
`)C.A. No. 13-919-LPS )
`GOOGLE LLC, ) )
`Defendant. ) ____________________________ )
`ARENDI S.A.R.L., ) )
`Plaintiff, ) )
`v.
`)C.A. No. 13-920-LPS )
`OATH HOLDINGS INC. and OATH ) INC.,
`) Defendants. )
`____________________________ ) )
`Job No. CS3601378
`
` )
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`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 4 of 284 PageID #: 52480
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`______________________________________________________
`VIDEO RECORDED DEPOSITION UPON ORAL EXAMINATION OF
`ANIND DEY
`______________________________________________________
`
`11:01 A.M.
`NOVEMBER 12, 2019
`701 FIFTH AVENUE, SUITE 6900
`SEATTLE, WASHINGTON
`
`REPORTED BY: CARLA R. WALLAT, CRR, RPR, CCR 2578
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`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 5 of 284 PageID #: 52481
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`A P P E A R A N C E S
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`FOR THE PLAINTIFF AND THE WITNESS:
`KEMPER DIEHL
`Susman Godfrey LLP
`1201 Third Avenue, Suite 3800
`Seattle, Washington 98101
`206.373.7382
`kdiehl@susmangodfrey.com
`
`FOR DEFENDANT LG ELECTRONICS, INC., LG ELECTRONICS USA,
`INC. and LG ELECTRONICS MOBILECOMM U.S.A., INC.:
`(Present via telephone conference call)
`MATTHEW C. BERNSTEN
`Fish & Richardson PC
`One Marina Park Drive
`Boston, Massachusetts 02210-1878
`617.542.5070
`bernsten@fr.com
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`A P P E A R A N C E S (Continued)
`
`FOR DEFENDANT APPLE INC.:
`JONATHAN H. HICKS
`DLA Piper
`2000 University Avenue
`East Palo Alto, California 94303
`650.833.2000
`jonathan.hicks@dlapiper.com
`
`FOR DEFENDANTS BLACKBERRY LIMITED AND BLACKBERRY
`CORPORATION:
`(Present via telephone conference call)
`JASON W. COOK
`McGuireWoods LLP
`2000 McKinney Avenue, Suite 1400
`Dallas, Texas 75201
`214.932.6422
`jcook@mcguirewoods.com
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`A P P E A R A N C E S (Continued)
`
`FOR DEFENDANT MICROSOFT MOBILE, INC.:
`(Present via telephone conference call)
`DeANNA ALLEN
`Cooley LLP
`1299 Pennsylvania Avenue, NW, Suite 700
`Washington, DC 20004-2400
`202.842.7896
`dallen@cooley.com
`
`FOR DEFENDANTS SONY MOBILE COMMUNICATIONS (USA) INC.,
`f/k/a SONY ERICSSON MOBILE COMMUNICATIONS (USA) INC.,
`SONY CORPORATION and SONY CORPORATION OF AMERICA, and
`OATH HOLDINGS INC. and OATH INC.:
`(Present via telephone conference call)
`ALPER T. ERTAS
`Venable LLP
`101 California Street Suite, 3800
`San Francisco, California 94111
`415.653.3750
`atertas@Venable.com
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`A P P E A R A N C E S (Continued)
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`FOR DEFENDANT GOOGLE LLC and MOTOROLO MOBILITY LCC
`f/k/a MOTOROLA MOBILITY, INC.:
`ROBERT UNIKEL
`Paul Hastings LLP
`71 South Wacker Drive, 45th Floor
`Chicago, Illinois 60606
`312.499.6030
`robertunikel@paulhastings.com
`
`ALSO PRESENT: EDDIE SAMS - Videographer
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`I N D E X
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`EXAMINATION BY:
`MR. UNIKEL
`MR. DIEHL
`MR. UNIKEL
`
` PAGE(S)
` 13
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` 265
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` PAGE
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`EXHIBITS FOR IDENTIFICATION
` 15
`Exhibit 1 Subpoena
`Exhibit 2 University of Washington iSchool 17
`Directory, Anind K. Dey
`Exhibit 3 Future Computing Environments home 21
`page
`Exhibit 4 Future Computing Environments,
`Projects
`Exhibit 5 Document bearing Bates numbers
`ARENDI-DEFS00021090 through
`ARENDI-DEFS00021091
`Exhibit 6 Document bearing Bates numbers
