In The Matter Of:
`
`APPLE, INC.
`
`v.
`
`SIGHTSOUND TECHNOLOGIES, LLC
`
`IOHN P. ]. KELLY, Ph.D. - Vol. 1
`
`December 4, 2013
`
`Fax: “535?,d30‘é
`
`MERRILL EflHFOHflTIflH
`
`LegaLlnl-u, Inc.
`
`135 Maia“) Street
`4th F1043:
`San Franeism. CA 94105
`Phana: «1133534300
`
`SIGHTSOUND TECHNOLOGIES
`EXHIBIT 2126
`
`CBM2013-00020 (APPLE v. SIGHTSOUND)
`PAGE 000001
`
`
`
`APPLE, INC.
`
`v.
`
`SIGHTSOUND TECHNOLOGIES, LLC
`
`IOHN P. ]. KELLY, Ph.D. - Vol. 1
`
`December 4, 2013
`
`Fax: “535?,d30‘é
`
`MERRILL EflHFOHflTIflH
`
`LegaLlnl-u, Inc.
`
`135 Maia“) Street
`4th F1043:
`San Franeism. CA 94105
`Phana: «1133534300
`
`SIGHTSOUND TECHNOLOGIES
`EXHIBIT 2126
`
`CBM2013-00020 (APPLE v. SIGHTSOUND)
`PAGE 000001
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`(2001—454287)
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`RADEMARK Oh'h' C'.
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` D APB
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` *ZAT.
` %OAR
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`VS.
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`:GHTSOUN
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`
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`Petitioner,
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`
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`
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`?CHNOLOG
`
`Responde
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`
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`
`
`
`
`3M2013—00020,
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`Patent 5,191,573
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`3M2013—00023,
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`Patent 5,966,440
`
`
`
`
`
`
`fiBOS i
`
`D
`
`JOHN P. J. K
`
`
`
`
`
`
`
`Wednesday,
`
`
`December 4,
`
`2013
`
`
`
`
`
`
`
`
`
`
`
`ERSON, CSR 4096
`
`PAGE 000002
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`JOHN P. J. KELLY, Ph.3.
`
`—
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`12/4/2013
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`Page 2
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` BY MR. MARSH
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`
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`
`
`
`
`Description
`
`
`
`
`Bxhibit
`ll32 Dec'aration of Dr.
`
`
`
`
`
`
`
`Inc.'s
`Kel'y "q Supporc O.
`Petition For Covered Business
`
`
`ethod Pacenc Review Of United
`
`
`
`States Pacenc No. 5,19;,573
`Pursuant To 35 J.S.C. Section
`
`
`
`
`
`32;, 35 C.F.R Section 42.304
`
`
`
`
`
`
`
`lO5l Dec'aration of Dr. Joqn P. p.
`
`
`
`
`
`
`Ke"y "a Support O" Apple "rc.'s
`Petition For Covered Business
`
`
`Method Pacenc Review Of United
`
`
`
`
`States Pacenc No. 5,19;,573
`Pursuant To 35 J.S.C. Section
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`
`
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`Bxhibit
`
`
`Exhibit
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`.
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`
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`32;, 35 C.F.R Section 42.304
`
`
`Dec'aration of Dr.
`
`
`
`"rc.'s
`Ke"y "q Supporc O
`Petition For Covered Business
`
`
`
`ethod Pacenc Review Of United
`
`
`States Pacenc No. 5,996,440
`Pursuant To 35 U.S.C. Section
`
`
`
`
`
`
`
`
`
`
`
`
`
`321, 35 C.F.R Section 42.304
`
`
`Artic'e in Bi"board
`
`Artic'e in Bi"board
`
`
`Bxcerpt
`
`
`
`‘
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`
`Billboard
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`(800) 869—9132
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`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
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`PAGE 000003
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`Dear
`TTR:1}{P}
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`Sing'e—Page Documeno co Dear
`Shareholder dated 7/l6/8T
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`JOHN P. J. KELLY, Ph.3.
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`—
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`12/4/2013
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`Page 3
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`?Xcerpt
`‘
`Rillboard
`
`One—Page R'oc< Diagram
`
`One—Page R'oc< Diagram
`
`
`?Xcerpv
`rom RroadcaS" Managemen'
`Engineering
`
`
`
`
`rom Rroadcas' Managemen'
`?xcerpv
`Engineering
`
`
`Transcription 0: Audio
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`.exis—Nexis Document dated
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`Wovember ‘7,
`'98?
`
`.exis Nexis Article dated
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`Wovember ‘7,
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`'98?
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`
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`Sing'e—Page Documeno
`Shareholder dated 7/;
`
`
`——oOo——
`
`igh Speed
`Article entitled A
`
`
`Telecommunications "nter‘ace For
`
`Digital Audio Transrission And
`
`Reception
`
`
`?xhibit
`
`l3l7 Article entitled A Pigh Speed
`
`Telecommunications "nter‘ace For
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`Digital Audio Transrission And
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`Reception
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`(800) 869—9132
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`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
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`PAGE 000004
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`JOHN P. J. KELLY, Ph.3.
