Case 2:22-md-03034-TGB ECF No. 255-16, PageID.19445 Filed 06/20/24 Page 1 of 46
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`Case 2:22-md-03034-TGB ECF No. 255-16, PageID.19446 Filed 06/20/24 Page 2 of 46
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`Transcript of Kemin Li, Ph.D.
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`Date: June 30, 2023
`Case: Neo Wireless, LLC Patent Litigation, In Re:
`
`Planet Depos - Michigan Firm Registration #8598
`Phone: 888.433.3767
`Email: transcripts@planetdepos.com
`www.planetdepos.com
`
`WORLDWIDE COURT REPORTING & LITIGATION TECHNOLOGY
`
`

`

`Transcript of Kemin Li, Ph.D.
`Conducted on June 30, 2023
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`1 (1 to 4)
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`APPEARANCES (Continued):
`
`For TOYOTA:
`
` SCHEEF & STONE, LLP
` BY: BECCA SKUPIN, ESQ.
` 200 North Travis Street
` Suite 402
` Sherman, Texas 75090
` (430) 262-5660
` (Via Videoconference)
`
`
`
`For GENERAL MOTORS COMPANY and GENERAL
`
` MOTORS LLC:
`
` FISH & RICHARDSON
` BY: LAWRENCE R. JARVIS, ESQ.
` 1180 Peachtree Street, NE
` 21st Floor
` Atlanta, Georgia 30309
` (404) 892-5005
` (Via Videoconference)
`
`
`
`For FORD MOTOR COMPANY:
`
` JENNER & BLOCK, LLP
` BY: PAARAS MODI, ESQ.
` 353 North Clark Street
` Chicago, Illinois 60654
` (312) 222-9350
` (Via Videoconference)
`
`
`Also Present:
` Lucien Newell, Legal Video Specialist
` Johanna Lopez, Legal Video Specialist
` Jerry Buttler, Planet Depo (Via Zoom)
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` UNITED STATES DISTRICT COURT
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` FOR THE EASTERN DISTRICT OF MICHIGAN
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` SOUTHERN DIVISION
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`
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`In Re: NEO WIRELESS, LLC ) Case No.
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`PATENT LITIGATION ) 2:22-MD-03034-TGB
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`______________________________)
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`Case 2:22-md-03034-TGB ECF No. 255-16, PageID.19447 Filed 06/20/24 Page 3 of 46
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` DEPOSITION OF KEMIN LI, Ph.D.
`
` Taken Friday, June 30, 2023
`
` At 9:13 A.M.
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` At 46100 Landing Parkway
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` Fremont, California
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`Stenographically Reported by: DONNA J. RUDOLPH,
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`RPR, CA. CSR NO. 9652, NV. CCR NO. 420, WA. NO.
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`22005830, UT. NO. 12708017-7801
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`2
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` I N D E X
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`KEMIN LI, Ph.D.
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` Page
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`By Mr. Tapparo 7, 141
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` E X H I B I T S
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`Number Description Page
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`Exhibit 1 U.S. Patent No. 8,467,366,
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` issued 6/18/13 15
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`Exhibit 2 U.S. Patent No. 10,833,908,
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` issued 11/20/20 15
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`Exhibit 3 U.S. Patent No. 10,075,941,
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` issued 9/11/18 15
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`Exhibit 4 U.S. Patent No. 10,965,512,
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` issued 3/30/21 15
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`Exhibit 5 U.S. Patent No. 10,771,302,
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` issued 9/8/20 15
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`Exhibit 6 LinkedIn profile of Kemin Li,
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` Ph.D. 32
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`Exhibit 7 U.S. Patent No. 6,947,748 55
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` DEPOSITION OF KEMIN LI, Ph.D., taken at
`
`46100 Landing Parkway, Fremont, California, on
`
`Friday, June 30, 2022, at 9:13 A.M., before Donna J.
`
`Rudolph, RPR, Certified Shorthand Reporter, in and
`
`for the State of California.
`
`
`
`APPEARANCES:
`
`For NEO WIRELESS, LLC:
`
` CALDWELL CASSADY & CURRY
` BY: CHRISTOPHER S. STEWART, ESQ.
` ALEX GRAS, ESQ.
` 2121 North Pearl Street
` Suite 1200
` Dallas, Texas 75201
` (214) 888-4848
`
`
`
`For FCA US, LLC:
`
` VENABLE LLP
` BY: ROBERT C. TAPPARO, ESQ.
` JONATHAN L. FALKLER, ESQ. (Via Zoom)
` 600 Massachusetts Avenue, NW
` Washington, DC 20001
` (202) 344-4000
`
`
`For KEMIN LI, Ph.D.:
`
` GOLDFARB & HUCK ROTH RIOJAS, PLLC
` BY: CHRISTOPHER M. HUCK, ESQ.
` 925 Fourth Avenue
` Suite 3950
` Seattle, Washington 98104
` (206) 452-0260
` (Via Videoconference)
`
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`