`ARENDI-DEFS00022070 through
`ARENDI-DEFS00022077
`Exhibit 7 Document bearing Bates numbers
`ARENDI-DEFS00022052 through
`ARENDI-DEFS00022053
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` 50
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`EXHIBITS FOR IDENTIFICATION PAGE
`Exhibit 8 Future Computing Environments 52
`blow-up of Web pages, 3 pages
`Exhibit 9 Document bearing Bates numbers 67
`ARENDI-DEFS00022056 through
`ARENDI-DEFS00022064
`Exhibit 10 Document bearing Bates numbers 73
`ARENDI-DEFS00021078 through
`ARENDI-DEFS00021079
`Exhibit 11 Document bearing Bates numbers 74
`ARENDI-DEFS00021071 through
`ARENDI-DEFS00021077
`Exhibit 12 Blow-ups from Exhibit 11, five 80
`pages
`Exhibit 13 Document entitled: "CyberDesk: A 97
`Framework for Producing
`Self-Integrating Ubiquitous
`So ware Services"
`Exhibit 14 Document bearing Bates numbers 99
`ARENDI-DEFS00022065 through
`ARENDI-DEFS00022069
`Exhibit 15 Document bearing Bates numbers 109
`ARENDI-DEFS00021059 through
`ARENDI-DEFS00021063
`Exhibit 16 Blow-ups from Exhibit 15, 2 pages 112
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` PAGE
`EXHIBITS FOR IDENTIFICATION
`Exhibit 17 Document bearing Bates numbers
`ARENDI-DEFS00021045 through
`ARENDI-DEFS00021050
`Exhibit 18 Document bearing Bates numbers
`ARENDI-DEFS00021080 through
`ARENDI-DEFS00021081
`Exhibit 19 Document bearing Bates numbers
`ARENDI-DEFS00021064 through
`ARENDI-DEFS00021070
`Exhibit 20 Blow-ups from Exhibit 19, 11 pages 132
`Exhibit 21 Document bearing Bates numbers
` 133
`ARENDI-DEFS00022078 through
`ARENDI-DEFS00022081
`Exhibit 22 Document bearing Bates numbers
`AHL0121553 through AHL0121563
`Exhibit 23 Document bearing Bates numbers
`ARENDI-DEFS00021056 through
`ARENDI-DEFS00021058
`Exhibit 24 Blow-ups from Exhibit 23, six 140
`pages
`Exhibit 25 Document bearing Bates numbers 147
`ARENDI-DEFS00021092 through
`ARENDI-DEFS00021093
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` 135
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` 138
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`EXHIBITS FOR IDENTIFICATION
`Exhibit 26 Document Entitled: "Simple
`Contact Book Manager" Manager
`Exhibit 27 Document bearing Bates numbers
`ARENDI-DEFS00021084 through
`ARENDI-DEFS00021086
`Exhibit 28 Document bearing Bates number
`ARENDI-DEFS00021088
`Exhibit 29 Document bearing Bates numbers
`ARENDI-DEFS00021082 through
`ARENDI-DEFS00021083
`Exhibit 30 Document bearing Bates number
`ARENDI-DEFS00021089
`Exhibit 31 Document bearing Bates numbers
`ARENDI-DEFS00021095 through
`ARENDI-DEFS00021096
`Exhibit 32 Document bearing Bates numbers
`ARENDI 130254 through ARENDI
`130266
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` 239
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`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 13 of 284 PageID #: 52489
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`SEATTLE, WASHINGTON; NOVEMBER 12, 2019
`11:01 a.m.
`--oOo--
`
`THE VIDEOGRAPHER: Good morning. We're
`going on the record at 11:01 on Tuesday, November 12th,
`2019. Please note that the microphones are sensitive
`and may pick up whispering, private conversations, and
`cellular interference. Please turn off all cell phones
`or place them away from the microphones as they can
`interfere with the deposition audio.
`Audio and video recording will continue to
`take place unless all parties agree to go off the
`forward.
`This is media unit one of the video-recorded
`deposition of Anind Dey taken in the matter of Arendi
`S.A.R.L. versus Google, et al., filed in the United
`States District Court for the District of Delaware,
`Case Number 12-1601-LPS. This deposition is being held
`at DLA Piper, 701 Fi h Avenue, Suite 6900, Seattle,
`Washington.