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`—
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`12/4/2013
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`Page 4
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`{fl Bfii
`i ONfiR:
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`ROPES & GRAY
`
`
`1211 Avenue Of The Americas
`
`
`
`10036— 8704
`Wew York, New York
`
`
`
`
`
`
`BY:
`CH NG— T.tfi hUKUDA, ESQ.
`212— 596— 9000
`
`ching—lee.fukuda@ropesgray.com
`
`ROPES & GRAY
`
`
`
`
`
`
`
`
`1900 University Avenue, 6th Floor
`
`
`
`Eas: Palo Alto, Ca i"ornia
`94303—2284
`
`
`RY:
`TAUREW N. ROR NSON, ESQ.
`650— 617—4077
`
`laureq.robinson@ropesgray.com
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`
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`FOR iHfi RfiSBONDEWi:
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`ARNO. D & PORTER .T.P
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`
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`555 12Lh Saree N. W.
`
`Washingtoq, DC 20004
`
`
`
`
`BY:
`DAV-D R. MARSH Ph. D
`202— 942— 5068
`
`david.marsh@aporter.com
`
`——oOo——
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`(800) 869—9132
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`Merrill Corporation — San Francisco
`www.merrillcorp.com/1aw
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`PAGE 000005
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`a Cerci_ied Shorthand Reporter
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`personally appeared
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`
`. J. KELLY, Ph.3.
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`——oOo—— . DANl, who, having been
`
`JOHN P. J. K
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`
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`ELLY, Ph.3.
`
`—
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`12/4/2013
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` -% '.
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` 1 RfiMfiM%fiR
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`:3 that pursuant
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`to notice and
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`Page 5
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`on Wednesday,
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`4, 2013 commencing at 8:05 A.M.
`
` December
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`
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`at the Law 0
`”ices of ROPRS & GRAY, 1900
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`
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`c Palo Alto,
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`
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`California, before
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`
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`
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`thereof,
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`
`University Avenue, Eas
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`me,
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`Corey W. Anderson,
`
`and Realtime Reporter,
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` JOiN P
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`1d testified as
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` follows:
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`called as a witness by the
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`first duly sworn, was exami
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`(800)
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`869—9132
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`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
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`PAGE 000006
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`JOHN P. J. KELLY, Ph.D.
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`—
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`12/4/2013
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`Page 6
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`EAST PALO AnTO, CAL PORN A
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`
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`Wednesday, December 4, 2013
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`8:05 A.M.
`
`——oOo——
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`
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`1
`1 D
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`N G S
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`P R O C
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`JOHN P. J. KH.LY, Ph.3.
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`
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`having been sworn by the Reporter,
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`
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`testified as follows:
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` lNfiSS:
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`do.
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`BY MR. MARSi:
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`
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`Could you state your name?
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`John Kelly.
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`
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`Pave you b
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`n d pos d b i
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`have.
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`You understand that you are
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`'Iying today
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`under oath just as would you in a cour
`'aw?
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`I do understand that.
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`
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`A.
`
`Q.
`
`my question.
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`I will ask you qaestions and your answers are
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`
`
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`being recorded by the court reporter.
`"" you don't
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`
`
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`understand my questions, please let me know and I will
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`explain or rephrase them.
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`_ you have a question, please ask it.
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`don't have a question I will assume you have unders
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`(800) 869—9132
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`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
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`PAGE 000007
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`JOHN P. J. KELLY, Ph.3.
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`—
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`12/4/2013
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`Page 7
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`Is that jair?
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`
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`(Witness nods head).
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`
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`"I at any time you need a break just let me
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`A.
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`Q.
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`know.
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`
`I
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`just ask that you don't take a break while a
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`response is —— while a question is pending.
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`Any reason why you cannot give your best
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`testimony today?
`
`A.
`
`No.
`
`Q.
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`Are you sick or taking any drugs?
`
`
`take asthma medication, but it doesn't
`I
`A.
`
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`
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`testimony.
`
`
`I
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`take no other drugs.
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`
`You are president 0:
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`the the Kelly Technology
`
` Is that correct?
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` That's correct.
`
`How many employees?
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`A.
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`Q.
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`We have eight employees currently.
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`How many employees of Kelly Technology Group
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`have worked on this matter beyond yourself?
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`MS. FUKUDA: And just object to that.
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`Can we
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`
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`covered business methods patent review, one other
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` fine what "this matter" is?
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`
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`BY MR. MARSi:
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`
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`Q.
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`A.
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`You can answer the question.
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`Assuming we are talking about
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`the —— the
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`(800) 869—9132
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`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
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`PAGE 000008
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`JOHN P. J. KELLY, Ph.3.
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`—
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`12/4/2013
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`Page 8
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`employee.
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`Q.
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`A.