`

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`Transcript of Kemin Li, Ph.D.
`Conducted on June 30, 2023
`5
` FREMONT, CALIFORNIA; FRIDAY, JUNE 30, 2023
` 9:13 A.M.
`
` THE VIDEOGRAPHER: Here begins media
`number one in the videotaped deposition of Kemin Li
`in the matter of In Re Neo Wireless, LLC, patent
`litigation in the United States District Court for
`the Eastern District of Michigan, Southern Division,
`case number 22-MD-03034-TGB [sic].
` Today's date is June 30th, 2023. The time
`on the video monitor is 9:13 A.M. Pacific Standard
`Time. The videographer today is Lucien Newell
`representing Planet Depos. This video deposition is
`taking place at 46100 Landing Parkway, Fremont,
`California.
` Would counsel please voice identify
`themselves and state whom they represent.
` MR. TAPPARO: Robert Tapparo of Venable,
`LLP, representing FCA US LLC. And with me today is
`my colleague Jonathan Falkler on the Zoom.
` MR. STEWART: Chris Stewart of the firm
`Caldwell Cassady Curry, PC, on behalf of the
`plaintiff, Neo Wireless, as well as the witness
`Dr. Kemin Li. And with me is my colleague Alex Gras
`of my firm.
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` EXAMINATION
`BY MR. TAPPARO:
` Q All right. Dr. Li, good morning.
` A Good morning.
` Q Thanks for being here.
` A Thank you.
` Q Now I know this is not everybody's
`favorite activity. But before we get started today,
`there's just a few things that I want to go over
`just so we have a, you know, nice, smooth deposition
`with no issues.
` So I'm going to be asking questions today,
`and you're going to be answering those questions
`under oath.
` A Okay.
` Q Do you understand?
` The court reporter today will be writing
`everything down, so I ask that we just try not to
`speak over each other. So I'm going to ask a
`question, and if you would let me fully ask my
`question before you answer, and I will also try to
`let you fully answer before -- before I pick back up
`again.
` Does that make sense?
` A Yeah, sure.
`
`2 (5 to 8)
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` Q Great.
` It's also important that you answer
`audibly because there is a typed transcript today.
`So head nodding or "hm-hms" don't necessarily get
`picked up by the court reporter. So if you could
`just use "yes" and "no" when answering yes/no
`questions that'd be appreciated.
` A Yes.
` Q Does that make sense? Great.
` If I ask anything that's unclear to you,
`0
`please ask me to either rephrase or tell me that you
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`don't understand, and I'll try to ask the question
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`in a more understandable way. Is that --
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` A Yes.
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` Q Does that work?
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` Great.
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` A I understand.
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` Q And I plan to take breaks periodically,
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`maybe every -- ever hour just, you know, because
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`it's kind of hard sitting here for that long. If
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`you ever need a break, I ask that you just let me
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`know, and we'll take a break. But we'll just finish
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`that question and answer before we break. Does that
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`make sense?
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` A Yes.
`25
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
` THE VIDEOGRAPHER: Okay. The court
`reporter today is Donna J. Rudolph representing
`Planet Depos.
` The witness will now be sworn.
`
` KEMIN LI, PH.D.,
`called as a witness, being first duly sworn to tell
` the truth, the whole truth, and nothing but the
` truth, testified as follows:
`
` MR. JERRY BUTLER: Apologize for the
`interruption. We have a number of attorneys also on
`the Zoom call. Do we want to have them also
`identify who they are?
` MR. STEWART: It's fine for us --
` MR. TAPPARO: Yes.
` MR. STEWART: -- if they just identify by
`their appearances in the chat, we don't need to go
`through every single one as far as the plaintiff is
`concerned and Dr. Li is concerned.
` MR. TAPPARO: We agree.
` MR. JERRY BUTLER: Thank you.
`/ / / /
`/ / / /
`/ / / /
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`Case 2:22-md-03034-TGB ECF No. 255-16, PageID.19448 Filed 06/20/24 Page 4 of 46
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`