`My name is Eddie Sams from the firm Veritext,
`and I'm the videographer. The court reporter is Carla
`Wallat from the firm Veritext.
`I am not authorized to administer an oath, I
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`ANIND DEY,
`sworn as a witness by the Certified Court Reporter,
`testified as follows:
`
`am not related to any party in this action, nor am I
`financially interested in the outcome.
`If there are any objections to proceeding,
`please state them at the time of your appearance.
`Counsel's appearances will be noted on the
`written record.
`Will the court reporter please swear in the
`witness.
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`EXAMINATION
`14
`BY MR. UNIKEL:
`15
`16 Q. Good morning, sir.
`17
`A. Good morning.
`18 Q. Can you please state your name for the record?
`19
`A. Anind Dey.
`20 Q. And sir, thank you very much for appearing
`21
`here today. Just, have you ever been deposed before?
`A.
`22
`I have not.
`23 Q. So this will be a new life experience for you?
`24
`A. That's right.
`25 Q. Just to give you a quick rundown as to how
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`this works today, I'll be asking you questions and
`1
`you'll be answering questions under an oath to tell the
`2
`truth. Do you understand that?
`3
`A. Yes.
`4
`5 Q. And we have a court reporter here today that
`6
`will type down everything that you or I or other
`7
`counsel state. You understand that?
`8
`A. Yes.
`9 Q. And we have a videographer here so that this
`10
`can be videotaped and potentially shown at a trial, and
`11
`therefore, you wouldn't, hopefully, have to appear
`12
`and -- and disrupt your schedule any more than this.
`13
`A. Yes.
`14 Q. Do you understand that?
`15
`A.
`I do, thank you.
`16 Q. Also, I want to be clear, you are not involved
`17
`in this lawsuit in any way. You understand that?
`18
`A. I do.
`19 Q. We are simply here trying to explore some work
`20
`that you did back in the 1990's, but I just wanted to
`21
`reassure you again that you are not a defendant, you
`22
`are not implicated in this lawsuit, and -- and I
`23
`appreciate your appearance here today.
`24
`A. Sure.
`25 Q.
`If you don't understand a question that I ask
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`or you need me to speak up or rephrase it, please let
`1
`me know and I'll be happy to do that. Would you -- do
`2
`you understand that?
`3
`I do, thanks.
`A.
`4
`5 Q. Great. And from time to time today, I'm going
`6
`to be marking some paper exhibits and I'll share any
`7
`copies of those with you, just so you understand just
`8
`sort of how the procedure works.
`9
`A. Sure.
`10 Q. Let me start, if I might, by showing you what
`11
`has been marked as Dey Exhibit Number 1.
`12
`(Deposition Exhibit 1 was marked for
`13
`identification.)
`14 Q. (BY MR. UNIKEL) And Dey Exhibit Number 1 is a
`15
`subpoena to testify in a deposition, and this is issued
`16
`by Google LLC. Do you see that?
`17
`A. I do.
`18 Q. And am I correct, sir, you received a copy of
`19
`this?
`20
`A. I do -- I did, yeah.
`21 Q. And in fact, this is the reason you're
`22
`appearing here for the deposition today, because you
`23
`received a subpoena --
`24
`A. Several.
`25 Q. -- from Google, Motorola, and a number of
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`other defendants in the case? You under --
`1
`A. That's correct.
`2
`3 Q. Okay. And, sir, you are not being paid in any
`4
`way for your testimony here today --
`5
`A. Not at all.
`6 Q. -- correct?
`7
`And you have no financial interest in the
`8
`outcome of this litigation whatsoever, do you?
`9
`A. No, I do not.
`10 Q. Okay. Sir, as part the subpoena, you will
`11
`recall that you were asked to look for some documents
`12
`in -- in the event that you might have any of those in
`13
`your possession. Did you do that, sir?
`14
`A. I did look.
`15 Q. And did you find anything?
`16
`A. I could only find what was available on the
`17
`public website.
`18 Q. Okay. And when you say "the public website,"
`19
`what is the public website that you're referring to?
`20
`A. There's a website called the "Future Computing
`21
`Environment CyberDesk" page hosted at Georgia Tech in
`22
`the College of Computing, where I did my Ph.D. That
`23
`was a site I put together probably in 1997
`24
`through 1999. And that has the documentation of all
`25
`the papers that I published and some source code, as
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`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
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`well as some additional descriptions of -- additional
`1
`descriptions of services involved in the CyberDesk
`2
`system that didn't show up in a publication.