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`Q.
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`A.
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`T—r—i—a—l.
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`Has any other employee helped you?
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`(No response)
`
`
`What is the name of that employee?
`
`Alain Trial, spelled A—l—a—i—n, Trial,
`
`Q.
`
`Has any other employee helped you regarding
`
`the testimony you are going to give today or the
`
` testimony you have provided in your declaration?
`
`A.
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`I don't believe so.
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`
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`It's possible tha
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`
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`was a minor assistance from another employee, bu'
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`
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`I don't recall that having happened.
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`Who woald be that other employee?
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`
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`What did you bring with you today?
`
`
`
`sit here,
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`Q.
`
`A.
`
`Q.
`
`I'm nOt sure.
`
`
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`Is there anything that you could look at to
`
`
`fresh your reco"ection?
`
`A.
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`
`In my 0
`
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`1C8 " could look
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`—— at our records
`
`and determine that.
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`
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`Did you bring any records or papers with you
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`well, no —— no records from my
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`"ice.
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`The kind 0:
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`records that I was thinking about
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`when I answered your last question,
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`I don't have those
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`
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`with me.
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`Q.
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`(800) 869—9132
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`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
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`PAGE 000009
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`JOHN P. J. KELLY, Ph.3.
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`—
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`12/4/2013
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`Page 9
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`
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`brought with me the declarations that ——
`
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`that I prepared in the PTO action that we are talking
`
`about,
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`the covered business method patent review.
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`
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`brought those.
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`And I also brought excerpts from the exhibits
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`
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`had referenced in the declarations.
`
`Q.
`
`Thank you. Any of your other employees
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`working on any matters related to the SightSound
`
`
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`patents?
`
`A.
`
`Q.
`
`
`I don't believe so.
`
`How much time was spent by Others on preparing
`
`
`
`:or the, your declaration and the —— and evidence you
`
`
`are going to give today in the CBM matters?
`
`
`
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`couldn't say.
`
`A.
`
`
`
`Q.
`
`
`What percentage 0: his time does your employee
`
`Alain Trial spend on this matter?
`
`
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`
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`I really don't know how to answer that
`
`wh n w
`ar pr paring —— when ——
`
`A.
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`
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`Som
`question.
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`
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`right up to the time when I was working on this in May
`
`
`
`
`
`
`
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`was working on it
`
`'u'l
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`time and he was working on it
`
`
`probably sabstantial'y Sull
`time.
`
`
`
`Wow he is not working on it at all.
`
`Q.
`
`
`But how many months were you, were the two of
`
`
`
`you working on it :ull time?
`
`A.
`
`
`
`I —— as " sit here "
`
`
`firm recollection
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`(800) 869—9132
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`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
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`PAGE 000010
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`JOHN P. J. KELLY, Ph.3.
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`—
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`12/4/2013
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`Page 10
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`o:
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`
`
`: how much time I spent on this. Certainly some
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`time in April and certainly time in ear'y May.
`
`These
`
`declarations,
`
`
`
`I swore them on the 5th 0: May 0: this
`
`
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`year.
`
`
`
`
`
`%ut
`
`
`don't have a —— I don't have any better
`
`recollection than that.
`
`Q.
`
`When were you engaged by counsel
`
`in this
`
`matter?
`
`A.
`
`Q.
`
`A.
`
`And you are talking about ——
`
`The CBMS.
`
`
`
`The C3Ms?
`
`
`I had already been engaged by
`
`counsel for the SightSound district court litigation.
`
`
`
`
`i‘
`—— "'m not sure I can ——
`
`And so it was —— I mean,
`
`
`
`
`
`ngag m nL l
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`
`
`
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`
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`wasn't tqinking of it as now I was engaged for some new
`
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`So I don't have a —— I don't
`
`
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`SightSouqd V Apple matter.
`
`
`have any firm date in mind.
`
`Q.
`
`So it would be correct to say that you were
`
`
`not separately engaged Ior she CBM matters?
`
`
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`
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`MS. FUKUDA: Objeccion so jorm.
`
`
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`lHfi W lNfiSS: Well, no,
`
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`I wouldn't say that.
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`"n terms 0" —— well,
`
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`I guess it depends on what you mean
`
`by separately engaged.
`
`
`BY MR. MARSH:
`
`
`
`Q.
`
`
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`When you are engaged on a ma
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`typically have a writt n
`
`(800) 869—9132
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`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
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`PAGE 00001 1
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`JOHN P. J. KELLY, Ph.3.
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`—
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`12/4/2013
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`Page ll
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`NO.
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`a have a separate written engagement
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`3M matters?
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`
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`Again, when were yoa Iirsc contacted by
`
`
`
`
`I don't have any recolleCtion.
`
`
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`
`
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`
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`Do you separate out your billings jor
`
`Q.
`
`A.
`
`Q.
`
`counsel with respect to the CBM matters?
`
`know time—wise.
`
`matters versus the district court litigation in
`
`SightSound matter?