`

`Transcript of Kemin Li, Ph.D.
`Conducted on June 30, 2023
`9
`
`3 (9 to 12)
`
`11
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` Q Yes.
` You mentioned that you searched for
`documents in response to the subpoena.
` A Uh-huh.
` Q Did you find any documents in response to
`that subpoena?
` A No.
` Q No. Okay.
` So were -- is it fair to say all the
`documents that you reviewed today were provided by
`your attorneys?
` A That's correct.
` Q Okay. You mentioned searching for
`documents before. How did you search for these
`documents?
` A I search for my computer.
` Q Okay.
` A I search for my e-mail and also I search
`for, like -- I -- typically, I put my paper -- paper
`file -- paper documents.
` Q Okay. So you mentioned your computer. Is
`this a computer that you've had for a long time? Is
`this --
` A I typically change computer, like, every
`three, four years.
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` Q Great.
` Is there any reason that you cannot
`provide truthful testimony today?
` A No.
` Q Great.
` Have you ever been deposed before?
` A This is actually my first time. No.
` Q First time?
` A Yeah.
` Q Great.
` What did you do today to prepare for this
`deposition?
` A That's actually -- let me -- it's not a
`yes/no answer.
` Q Correct. Just answer fully.
` A I guess like, one, is I search for the
`document -- documents the subpoena requested.
` Q Good.
` A And I also discussed the matter with my
`attorney.
` Q Did you speak with anybody else aside from
`your attorneys to prepare for the deposition today?
` A No.
` Q How long roughly did you meet with your
`attorneys when preparing?
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` A How long roughly? A few hours maybe.
` Q Okay.
` A Yeah.
` Q Like three hours? Five hours?
` A Maybe -- actually, I -- maybe three to
`five. I think that's probably right.
` Q Okay. Great.
` Did you review any documents to prepare
`for the deposition today?
` MR. STEWART: I would just answer that
`"yes" or "no."
` THE WITNESS: Yes.
`BY MR. TAPPARO:
` Q Do you have an estimate of how many?
` A The number of documents?
` Q Yeah.
` A Probably 10 to 20.
` Q Okay. You mentioned earlier that you
`searched for documents in response to the subpoena?
` A Yes.
` Q Did you find those documents yourself, and
`were those the types of documents that you reviewed
`in preparation for the deposition today?
` A That's actually a long question. Can you
`say it again.
`
` Q Okay. Do you bring the files -- every
`time you switch computers, do you bring the files
`from the last computer and put them on the new
`computer?
` A Yes.
` Q Okay. Would you say that you've lost any
`documents in the last 20 years when you've been
`switching computers?
` A Oh, I -- I wouldn't characterize as a
`loss. Sometimes, like -- can I elaborate?
`0
` Q Yeah.
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` A So, like -- sometimes, like, if I put some
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`personal information which is important, I always
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`try to keep them. And there are some information I
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`consider not usable anymore, so I would just don't
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`keep them, I guess.
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` Q Okay. You mention you searched your
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`e-mail.
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` Did you search a personal e-mail address
`19
`or a work e-mail address?
`20
` A I actually -- right now, I only have --
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`have two e-mail address. Like, one is my personal;
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`one is my current employer --
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` Q Okay.
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` A -- which I don't think has anything to do
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Case 2:22-md-03034-TGB ECF No. 255-16, PageID.19449 Filed 06/20/24 Page 5 of 46
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`