`3
`4 Q. Okay. That's very helpful, and let me -- I'm
`5
`going to get to that in greater detail.
`6
`A. Sure.
`7 Q. Let me do one first if I might, which is I'm
`8
`going to show you a copy of what I'm marking as Exhibit
`9
`Number 2.
`10
`(Deposition Exhibit 2 was marked for
`11
`identification.)
`12
`MR. UNIKEL: Here you go, sir.
`13
`THE WITNESS: Thank you.
`14
`MR. UNIKEL: This one, I didn't have an
`15
`extra copy of. I apologize.
`16 Q. (BY MR. UNIKEL) And am I correct, sir, that
`17
`Exhibit Number 2 is a printout from your University of
`18
`Washington Information School Web page?
`19
`It looks like it. I have to say I've never
`20
`seen it before so -- but it really looks like my
`21
`school, yes.
`22 Q.
`I guess just -- just to lay the groundwork of
`23
`who you are and what you're doing right now --
`24
`A. Sure, sure.
`25 Q. -- am I correct, you currently live here in
`
`A.
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`16:7-17:3
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`Arendi's
`Objections:
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`IPR Estoppel
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`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
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`17:25 - 18:15
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`Washington?
`1
`A. I do.
`2
`3 Q. And what is your current job?
`4
`A. I'm the dean of the Information School and a
`5
`professor within the Information School at the
`6
`University of Washington.
`7 Q. And when you say "the Information School,"
`8
`what is the Information School in particular?
`9
`A. It's a college that comes from -- used to be
`10
`an old library school, as library schools transitioned
`11
`what they focused on, being much more about technology.
`12
`It covers basically the interaction between
`13
`human centered and humanities, as well as more of a
`14
`STEM focus, so really looking at how to apply
`15
`technology for the greater good.
`16 Q. And how long have you been as -- on faculty at
`17
`the Information School at the University of Washington?
`18
`A. Since January 1st, 2018, so almost two years.
`19 Q. And this web bio, did you have some role in
`20
`putting together your -- your web bio for the
`21
`Information School?
`22
`I think I provided a CV to an admin, an IT
`23
`person at the school, and they must have put this
`24
`together.
`25 Q. So just so I'm aware, under -- there's a
`
`A.
`
`Google's Designations
`
`Arendi's Counter Designations
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`17:25 - 18:15
`
`
`
`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 20 of 284 PageID #: 52496
`Dey, Anind
`2019-11-12
`Page 19
`
`section on Page 2 of this Exhibit 2 called "Education."
`1
`A. Yes.
`2
`3 Q. See that?
`4
`And am I correct that you received your
`5
`bachelor's of science in computer engineering from
`6
`Simon Fraser University in 1993?
`7
`A. Correct.
`8 Q. And then you received a master's of science in
`9
`aerospace engineering from Georgia Tech in 1995; is
`10
`that right?
`11
`A. That's correct.
`12 Q. And then you -- you received both a master's
`13
`of science in computer science and a Ph.D. in computer
`14
`science from Georgia Tech in 2000; is that right?
`15
`A. That's correct.
`16 Q. And at a high level, since you graduated from
`17
`Georgia Tech with your Ph.D. in 2000 until your time
`18
`joining the Information School at University of
`19
`Washington, can you give me a brief description of what
`20
`your work history was between those periods of time?
`21
`A. Yes. So right a er graduate school, I
`22
`started as a senior researcher at Intel Research in
`23
`Berkeley, a brand-new lab that had just started, and I
`24
`became an adjunct faculty member at the University of
`25
`Berkeley within the electrical engineering and computer
`
`Google's Designations
`
`Arendi's Counter Designations
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`19:8-15
`
`
`
`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 21 of 284 PageID #: 52497
`Dey, Anind
`2019-11-12
`Page 20
`
`science department.
`1
`In roughly 2004, started -- I started -- well,
`2
`we moved from Berkeley to Pittsburgh in the summer of
`3
`2004, but I didn't start at Carnegie Mellon until 2005.
`4
`I was on the faculty in the Human Computer
`5
`Institute from January 2005 until I le , which was
`6
`December 2017, end of December 2017. I was an
`7
`assistant professor, an associate professor with
`8
`tenure, a full professor, and the last four -- four-ish
`9
`years, I served as department head.
