Case 2:22-md-03034-TGB ECF No. 246-9, PageID.12804 Filed 06/20/24 Page 1 of 6
`
`EXHIBIT 8
`
`
`
`EXHIBIT 8
`
`
`
` UNITED STATES DISTRICT COURT
` EASTERN DISTRICT OF MICHIGAN
` SOUTHERN DIVISION
`--------------------------X
`IN RE NEO WIRELESS, LLC : Case No.
`PATENT LITIGATION : 2:22-md-03034-TGB
`--------------------------X
`
` HIGHLY CONFIDENTIAL -- ATTORNEYS' EYES ONLY
` VIDEOTAPED DEPOSITION OF HARRY V. BIMS
` Wednesday, May 22, 2024
` Atlanta, GA
` 9:16 a.m. Eastern Time
`
`Job No.: 536432
`Pages: 1 - 187
`STENOGRAPHICALLY REPORTED BY:
`GISELLE MITCHELL-MARGERUM, RPR, CRI, CCR, LCR, ACCR, CSR
`CALIFORNIA CSR 14424
`
`1 2 3 4 5 6 7 8 9 1
`
`0
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`Case 2:22-md-03034-TGB ECF No. 246-9, PageID.12805 Filed 06/20/24 Page 2 of 6
`
`
`
`Case 2:22-md-03034-TGB ECF No. 246-9, PageID.12806 Filed 06/20/24 Page 3 of 6
`
`Highly Confidential - Attorneys' Eyes Only
`Transcript of Harry V. Bims
`Conducted on May 22, 2024
`
`141
`
`03:57:03
`03:57:16
`03:57:20
`03:57:30
`03:57:36
`03:57:42
`03:57:52
`03:58:10
`03:58:15
`03:58:23
`03:58:26
`03:58:32
`03:58:35
`03:58:39
`03:58:41
`03:58:44
`03:58:48
`03:58:50
`03:59:01
`03:59:04
`03:59:09
`03:59:14
`03:59:17
`03:59:22
`03:59:24
`
`period of the transmitted information bits.
` Q. In an LTE system, are the symbols OFDM
`symbols?
` A. Well, in an LTE system, there are no DSSS
`signals, to begin with. In an LTE system, on the
`downlink direction, there are OFDM symbols for the
`downlink from the base station to the UE.
` Q. And in this section of your report on the
`'908 Patent, you don't cite to anything that shows
`that the actual claim language of the asserted
`claims themselves recite the phrase, "multiple
`integer." Correct?
` A. The phrase, "multiple integer," does not
`appear in the claims. That's true.
` Q. And the phrase, "multiple integer," also
`does not appear in the asserted claims of the
`'302 Patent. Correct?
` A. That's correct.
` Q. And you do not cite anything in your
`report showing that the specification defines a time
`duration of a DSSS signal as an integer multiple of
`a symbol period during which data is transmitted.
`Correct?
` A. You are talking about the '908 Patent
`specification?
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`1 2 3 4 5 6 7 8 9 1
`
`0
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`
`
`Case 2:22-md-03034-TGB ECF No. 246-9, PageID.12807 Filed 06/20/24 Page 4 of 6
`
`Highly Confidential - Attorneys' Eyes Only
`Transcript of Harry V. Bims
`Conducted on May 22, 2024
`
`149
`
`04:14:44
`04:14:49
`04:14:51
`04:14:54
`04:14:58
`04:15:00
`04:15:03
`04:15:05
`04:15:07
`04:15:09
`04:15:14
`04:15:14
`04:15:15
`04:15:16
`04:15:17
`04:15:30
`04:15:34
`04:15:39
`04:15:47
`04:15:50
`04:15:54
`04:15:59
`04:16:04
`04:16:09
`04:16:14
`
`for transmission.
` Q. And so, am I understanding correctly your
`answer to be that this is data modulation as opposed
`to signal modulation, in your view?
` A. Yes. Data modulation still occurs even if
`all of the information bits are one.
` Q. And then the next sentence, you say:
` "The transmitter and receiver both
`understand there is a one-to-one correspondence
`between the DSSS signal and information bits of
`one."
` Correct?
` A. Yes.
` Q. What do you mean by "one-to-one"
`correspondence here?
` A. The DSSS signal was constructed through a
`mathematical operation, in which a DSSS sequence was
`multiplied by information bits. Both the
`transmitter and receiver understand that this
`mathematical operation is taking place.
` So, the function of the receiver is to
`reverse the process of the transmitter, whereas the
`transmitter received as an input, information bits,
`and then multiplied them mathematically by a DSSS
`sequence to form a DSSS signal.
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`1 2 3 4 5 6 7 8 9 1
`
`0
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`
`
`Case 2:22-md-03034-TGB ECF No. 246-9, PageID.12808 Filed 06/20/24 Page 5 of 6
`
`Highly Confidential - Attorneys' Eyes Only
`Transcript of Harry V. Bims
`Conducted on May 22, 2024
`
`185
`
` C E R T I F I C A T E
`
` I, Giselle M. Mitchell, RPR, CRI, CCR,
`LCR, ACCR, CSR, do hereby certify that the witness,
`HARRY BIMS, was first duly sworn by me pursuant to
`stipulation of counsel and that I was authorized to and
`did report said proceedings.
` I further certify that the foregoing transcript is
`a true and correct record of the proceedings; that said
`proceedings were taken by me stenographically and
`thereafter reduced to typewriting under my supervision;
`that reading and signing was not requested; and that I
`am neither attorney nor counsel for, nor related to or
`employed by, any of the parties to the action in which
`this deposition was taken; and that I have no interest,
`financial or otherwise, in this case.
`
` IN WITNESS WHEREOF, I have hereunto set my
`hand this 4th day of June, 2023.
`
`____________________________________
`GISELLE MITCHELL-MARGERUM, RPR, CRI, CCR, LCR, ACCR, CSR
`
`1 2 3 4 5 6 7 8 9 1
`
`0
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`
`
`Case 2:22-md-03034-TGB ECF No. 246-9, PageID.12809 Filed 06/20/24 Page 6 of 6
`
`Highly Confidential - Attorneys' Eyes Only
`Transcript of Harry V. Bims
`Conducted on May 22, 2024
`
`186
`
` DISCLOSURE
`STATE OF GEORGIA:
`Deposition of HARRY BIMS
`
` Pursuant to Article 8.B of the Rules and
`Regulations of the Board of Court Reporting of the
`Judicial Council of Georgia, I make the following
`disclosure:
` I am a Georgia Certified Court Reporter. I am here
`as a representative of Planet Depos.
` I was contacted by Planet Depos to provide court
`reporting services for this Deposition. I will not be
`taking this Deposition under any contract that is
`prohibited by O.C.G.A. 15-14-37 (a) and (b).
` I have no contract/agreement to provide reporting
`services with any party to the case, any counsel in the
`case, or any reporter or reporting agency from whom a
`referral might have been made to cover this Deposition.
`I will charge my usual and customary rates to all
`parties in the case and a financial discount will not be
`given to any party to this litigation.
`
` This, the 4th day of June, 2024.
`
`____________________________________
`GISELLE MITCHELL-MARGERUM, RPR, CRI, CCR, LCR, ACCR, CSR
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`1 2 3 4 5 6 7 8 9 1
`
`0
`
`11
`
`12
`
`13
`
`14
`
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