`
`A.
`
`No.
`
`Q.
`
`What have your total billings in the
`
`
`
`SightSound matter, matters been to date?
`
`
`
`
`
`
` couldn't tell you.
`
`tat else does the Kelly Technology Group do?
`
`
`ther than the SightSound matter?
`
`ther than the expert testimony work that you
`
`
`hold yoursel_ out
`
`to do.
`
`A.
`
`We do —— we do what you might consider to be
`
`
`
`traditional consulting, high—technology consulting. And
`
`we also do product development.
`
`
`
`Q.
`
`
`What percentage 0: your revenue is derived
`
`
`from expert testimony and related matters?
`
`A.
`
`
`I'm not sure revenue—wise.
`
`
`I mean,
`
`
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`
`
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`(800) 869—9132
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`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
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`PAGE 000012
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`JOHN P. J. KELLY, Ph.3.
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`—
`
`12/4/2013
`
`Page 12
`
`Q.
`
`
`What percentage of the Technology, Kelly
`
`Technology Group's work time—wise is devoted to expert
`
`testimony and related matters?
`
`
`
`A. Well,
`
`would see that as wider than expert testimony,
`
`
`if you take litigation support, and
`
`
`
`
`
`'m
`
`
`
`
`
`
`not sure I can break out expert testimony separately.
`
`But litigation support is around 50 percent
`
`
`_ wqao we do.
`
`
`
`
`
`
`
`Q.
`
`
`So 50 percent of all the time 0:
`
`
`
`employees?
`
`A. Well,
`
`
`
`I can spea< for the time, my time.
`
`
`
`
`not sure that —— I'm not sire how it translates to
`
`
`specific employees. And it certainly changes over time.
`
`When somebody is assigned to help me in a particular
`
`matter,
`
`
`they might be spending a hundred percent or
`
`
`their time for a week or more.
`
`Q.
`
`
`What percentage of that 50 percent, assuming
`
`
`
`
`that that 50 percent is as you de‘ined it previously,
`
`
`
`devoted to working on behal
`0 Apple?
`
`
`
`Depends on th tim fram w
`ar
`
`
`
`A.
`
`
`
`is
`
`talking about.
`
`
`
`
`
`Sometimes,
`
`
`like I can tell you,
`
`I can speak more
`
`
`accurately about my time, because I know exactly what
`
`
`
`am doing.
`
`
`
`
`And I mean,
`
`
`I can tell you that around about
`
`: May 0: this year when I was preparing these
`
`
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000013
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 13
`
`declarations it was close to a hundred percent. And
`
`recently it's been close to zero percent.
`
`Q.
`
`Year—to—date in 20l3, what percentage 0:
`
`
`
`time has been devoted to Apple related matters?
`
`
`
`
`
`A.
`
`
`
`I can't give you any firm numbers, but
`
`
`I could
`
`
`
`Who did you meet with?
`
`say that it probably is on the order or —— let me think
`
`
`
`
`abouc this Ior a minute.
`
`
`I can't give you any firm
`
`
`
`number.
`
` i mean,
`
`
`
`
`" was to guess,
`i‘
`
`
`I would say it
`
`would be around ten percent.
`
`Q.
`
`
`
`Do you review all 0:
`
`the invoices that Kelly,
`
`sorry,
`
`the Kelly Technology Group sends out?
`
`
`I do.
`
`A.
`
`Q.
`
`
`
`be able to determine wqat percentage 0" Kel'y Techno:
`
`
`
`
`
`Group revenue was due co Lestijying on beha'
`o
`or
`
`So based on those, you would have a —— wou:
`
`
`
`
`
`related to matters related to Apple?
`
`A.
`
`
`
`" cou'd determine how much revenue we ——
`
`
`
`mean,
`
`
`I can —— I can determine how much revenue, how
`
`
`
`much was invoiced to Apple.
`
`
`I can do that.
`
`
`I mean, not
`
`
`as I sit here, but we have those records.
`
`Q.
`
`Approximately how much time did you spend
`
`
`preparing for this deposition?
`
`
`Probably I would say about three days.
`
`A.
`
`Q.
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000014
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`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 14
`
`A.
`
`
`I met with, well, Alain Trial on an ongoing
`
`
`
`basis. And I met with Ms. Fukuda, Ms. Robinson, and
`
` Mr. 3atchelder.
`
`Q.
`
`Q.
`
`When did you meet?
`
`Yesterday.
`
` What other dates did you meet, meet with your
`
`(No response).
`
`Your legal team?
`
`And what do you mean by meet with the legal
`
`
`
`You testijied that you met with Ms. Fukuda,
`
`
`
`
`Ms. Robinson, and Mr. 3atchelder. When did you meet
`
`with Ms. Fukuda and Mr. 3atchelder?
`
`A.
`
`Yesterday.
`
`
`Did you meet with them on any other day?