`

`Transcript of Kemin Li, Ph.D.
`Conducted on June 30, 2023
`13
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`4 (13 to 16)
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`named inventor on, against various different
`defendants?
` A I think this is actually, like, this
`contain multiple question. Like, I'm aware of this,
`like, lawsuit, but actually, I don't know how
`patents I was involved in.
` Q Okay. Great. Well, I'm going to
`introduce some documents right now. And then we'll
`go from there.
` (Exhibits 1 through 5 marked.)
`BY MR. TAPPARO:
` Q All right. So, Dr. Li, I just put five
`patents in front of you. On each of the five
`patents, you're a named inventor. So we're just
`going to go through these really quickly at a high
`level.
` A Okay.
` Q So if you could pick up the --
` A First one?
` Q -- first one labeled. It has a 1 in the
`bottom corner.
` A Yes, yes.
` Q This is -- can you read me the patent
`number in the front.
` A Okay. That's 8,467,366.
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`with this lawsuit. Right? And I don't have any
`access to my previous -- any employees' work e-mail.
` Q Of course.
` And just to confirm, did you find any
`e-mails in your personal e-mail that were relevant
`to the subpoena?
` A No.
` Q Okay. Did you bring any documents with
`you today?
` A No.
` Q Okay. Is there any documents or
`information that you wanted to review to prepare for
`the deposition today but that you weren't able to?
` A Frankly, I don't have any document I'd
`want to review because basically, like, I just want
`to, like, state one fact. Like, I move -- I change
`my technical field, like, ten-plus years ago.
` Right now, I'm working, like, big data and
`cloud computing, so I have no actually personal
`interest in any documents in that sense, yes.
` Q Totally understand.
` Do you understand why you're being deposed
`today?
` A Roughly, yes.
` Q Can you explain.
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` Q Great.
` And let's flip over the first page to the
`back of the first page.
` A Okay.
` Q And I'm going to direct you to -- there's
`a little 75 in the top left corner.
` A Seventy-five, top left. Okay, I saw that.
` Q Great.
` And you see next to that your name, Kemin
`Li?
`0
` A Yes.
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` Q Do you recognize this document at all?
`12
` A Frankly, I don't recognize this one. I --
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`I remember I -- like, there's some patents, yes, but
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`I didn't read them later, I guess.
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` Q Okay. But you do recall that you were a
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`named inventor on this -- on this patent? You see
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`your name?
`18
` A That's true.
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` Q Okay. But you don't remember anything
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`about this patent more than just a general
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`recollection?
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` A Yeah. That's many years ago, I guess.
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`Like, I -- yeah.
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` Q Okay. Did you review these patents before
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
` MR. STEWART: I would just caution you.
`You can state your understanding at a high level of
`your personal understanding, but don't reveal any
`conversations you had with attorneys.
` THE WITNESS: Okay. I guess, like, it's
`just, like, I think, based on the subpoena I read,
`about the document I could have had and also about,
`like, some -- some facts about this lawsuit, I
`guess.
` Q Okay. And what are those facts that
`you --
` A This I don't --
` (Reporter seeks clarification.)
` THE WITNESS: I guess one is about the
`document I was subpoenaed. And also, like, being
`question -- asked for the facts about -- that relate
`to this lawsuit.
`BY MR. TAPPARO:
` Q Do you know the nature of this lawsuit?
` A High level, yes.
` Q Okay. What is that?
` A Patent infringement, I suppose.
` Q Okay. Are you aware that Neo Wireless,
`the plaintiff in this case, is alleging infringement
`of multiple patents, five of which that you're the
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`Case 2:22-md-03034-TGB ECF No. 255-16, PageID.19450 Filed 06/20/24 Page 6 of 46
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`