`10
`11 Q. And that was all at Carnegie Mellon?
`12
`A. That was all at Carnegie Mellon.
`13 Q. And then a er you departed Carnegie Mellon,
`14
`did you come right to the University of Washington?
`15
`A. That's right.
`16 Q. And then since that time, when you joined the
`17
`University of Washington Information School, that's
`18
`where you've been ever since?
`19
`A. That's right.
`20 Q. Great. Thank you.
`21
`Sir, you had mentioned a website that, I think
`22
`you said, was for FCE, and what -- what is FCE?
`23
`A. Future Computing Environments. It was the
`24
`name of my researcher -- my -- my Ph.D. advisor was
`25
`Gregory Abowd's research group at the time.
`
`Google's Designations
`
`Arendi's Counter Designations
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`20:21 - 21:2
`
`
`
`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 22 of 284 PageID #: 52498
`Dey, Anind
`2019-11-12
`Page 21
`
`1 Q. Let me show you a document that I'm marking as
`2
`Exhibit Number 3.
`3
`(Deposition Exhibit 3 was marked for
`4
`identification.)
`5
`MR. DIEHL: Here's your document.
`6 Q. (BY MR. UNIKEL) Sir, is Exhibit Number --
`7
`what is Exhibit Number 3?
`8
`A. Exhibit Number 3 is the main homepage for the
`9
`Future Computing Environments website that we just
`10
`discussed.
`11 Q. And this -- the Future Computing Environments,
`12
`is that a group that is part of Georgia Tech?
`13
`A. It was.
`14 Q.
`It was. When was FCE, or Future Computing
`15
`Environments, a group that was part of Georgia Tech to
`16
`your recollection?
`17
`I think it started the year before I joined,
`18
`which would be 1996 or so. Could be 1995. And it was
`19
`a group at least through my Ph.D. graduation, but I
`20
`don't know when it ended a er that. So at least up
`21
`till 2000, possibly a er that. You can see this
`22
`website says it wasn't updated till -- since January of
`23
`'97, which I don't think is actually accurate.
`24 Q. Okay. So this -- the website in the Future
`25
`Computing Environments website, that was up and
`
`A.
`
`Google's Designations
`
`Arendi's Counter Designations
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`20:21 - 21:2
`
`21:6 - 13
`
`21:24 -22:3
`
`
`
`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 23 of 284 PageID #: 52499
`Dey, Anind
`2019-11-12
`Page 22
`
`A.
`
`available during the time that you were at Georgia
`1
`Tech?
`2
`A. Absolutely.
`3
`4 Q. And does that include -- you said you started
`5
`at Georgia Tech at around what year?
`6
`In computer science, I started in 1995, in the
`7
`fall.
`8 Q. Okay. And when you arrived, was the Future
`9
`Computing Environments website up and running, so to
`10
`speak?
`A.
`11
`I believe so.
`12 Q. Was there restricted access to the website, or
`13
`could anybody access it?
`14
`A. Anybody could access it.
`15 Q. And what sorts of things were put on the
`16
`Future Computing Environments website?
`17
`A. It was a typical research homepage for fact in
`18
`academia. So it was a list of people who were
`19
`associated with the Future Computing Environments
`20
`group, the projects that were undertaken by the people
`21
`involved in the group, access to equipment, and as well
`22
`as a list of projects that undergrads could get engaged
`23
`in to be part of the research group.
`24 Q. And did you -- let me show you, on this page
`25
`of Exhibit 3 --
`
`Google's Designations
`
`Arendi's Counter Designations
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`21:24 -22:3
`
`22:12 - 23:10
`
`
`
`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 24 of 284 PageID #: 52500
`Dey, Anind
`2019-11-12
`Page 23
`
`A. Yeah.
`1
`2 Q. -- which is the homepage, so to speak, of the
`3
`Future Computing Environments website, you see there's
`4
`a -- a tag called "projects"?
`5
`A. Yes.
`6 Q. And am I correct that that was a link which
`7
`would take you to a subsequent Web page?
`8
`A. That's right. All of these were links, yeah.
`9 Q. Let me show you a document that I'm marking as
`10
`Dey Exhibit 4.
`11
`(Deposition Exhibit 4 was marked for
`12
`identification.)