`
`Well,
`
`
`I'm trying to understand what you mean
`
`
`Did you meet with them in person on any other
`
`
`
`those you recite in your declaration related to this
`
`\TO.
`
`
`
`
`Did you meet with them jor the ul' day?
`
`
`tqem :or tqe 'u'l day.
`
`
`A. With —— with some 0:
`
`
`
`
`
`
`Q.
`
`Have you read any additional materials beyond
`
`
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000015
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`
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`
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`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 15
`
`Since the
`
`
`
`l
`s rv d th d claration?
`
`
`
`
`
`looked a
`
`
`
`
`
`yes and no for now and I want
`
`
`just answer that
`MS. FUKUDA: Yeah. Dr. Kelly,
`
`
`to be care u'
`
`MR. MARSH: Sorry, you are not allowed to coach
`
`
`
`
`
` BY MR. MARSH:
`
`your witness.
`
`
`It's my deposition, not yours.
`
`So ——
`
`the witness.
`
`
`
`MS. FUKUDA: Well, actually,
`
`
`I'm not coaching
`
`
`I want
`
`
`to make sure that I get
`
`the chance
`
`
`
`to object to privilege.
`
`
`So if you ask a yes—or—no
`
`question,
`
`
`I
`
`just want
`
`to caution the witness ——
`
`your deposition.
`
`
`
`MR. MARSH: No, no.
`
`"5 Mr. Kelly has questions he can ask
`
`
`It's my deposition, not
`
`those questions.
`
`"‘ you want
`
`to object to privilege you
`
`can object to privilege.
`
`
`
`
`
`
`But let Mr. Kelly answer the question.
`
`Dr. Kelly ——
`
`
`
`S. FUKUDA:
`
`
`I am not preventing you
`
`
`
`
`answering the question. But keep ——
`
`MR. MARSl: Please ——
`
`MS. FUKUDA:
`
`
`
`I'm going to instruct my witness
`
`
`
`to give answers that are not privileged.
`
`
`
`
`R. MARSi: That's fine.
`
`
`
`s. FUKUDA: Okay.
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000016
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 16
`
`Mr. Kelly, please provide an answer.
`
`Would you repeat the question, please?
`
`Sure. Have you read any additional ma'
`
`
` :ter?
`
`those you recite in your declaration rela'
`
`Yes.
`
`What were those materials?
`
`MS. FUKUDA:
`
`
`I instruct the witness not
`
`to
`
`
`
`answer to the extent that material was provided by
`
`
`
`
`counsel for purposes 0" preparing ‘or this deposition.
`
`
`
`
`
`
`
`lHfi W lNfiSS:
`brie‘ly looked at the PTAB
`
`BY MR. MARSH:
`
`
`
`Q.
`
`Did you review any other publications or
`
`
`non—privileged material beyond the PTAB orders?
`
`MS. FUKUDA: Same instruction.
`
`
`
`
`
`
`
`lHfi W lNfiSS:
`
`don't believe so. Not that
`
`
`
`can recall.
`
`BY MR. MARSH:
`
`
`
`
`Did you look at any —— I don't want
`
`the
`
`Did you look at any privileged materials?
`
`
`
`
`
`
`
`
`
`
`
`S. FUKUDA: Objection to form.
`
`
`
`
`
`
`
`
`
`lHfi W lNfiSS:
`'m not sure that
`
`
`
`
`have, but as " sit here " don't recall.
`
`BY MR. MARSH:
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000017
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 17
`
`Q.
`
`
`Did you look at any materials that were not
`
`prepared by counsel that you reviewed subsequent
`
`to your
`
`
`
`No.
`
`
`declaration beyond the CBM orders?
`
`
`MS. FUKUDA: Again, my ins:ruction is
`
`
`
`
`
`instruct the witness not
`
`to answer to the extent that
`
`any material was provided to you by counsel
`
`
`preparation :or this deposition.
`
`
`
`
`
`
`lHfi W lNfiSS:
`
`in
`
`can't answer that question.
`
`
`BY MR. MARSH:
`
`Q.
`
`A.
`
`received.
`
`Why can't you answer that question?
`
`
`
`
`
`Because " am Sollowing the instruction that
`
`
`
`
`
`
`MS. FUKUDA: Just so we are clear, you can
`
`answer yes or no, but not
`
`
`
`
`
`lHfi W lNfiSS: Okay.
`
`the content.
`
`So with that in mind,
`
`the
`
`answer is yes.
`
`
`BY MR. MARSH:
`
`
`
`the material you reviewed prepared by
`
`Q.
`
`counsel?
`
`
`MS. FUKUDA: Objection to form.
`
`
`
`
`
`
`
`lHfi W lNfiSS:
`
`don't believe so.
`
`
`
`
`BY MR. MARSH:
`
`
`
`the material you reviewed publicly
`
`Q.
`
`Was
`
`available?
`
`A.
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000018
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 18
`
`Q.
`
`Was
`
`the material you reviewed under
`
`
`
`Sidentiality order 0" the SightSound litiga
`
`A.
