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`SHAMOS-021020rough
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`ROUGH DRAFT - NOT FINAL EDITED
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`1
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`ROUGH ASCIT -- NOT CERTIFIED
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`NOTICE
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`This transcript is an UNCERTIFIED ROUGH DRAFT
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`TRANSCRIPT.
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`Stenotype machine translated into English by the
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`court reporter's computer, without the benefit of
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`proofreading.
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`It will contain untranslated steno
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`outlines, mistranslations (wrong words), and
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`misspellings. These and any other errors will be
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`corrected in the final
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`transcript.
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`Since this rough
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`draft transcript has not been proofread,
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`the court
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`reporter cannot assume responsibility for any errors
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`therein. This rough draft transcript is intended to
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`assist attorneys in their case preparation and is
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`not to be construed as the final
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`transcript.
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`It is
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`not to be read by the witness or quoted in any
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`pleading or for any other purpose and may not be
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`filed with any court.
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`2
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`1
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`COMMENCING --
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`Page 1
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`Case 1:19-cv-11278-RGS Document 35-1 Filed 02/12/20 Page 2 of 3
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`see what happens.
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`SHAMOS-021020rough
`It could very well be that Mr.
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`Chassman will handle the objections during your
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`redirect.
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`THE WITNESS:
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`He seems capable to me.
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`MR. KATZ: We can go off the record.
`ae
`he
`le
`*
`ow
`OO
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`(Whereupon, a brief recess was taken.)
`wow ot
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`EXAMINATION
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`BY MR. FOSTER:
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`Q.
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`Dr. Shamos, you understand you're still
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`under oath?
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`A.
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`Q.
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`Yes,
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`I do.
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`All right.
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`You have in front of you your
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`computer with a number of documents that have been
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`filed in court;
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`is that right?
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`ROUGH DRAFT - NOT FINAL EDITED
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`100
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`A.
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`Q.
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`Yes.
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`would you open up on the computer the
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`document entitled defendant's joint opening brief on
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`claim construction and indefiniteness.
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`A.
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`Yes,
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`I have that.
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`I have a flash drive, if
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`you want to look at these documents.
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`MR. CHASSMAN:
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`Is this -- you're talking
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`about the brief filed in this case?
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`MR. FOSTER: Yeah.
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`MR. CHASSMAN: Yes.
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`MR. FOSTER:
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`I assume you have a copy.
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`BY MR. FOSTER:
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`Q.
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`Have you read that document?
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`Page 87
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`Case 1:19-cv-11278-RGS Document 35-1 Filed 02/12/20 Page 3 of 3
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`OoDoSNUNDDWwHBPWwWNMFR
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`A.
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`Q.
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`Yes.
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`SHAMOS~021020rough
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`Have you formed any opinions on statements
`
`that are contained in that document?
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`MR. CHASSMAN: Objection; goes beyond
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`the scope of cross.
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`A.
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`I have rebuttal argument to some of the
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`points made in the brief.
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`MR. FOSTER: what's the next exhibit?
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`11?
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`COURT REPORTER: Yes.
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`MR. FOSTER: Ask the reporter to mark as
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`Exhibit 11 this document.
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`101
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`fede
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`(Shamos Deposition Exhibit 11 was marked for
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`identification.)
`ee
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`A.
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`T'm ready.
`
`BY MR FOSTER:
`
`Okay. who prepared this document?
`
`I did.
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`And what was the purpose of your preparing
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`Q.
`
`A.
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`Q.
`
`it?
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`A.
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`I was asked to look at defendant's Markman
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`brief and see if I disagreed with anything in there.
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`MR. CHASSMAN:
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`I'm going to object to
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`this whole line of questioning as improper, it's
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`prejudicial, and we were not provided a copy of this
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`in advance of the deposition. This appears to be --
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`call it what you want, but it's additional opinions,
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`Page 88
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