`13 Q. (BY MR. UNIKEL) Sir, am I correct that
`14
`Exhibit 4 appears to be the Projects page from the
`15
`Future Computing Environments website?
`16
`A. That's correct.
`17 Q. And there -- on this page, there is a list of
`18
`projects, and again, I assume that these are all links
`19
`which would take you to individual project pages?
`20
`A. That's correct.
`21 Q. And do you see on Page 2 of this "projects"
`22
`tab, there's a section for "past projects"?
`23
`A. Yes.
`24 Q. And one of those past projects is CyberDesk,
`25
`correct?
`
`Google's Designations
`
`Arendi's Counter Designations
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`22:12 - 23:10
`
`23:13-16
`
`23:21 - 25:12
`
`
`
`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 25 of 284 PageID #: 52501
`Dey, Anind
`2019-11-12
`Page 24
`
`A. Correct.
`1
`2 Q. Now, CyberDesk, what was -- are you familiar
`3
`with CyberDesk?
`4
`A. Yeah, I was one of the inventors of it.
`5 Q. So can you give me, at least at a high level,
`6
`a description of what CyberDesk was?
`7
`A. CyberDesk was a -- both an infrastructure and
`8
`a platform that allowed you to select information in
`9
`some application, have that information be -- have the
`10
`selected information be processed in a number of
`11
`different ways, and to cause a number of services to be
`12
`made available to -- in the user interface to somebody
`13
`who's trying to get more information about the
`14
`information they had selected.
`15
`The information could either be completely
`16
`highlighted with a mouse or if it -- a whole e-mail
`17
`could be considered as a selection. The whole -- all
`18
`the information -- content in a browser could be
`19
`considered the selected information.
`20 Q. And what was your role in creating CyberDesk?
`21
`A. So at the very beginning, I worked with a
`22
`visiting Ph.D. student from University of Birmingham,
`23
`Andy Wood, Andrew Wood. He had built an infrastructure
`24
`called "Cameo" something, I don't remember exactly the
`25
`name of it, Cameo. And it was a system that allowed
`
`Google's Designations
`
`Arendi's Counter Designations
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`23:21 - 25:12
`
`
`
`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 26 of 284 PageID #: 52502
`Dey, Anind
`2019-11-12
`Page 25
`
`you to plug different so ware components together.
`1
`Together, we had this idea that we could build
`2
`a system that could do what CyberDesk did, and so
`3
`building off of his Cameo work, we put the first --
`4
`first version of CyberDesk together that allowed these
`5
`different components to work together, one where you
`6
`were able to select information from one application
`7
`and have it be represented in some way in another
`8
`application.
`9
`10 Q. And when did you start working on CyberDesk to
`11
`the best of your recollection?
`12
`A. Yes. So that would have been fall of 1996.
`13 Q. And when did you then create the first working
`14
`version of CyberDesk?
`15
`MR. DIEHL: Objection to form.
`16
`A. Pardon me?
`17
`MR. DIEHL: I'm sorry, you can ahead.
`18 Q. (BY MR. UNIKEL) Oh, sorry. This is one of
`19
`those things that happens at a deposition. Every once
`20
`in a while the lawyers might have an objection --
`21
`A. Oh, okay.
`22 Q. -- to a question that they'll have to preserve
`23
`for later for a court.
`24
`A. Okay.
`25 Q.
`It -- it shouldn't concern you.
`
`Google's Designations
`
`Arendi's Counter Designations
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`23:21 - 25:12
`
`
`
`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 27 of 284 PageID #: 52503
`Dey, Anind
`2019-11-12
`Page 26
`
`A. That's okay.
`1
`2 Q.
`It just lawyer stuff that -- that shouldn't
`3
`get in the way of the question.
`4
`A. That's fine. Can you repeat the question
`5
`again?
`6 Q. Yes. So I was saying: So you began the work
`7
`in the fall of 1996 --
`8
`A. Yes.
`9 Q. -- on CyberDesk, and when did you have your
`10
`first prototype version of CyberDesk?
`11
`A. We submitted the paper in September of '90 --
`12
`sorry. We submitted the paper -- the paper was
`13
`published in -- at CHI 1997. The conference is in
`14
`April, I'm just trying to make sure I get my calendar
`15
`years right. So it means we submitted the work in the
`16
`fall of '96. Sorry, which means we did the work in
`17
`the -- in the summer of '96.