`
`Q.
`
`A.
`
`The district court litigation?
`
`Correct.
`
`Yes.
`
`
`Have any 0: your opinions today or previously
`
`
`been based on material that is under the conjidentiality
`
`the SightSound material, confidential material
`
`
`
`
`
`
`
`Q.
`
`
`order 0:
`
`under the distriCt court litigation?
`
`
`MS. FUKJDA: Objection to jorm.
`
`
`
`can't answer that question.
`
`
`
`
`
`
`
`
`lHfi W lWfiSS: And you have to —— you have to
`
`
`
`BY MR. MARSH:
`
`
`
`lave you based in your declaration any basis
`
`
`
`Q.
`
`
`
`your opinion —— strike that, we'll start again.
`
`
`
`
`
`In any o_ the declarations you have provided
`
`
`any of the CBM proceedings, did you base your opinion
`
`
`
`on material that was under the con‘identiality order 0‘
`
`
`
`the district coart litigation?
`
`A.
`
`Q.
`
`material?
`
`
`I did not.
`
`
`What was the purpose 0: you reviewing such
`
`MS. FUKUDA: Objection.
`
`
`I instruct the witness
`
`not
`
`
`to answer on tie basis 0: privilege.
`
`
`
`
`
`lHfi W lNfiSS:
`
`
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000019
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page l9
`
`
`BY MR. MA
`
`Q.
`
`Okay.
`
`Le'
`
`
`I'm going to give you
`
`
`
`
`Txhibit 113?, which is your declaration in the '573.
`
`
`
`(Whereupon, Txhibi: “3? was
`
`
`produced :or iden
`icacion)
`
`
`
`
`
`
`
`
`
`
`
`MR. MARSl: Counsel,
`
`
`is it appropriate for us
`
`
`Lo rejer to is as Txhibit 1‘37, or would you like it to
`
`be marked as Exhibit
`
`1
`
`in this deposition?
`
`
`
`MS. FUKUDA: Probably easier i: we just use the
`
` 3 numbers.
`
`
`
`can tell you what he did.
`
`
`
`MR. MARSH: Thank you. Okay.
`
`
`Can you identify this document?
`
`Q.
`
`A.
`
`
`that —— in support 0:
`
`Yes. This appears to be my declaration
`
`
`
`the —— of Apple's pecition jor the
`
`
`covered business method patent review Ior she '573.
`
`
`
`
`Did you write this declaration?
`
`
`I did.
`
`
`Did Alain Train dra‘t any parts 0:
`
`
`
`
`
`declaration?
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Q.
`
`Triaj.
`
`Triaj.
`
`
`
`Yes, he helped me to prepare the declaration.
`
`Q.
`
`
`Which parts did he draft?
`
`A. Well,
`
`
`
`I sp ak
`sur
`w
`ar
`cl ar about what
`
`
`
`
`
`
`you mean by drafting.
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000020
`
`
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 20
`
`He
`
`ielped me to prepare the things like the materials
`
`
`list that I set forth on —— in paragraph 9 on page 5.
`
`
` that were —— we didn't make up these numbers,
`
`{e qelped me with putting in all these exhibit numbers
`
`
`
`
`
`they were
`
`h lp d m mak
`th
`th
`th
`
`provided to us.
`
`H
`
`chart on page 9, paragraph 14.
`
`And we have various, various places where we
`
`are cutting in here cutting and pasting from the
`
`
`
`
`
`
`
`
`documents that
`
`
`I am citing to, and he helped me with
`
`
`
`
`
`
`that.
`
`That
`
`type 0: thing.
`
`Q.
`
`
`lave you given us an exhaustive list of the
`
`plac s wh r
`
`h
`
`
`h lp d, where he dra_ted or helped you
`
`on the declaration?
`
`
`
`
`
`A. Well,
`
`
`
`I have given you a —— the type 0: thing
`
`
`I would have to go through it page by page
`
`that he did.
`
`
`
`
`to do my best to identify, you know, specific parts.
`
`
`
`Yoa know,
`
`
`for example, on page 26,
`
`there is a
`
`
`figure 3 phOtograph.
`
`Q.
`
`A.
`
`Let's do this systematically.
`
`Sure.
`
`
`
`Did he prepare any 0:
`
`the paragraphs on page
`
`Wo,
`
`
`I don't believe so.
`
` Did Mr. Train prepare any 0:
`
`the paragraphs on
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000021
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`
`
`
`
`
`A.
`
`understand who you are talking about,
`
`Page 21
`
`
`
`
`
`think of him as Dr. Trial.
`
`Sorry.
`
`
`
`
`
`Not Mr. Train.
`
`know who you are talking
`
`
`
`don't believe so.
`
`
`
`Dr. Trial prepare any 0:
`
`
`
`the materials on
`
`q't believe so.