`

`Transcript of Kemin Li, Ph.D.
`Conducted on June 30, 2023
`17
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`5 (17 to 20)
`
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` A I don't really remember, actually. Like,
`by reading the name, I only have kind of like a very
`abstract understanding of that subject matter.
` Q And can you describe that abstract
`recollection.
` A Yeah. Actually, I can't tell right now,
`actually. That's many years ago. Sorry.
` Q Okay. So you don't remember anything more
`than just a -- anything more than that? That --
` A That's correct. That's probably true,
`yes.
` Q Okay. Let's put this one down again.
` A Okay.
` Q We're going to go to the next one that has
`a 3 I think she wrote on the bottom?
` A Yes, yes, yes.
` Q Great.
` Can you, again, read me the patent number
`on the front of this one.
` A 10,075,941.
` Q All right. We're going to go to the next
`page again. This time it has a 72 right next to the
`top left.
` A Yes, yes, yes.
` Q Is that your name, Kemin Li, right next to
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`your deposition today?
` A No.
` Q Okay. Are there any patents that you are
`a named inventor on, any other ones that you do
`recall more specifically?
` A Sorry. I don't remember.
` Q Okay. Do you have a general understanding
`of the subject matter of this patent?
` A At high level, yes.
` Q All right. Can you explain.
` A Like this -- this is about, like, wireless
`communication and, like, we use multi-carrier
`methods to transmit data for specifically --
`actually, I don't remember.
` Q And what is a multi-carrier method?
` A Multi- --
` MR. STEWART: Object to form.
` THE WITNESS: Multi- -- actually, at high
`level, a multi-carrier is like you transmit signal
`using multiple frequency bands.
`BY MR. TAPPARO:
` Q Okay. Can you give me an example.
` A OFDM, I suppose.
` Q Okay. All right. Let's put that one
`aside right now. And we're going to go with the one
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`it?
` A Yes.
` Q So you're a named inventor of this patent?
` A Yes.
` Q And do you recall anything about this
`patent?
` A Let me read the name first. That's
`probably very high level, actually. I don't
`remember any details.
` Q What's your high-level recollection?
`0
` A So basically, like, wireless channel is
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`kind of like an ever-changing time variant channel.
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`So basically, like, they probably relate to somehow
`13
`adapt to the channel. That's -- that's about it, I
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`can remember.
`15
` Q Okay. We can go to the next one. This
`16
`one's number 4.
`17
` A Okay.
`18
` Q Can you read me the patent number on the
`19
`front of this exhibit.
`20
` A Yes, 10,965,512.
`21
` Q Great.
`22
` And then, again, next to the 72, you see
`23
`your name next to it, Kemin Li?
`24
` A Yes.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`with a 2. You can just put it right in front of
`you. We're going to refer back to those later.
` A I see.
` Q And that one, can you read me the patent
`number on the front.
` A It's 10,833,908.
` Q Great. And then, again, we're going to go
`to the back of that first page.
` A Okay.
` Q And I'm going to direct you to the little
`number in the top left that says 72.
` A Yes.
` Q And you see next to that, your name, Kemin
`Li?
` A Yes.
` Q Do you recall this patent?
` A No.
` Q No?
` A No.
` Q We're going to go through the same
`questions we just did.
` A Okay.
` Q So can you -- do you have any recollection
`of the subject matter of this patent, generally
`speaking?
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`Case 2:22-md-03034-TGB ECF No. 255-16, PageID.19451 Filed 06/20/24 Page 7 of 46
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`Transcript of Kemin Li, Ph.D.
`Conducted on June 30, 2023
`21
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`6 (21 to 24)
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` A The law firm, I suppose.
` Q Besides -- besides the law firm.
` A Okay. I don't know, actually, this
`company. I don't even know where it is. Like, I
`don't know anything about this company.
` Q Okay. Have you ever -- so you've never
`acted as a consultant for Neo Wireless?
` A Well, like, I -- just for this deposition,
`I, like, consultant for the law firm. So I don't
`know whether this is Neo Wireless or not, actually,
`for the law firm.
` Q So you've been retained as a consultant
`for the law firm --
` A For the law firm, yes.
` Q -- Caldwell Cassady?
` A Yes.
` Q Specifically related to this litigation?
`You don't need to describe anything specific.
` A I believe so.
` Q Okay. Do you have any financial interest
`in Neo Wireless?
` A No.
` Q Do you have any financial interest in any
`of the five patents that we just looked at?
` A No. I think -- can I just, like,
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` Q So you're a named inventor of this patent,
`the 512 patent?
` A From the document? Yes.
` Q Great.
` And do you recall anything specific or
`anything about this patent?
` A I guess, again, at high level, actually.
`No details. High level, yes.
` Q And what's your high-level understanding?
` A So basically, like, OFDM system need some
`kind of like synchronization between base station
`and terminal. So I believe, like, pilot carrier was
`used for that purpose.
` Q Okay. And we're going to go into more
`detail later on these, but I'm just going to get
`these introduced, and then we'll come back to them,
`if that works.
` A Okay.
` Q Final patent that we're going to go over
`today. Can you read the patent number on the front
`of this one.
` A 10,771,302.
` Q Great.
` And, again, next to the 72 on the next
`page, you see your name next to that, Kemin Li?
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` A Yes.
` Q So you're a named inventor of this patent,
`10,771,302?
` A Yes.
` Q And do you have any specific recollection
`of this patent?
` A Actually, for this one, I don't recall at
`high level, actually. So -- for this one, channel
`probing was -- yeah, I don't want to guess. Like, I
`don't remember actually, yeah.
` Q Of course. Great.
` Are you familiar with the plaintiff, Neo
`Wireless, in this case?
` A No. Actually, first time, like, things I
`see, see the subpoena.
` Q That was the first time you've heard of
`the company Neo Wireless?
` A That's true.
` Q So you have no other relationship with Neo
`Wireless, except for the subpoena that you received?
`That's the only experience you have with this
`company?
` A I would say yes.
` Q Okay. Are you familiar with any other
`entities that might be related to Neo Wireless?
`
`elaborate a little bit more?
` Q Yeah.
` A Because, like, for all the companies I
`worked for, the understanding is basically, like,
`the patent relate to the job belong to the company.
` Q Okay.
` A So that's why, like, there's no -- like,
`after I leave this company, then nothing -- that's
`why I don't read it and don't -- not interested in
`any respect.
`0
` Q I totally understand.
`11
` A Yeah.
`12
` Q Are you being compensated in any way for
`13
`your testimony today?
`14
` A No.
`15
` Q So you're not being paid to be here?
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` A No.
`17
` Q Okay.
`18
` A Oh, actually, like, I was paid by --
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`80-some dollars by -- by the -- your firm maybe, I
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`think.
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` Q You were paid $80.00 to be here?
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` A 82- or 80-something, I think. Like, I
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`think there's a check associated with the subpoena.
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`I don't know whether this is for my search document
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`Case 2:22-md-03034-TGB ECF No. 255-16, PageID.19452 Filed 06/20/24 Page 8 of 46
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`