`18 Q. Okay. And when you say you "submitted the
`19
`paper," what do you mean?
`20
`A. We wrote up a paper that is -- if you went to
`21
`the -- the link on CyberDesk, it would come to a list
`22
`of publications, there's one paper that's listed, it's
`23
`a short paper, like three or four pages long --
`24
`actually, it might -- in those days, it might only be
`25
`two pages -- that was a description of the first
`
`Google's Designations
`
`Arendi's Counter Designations
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`26:9 - 27:6
`
`
`
`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 28 of 284 PageID #: 52504
`Dey, Anind
`2019-11-12
`Page 27
`
`instantiation of it, but the first -- but the work
`1
`was -- the first working version of it was in summer of
`2
`'96.
`3
`4 Q. Okay.
`5
`A. Because we had to have gotten it done before
`6
`we could submit the paper, update.
`7 Q. Understood.
`8
`So let me -- let me go through some of the
`9
`parts of that that you just described.
`10
`A. Sure.
`11 Q. Let me show you a document that I'm marking as
`12
`Exhibit Number 5.
`13
`(Deposition Exhibit 5 was marked for
`14
`identification.)
`15
`MR. UNIKEL: Here you go, sir.
`16
`A. Thank you.
`17 Q. (BY MR. UNIKEL) Sir, am I correct that
`18
`Exhibit Number 5 is the -- is the Web page for the
`19
`CyberDesk project that we just saw the linking to on
`20
`the Future Computer Environments Web page?
`21
`A. That's correct.
`22 Q. When was the last time you looked at this
`23
`particular Web page for the CyberDesk project?
`24
`I looked at it this morning just to refresh
`25
`myself.
`
`A.
`
`Google's Designations
`
`Arendi's Counter Designations
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`26:9 - 27:6
`
`27:17-21
`
`
`
`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 29 of 284 PageID #: 52505
`Dey, Anind
`2019-11-12
`Page 28
`
`1 Q. And did you have some role in creating this
`2
`index and this Web page?
`3
`A. I created the whole thing.
`4 Q. And when would you have -- sir, when did you
`5
`first post any information relating to CyberDesk?
`6
`A. It would have been in the spring of 1997 when
`7
`we got the paper published -- when we found out the
`8
`paper was getting published, and then it was updated
`9
`for a couple of years while the project was still
`10
`active.
`11 Q. And would you update it periodically or when
`12
`something happened that sort of made it worthwhile to
`13
`update it?
`14
`A. When something happened, when we had a
`15
`publication that was accepted or when we had a new
`16
`version of the so ware that we wanted to release.
`17 Q. Okay. And so on this, I notice at the top
`18
`le , we see the title of the page is "CyberDesk" and
`19
`it says "Version 2.0," correct?
`20
`A. Yes.
`21 Q. What -- what is Version 2.0?
`22
`A. I -- when I saw that this morning, I was
`23
`trying to remember, and honestly, I don't. My best
`24
`guess, if you want a guess, is that in those days, in
`25
`the early days of the Web, people were very concerned
`
`Google's Designations
`
`Arendi's Counter Designations
`
`Arendi's
`Objections:
`401; 402; 403;
`IPR Estoppel
`
`28:1-10
`
`
`
`Case 1:13-cv-00919-JLH Document 520-1 Filed 05/01/23 Page 30 of 284 PageID #: 52506
`Dey, Anind
`2019-11-12
`Page 29
`
`about versioning their Web pages, and so I suspect this
`1
`was a second version of the Web page, but I have no --
`2
`I don't really have a strong recollection of that.
`3
`4 Q. When did you -- did you continue to update
`5
`this page regularly until you le Georgia Tech?
`6
`A. No. When I moved to my thesis project, I
`7
`stopped working on this project completely. And so
`8
`this was fallow for a couple of years before I le
`9
`Georgia Tech.
`10 Q. So -- but all of the material that's on this
`11
`particular Web page, would you personally have put it
`12
`onto the Web page?
`13
`A. Yes.
`14 Q. And would that include, for example, the
`15
`linking to any articles or publications that are
`16
`included here?
`17
`A. That's correct.
`18 Q. I see at the top, under Version 2.0, there is
`19
`your name, correct?
`20
`A. Uh-huh, correct.
`21 Q. As well a
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