`
`
`
`
`Dr. Trial prepare any 0:
`
`
`
`the materials on
`
`
`
`
`
`
`
`Well, he helped me to assemble the —— we had a
`
`
`stack o_ macerials, and h
`h lp d m
`to
`
`to create
`
`this list of materials that I set forch in paragraph 9.
`
`
`
`
`
`
`
`
`
`
`Q.
`
`A.
`
`Q.
`
`A.
`
`Did he select the materials?
`
`Wo.
`
`
`
`
`Did Dr. Train assist you in —— on page 6?
`
`Yes, he did.
`
`He helped me to get this lis
`
`
`
`
`
`
`formatted and 1e helped me with the exhibit numbers
`
`on page 7, and he helped me to add to the exhibit
`
`
`
`were supplied to us.
`
`
`Did Dr. Trial, sOrry.
`
`
`
`i' Dr. Trial prepare
`
`
`
`f the materials on page 7?
`
`h lp d m
`to
`
`H
`
`
`to format
`
`
`the information
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000022
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 22
`
`numbers that were supplied to us,
`
`that type of thing.
`
`Q.
`
`On page 7, was his help limited to the actions
`
`you have described?
`
`A. Well,
`
`
`
`the actions I have described for page ——
`
`basically paragraph 9,
`
`
`I mean, page 7, his —— his
`
`assistance on page 7,
`
`
`
`
`
`di"erent
`'rom his assistance on page 6 and page —— and
`
`
`I don't believe, was materially
`
`
`paragraph 9 portion 0: page 5.
`
`Q.
`
`
`I don't believe you answered my question,
`
`so
`
`
`
`
`
`t again.
`
`
`
`Did Dr. —— let me just go back so
`
`
`
`have just described?
`
`
`
`
`
`this same question again.
`
`On page 7, we can add page 8 as well, and page
`
`9, was his help limited to the actions you have
`
`described?
`
`
`MS. FUKUDA: Objection to form.
`
`
`
`
`
`lHfi W lNfiSS:
`
`
`
`
`
`'m —— I'm not sure i: you were
`
`
`intending to identify pages 7, 8, and 9, because
`
`paragraph 9 finishes on page 7, and then we get
`
`
`
`
`
`
`di"erent master on page 8.
`
`into
`
`
`BY MR. MARSH:
`
`You are correct.
`
`net's talk about paragraph 9. Were the
`
`actions with respect to paragraph 9
`
`limited to those you
`
`
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000023
`
`
`
`JOHN P. J. K
`
`
`
`ELLY,
`
`
`Ph.3.
`
`—
`
`12/4/2013
`
`Page 23
`
`A.
`
`
`
`believe so.
`
` i mean,
`
`
`
`
`
`
` "erenL
`i-
`" said di
`
`things about
`
`say the portion 0:
`
`
`: paragraph 9 that's on
`
`
`
`the
`
`—— the
`
`page 5 vers
`
`portion
`
`
`union of
`
`that's on page 7,
`
`
`
`as the portion that's on page 6 and
`
`
`
`think i: you take tqe
`
`that description, it
`
`would apply to what he did
`
`in helping me prepare paragraph 9.
`
`Q.
`
`For paragraphs 10 through 12,
`
`did
`
`
`Dr. Trial
`
`assist you?
`
`A.
`
`Well,
`
`you know,
`
`
`
`
`don't recall
`" asked him
`i-
`
`
`
`—— to pul:
`
`_ up the —— the distriCt
`
`COUI
`
`t's description
`
`
`
`
`
`
`the person 0‘
`
`' ordinary skill
`
`<now,
`
`
`
`don't remember as
`
`
`
`in the ar
`
`t. And you
`
`wh '1 r h
`sit h r
`typ d
`
`
`But
`
`
`
`in the art.
`
`
`
`
`the extent 0:
`
`his help.
`
`And you know,
`
`paragraph ll,
`
`
`
`think that ——
`
`mean,
`
`as
`
` recall,
`
`we got that
`
`
`from an earlier
`
`invalidity report where
`
`
`
`had ——
`
`
`i had wr
`
`itten this.
`
`don't recall
`
`as
`
`
`
`sit here who did the cut and paste,
`
`but you
`
`know, i:
`
`it was him or it was me.
`
`Q.
`
`
`What was the earlier invalidity report you
`
`
`
`
`
`
`ferred to?
`
`
`
`typed them in.
`
` 'qat would be
`
`
`
`those words in or
`
`
`
`A.
`
`was the —— maybe it was the
`
`Maybe it :ted in ——
`
`declaration submi'
`
`
`for the Markman order.
`
`
`
`don't recall that.
`
`
`
` %ut
` had,
`
`
`
`had given an opinion
`
`OI
`
`
`
`_ ordinary skill
`
`(800)
`
`869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000024
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 24
`
`Q.
`
`
`Is this opinion that you are giving 0:
`
`
`
`ordinary skill in the art consistent with those where it
`
`
`was cut and pasoed from?
`
`
`
`
`
`" certain'y believe so.