`

`Transcript of Kemin Li, Ph.D.
`Conducted on June 30, 2023
`25
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` A Neo Wireless?
` Q Yes.
` A No, I don't know anything about Neo
`Wireless.
` Q So you've had no involvement with the
`patents in this case that were filed by Neo Wireless
`that list you as a named inventor?
` A This I cannot say because I don't know
`what kind of patent are they. Like, I don't know,
`actually.
` Q Okay. Well, we're going to go over some
`today that were filed by Neo Wireless that have your
`name on them. But now, we're going to turn to a few
`other companies.
` A Okay.
` Q Have you heard of the company Neocific?
` A This I know, yes.
` Q And can you describe your understanding of
`that company.
` A I never work for Neocific. I guess, like,
`I think, like, I work for Walbell. And Neocific
`is -- they have the same owner, I guess. Like,
`that's the only thing I know. I don't know anything
`about their relationship.
` Q And who are the owners of Walbell and
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`or, like, for this deposition. Actually, I don't
`know. Like, that's the only thing I got paid.
` Q Okay. And you received the check from
`whom?
` A I think DLP -- I think from the plaintiff.
`I forgot, like, the -- the company serve the
`subpoena.
` Q Okay. Outside of your testimony here
`today, have you had any other involvement with this
`litigation?
` A No.
` Q Are you a named inventor on any other
`patents besides these five patents?
` A I think this question's probably yes. I
`worked in China for a couple of years. So over
`there, I might have some, like, patent. But I don't
`remember, actually.
` Q Do you have an estimate of how many
`Chinese patents you would have?
` A I don't recall number. But, like, it
`should be between, like, one to five, something like
`that.
` Q Okay.
` A Low, single digit.
` Q And what about any U.S. patents? Any
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`other ones besides these five?
` A I don't recall, actually.
` Q You don't recall?
` A I don't keep track of those because, like,
`after I leave the company, it has nothing to do with
`me, I guess.
` Q I understand.
` Can you describe the subject matter
`generally of the Chinese patents that you
`referenced?
` A It's about communication system over
`coaxial cable.
` Q Okay.
` A So I -- I don't remember the specifics,
`like, but basically we -- we kind of like use
`existing technology. We made some improvements to
`make the communication a little more reliable.
` Q And where were you employed when you --
`when you were -- when you were --
` A It's called Laketune Technologies in
`China.
` Q Laketune Technologies?
` A Laketune Technologies, yes.
` Q Did you know that Neo Wireless has filed
`many applications with your name on them?
`
`Neocific?
` A Alex Li.
` Q Okay. Anybody else?
` A Actually, I don't know, actually. This is
`the only one I know.
` Q Okay. And can you describe any
`involvement that you've had with Neocific?
` A Not really. I work for Walbell. I was
`employed by Walbell. So I don't have, like,
`involvement with, like, Neocific.
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` Q So you've never worked for Neocific?
`11
` A I never worked for Neocific.
`12
` Q Okay. And never Neo Wireless?
`13
` A Never Neo Wireless.
`14
` Q Do you know if there's a relationship
`15
`between Neocific and Neo Wireless?
`16
` A There might be, actually. I don't know
`17
`the exact nature of their relationship. I only knew
`18
`about Neo Wireless from the subpoena.
`19
` Q Okay. Neo Wireless sounds pretty similar
`20
`to Neocific, but you don't know if there's any --
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` A I don't know. That's true.
`22
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`Case 2:22-md-03034-TGB ECF No. 255-16, PageID.19453 Filed 06/20/24 Page 9 of 46
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`

`Transcript of Kemin Li, Ph.D.
`Conducted on June 30, 2023
`29
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`8 (29 to 32)
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`let me try to just try my best understandings.
`Like, I have contact with Alex for sure, and not in
`the general area of, like, wireless communication.
`But regarding this patent, I believe it is possible.
`Like, for example, he may, like, just discuss, like,
`some -- some, like, related to maybe filing or
`something. It is possibly, I guess.
` Q Okay. And what would those conversations
`be about?
` MR. STEWART: Object to form.
` THE WITNESS: I don't remember, but it
`could be filing or maybe some specific stuff. I
`don't remember, actually, so --
`BY MR. TAPPARO:
` Q Okay. Can you describe your educational
`background.
` A Like, I -- my -- I have, like -- I was
`mostly in electrical engineering for my bachelor,
`master, and Ph.D., all in electrical engineering.
`And my -- like, before my Ph.D., I was more in,
`like, optical communication area, and my Ph.D. was
`wireless communication.
` Q Okay.
` A Yeah.
` Q Any specific aspects of wireless
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`BY MR. TAPPARO:
` Q Do you know how the patents that you are
`named inventor on came to be owned by Neo Wireless?
` A I think roughly, like, by acquisition of
`some kind, but I don't know the details, like,
`because the patent does not belong to me, so I don't
`know the exact nature of this relationship.
` Q So as soon as -- so what you're saying, if
`I'm understanding correctly, is as soon as you left
`Walbell Technologies, you had no more contact with
`anybody in relation to the patent applications that
`were filed that came to be these five patents?
` A Well, actually, this -- I'm not sure.
`Like, I have contact with, like, Alex.
` Q Okay.
` A And Alex I think mostly. Whether we
`discussed this patent, like, after I left or not, I
`don't remember. Like, I -- I would say, like, we
`are in good terms. So, like, if he had any support
`needed, I would happily to do that, like, but I
`don't remember whether there's such occasion or not.
` Q You just mentioned that you have had
`contact with Alex. That's Alex Li?
` A Alex Li, yes.
` Q Okay. And can you describe those contacts
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`that you've had?
` A You mean -- well, that's many years. Can
`you more specific.
` Q Let's start from the beginning. You know,
`as soon as you left Walbell Technologies, did you
`have contact with Alex Li?
` A Yeah, like, I think we are coworker. He
`is my boss. We are in good relationship. So we --
`we, like, talk from time to time. Like, for
`example, if I visit Seattle, I will try to contact
`him to see whether there's time for dinner or lunch
`sometimes, I guess, like this.
` Q Aside from social contacts, did you have
`any contacts about work or wireless communications
`or --
` A Not wireless communication because I -- I
`kind of like move away from wireless to this cable
`product. But I think if he, for example, discuss
`this patent, that's possible. But I don't remember,
`actually.
` Q Okay. So you have no specific
`recollection since you left Walbell Technologies of
`any contacts with Alex Li about these -- any patents
`that were filed?
` A I would say possible -- well, actually,
`
`communication that you focused on during your Ph.D.?
` A It's called CDMA.
` Q Okay. More exhibits.
` (Exhibit 6 marked.)
`BY MR. TAPPARO:
` Q So, Dr. Li, do you recognize this -- this
`document in front of you?
` A Yes.
` Q And what i