`
`
`Was it cut and pasted from an opinion in a
`
`I have told you what he
`
`A.
`
`Q.
`
`SightSound matter?
`
`A.
`
`Q.
`
`A.
`
` Education?
`
`Q.
`
`A.
`
`Yes.
`
`
`What is Dr. Trial's background?
`
`He has —— technical background, you mean?
`
`Yes, please.
`
`And experience?
`
`He has worked with me
`
`
`
`last 14 or 15 years.
`
`
`And before that he was a post doctoral
`
`
`researcher at UCSB.
`
`
`
`And before that he was a Ph.D. student at
`
`
`Princeton and at UCSB.
`
`
`And before that he was —— he was an
`
`
`
`undergraduate at University 0; Dayton in Ohio.
`
`Q.
`
`
`
`Is it typical for someone with such a long and
`
`detailed technical background to be limited to
`
`
`
`collecting lists and inserting exhibit numbers?
`
`
`
`MS. FUKUDA: Objection to form.
`
`
`
`lHfi W lNfiSS: Well,
`
`
`
`
`I can': speak in general
`
`
`But
`
`
`in —— in —— I mean,
`
`
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000025
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 25
`
`did to help me with those paragraphs.
`
`
`BY MR . MARSH:
`
`Q.
`
`
`
`What tasks does Dr. Trial
`typically undertake
`
` for Kelly Technology?
`
`
`
`Lots 0” di ”erent
`
`A.
`
`
`
`tasks.
`
`
`He writes software,
`
`he analyzes source code, he builds, he is able to take
`
`
`ancient hardware and software and construct working
`
`he is able to assist me
`
`
`
`activi
`in a'l sorts o
`
`systems, he is able to reverse engineer produc
`
`
`reviewing materials and the like.
`
`Q.
`
`
`Did he undertake any 0:
`
`those aCtivities with
`
`
`respect to your declarations in the CBM matters?
`
`h lp d m
`r vi w materials.
`
`
`
`
`
`ie —— we
`
`A.
`
`H
`
`
`
`Yes.
`
`didn't —— we didn't build any systems, we didn't analyze
`
`any source code
`
`
`
`‘or —— tor these purposes.
`
`
`
`Q.
`
`What do you mean when you say "He helped me
`
`review materials"?
`
`ones that I cite here I would have him also look a
`
`looked at —— at various documents and
`
`
`
`A.
`
`I
`
`
`
`
`
`
`
`
`documents to see i-
`" missed something or —— and
`
`
`
`
`would —— I would have discussions with him about
`
`the
`
`documents.
`
`Q.
`
`
`Okay. Let's turn to page 10 of
`
`declaration.
`
`A.
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000026
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 26
`
`Q.
`
`
`Can you identify what is the second party
`
`
`memory in this illastration in figure 1?
`
`
`
`
`MS. FUKUDA: Objection to form.
`
`
`
`
`lHfi W lNfiSS:
`
`(No response).
`
` BY MR. MARSH:
`
`What are you looking at?
`
`
`
`
`I'm going to look at the '573 patent and see
`
`what it says.
`
`
`
`
`I have asked you to idenLi'y i
`'rom the
`
`
`
`
`
`
`figure you have provided in your declaration.
`
`Q.
`
`A.
`
`Q.
`
`I have the same objection.
`
`
`
`A.
`
`
`
`
`I believe that this is figure —— this figure
`
`
`
`
`
`is from the '573 patent, it's figure 1 of the '573
`
`patent.
`
`
`So I'm going to look through and see what
`
`the —— what
`
`
`the patent specification says about
`
`the
`
`second a memory to answer your question.
`
`
`
`believe that was the question. Would you
`
`repeat the question, please?
`
`MR. MARSH: Could you?
`
`(Whereupon,
`
`the reporter read back
`
`the record as follows:
`
`
`
`"Can you identify what is the second
`
`party memory in this illustration
`
`
`
`in figure 1?")
`
`
`MS. FUKUDA:
`
`
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000027
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 27
`
`
`
`
`
`
`lHfi W lNfiSS:
`
`
`lhe figure 1
`
`in the patent,
`
`tqat
`
`
`
`
`
`'igure 1. And the
`second party is on the right side 0
`
`memories that are there are the incoming RAM 50C,
`
`the
`
`the second party would be equipment associated with the
`
`
`
`hard disk 60, and the playback RAM 503.
`
`
`
`party's memory system.
`
`And the specification describes those, it
`
`describes the incoming RAM access memory chip,
`
`the
`
`playback RAM access memory chip, and 60 is the hard disk
`
`
`
`0:
`
`the user.
`
`
`3u'
`
`
`
`to talk abou'
`
`
`
`and then —— and then later on it goes on
`
`a —— a —— a second, second memory, but it
`
`
`doesn't —— so it must be one or more Of
`
`those,
`
`those
`
`memories.
`
`Q.
`
`BY MR. MARSH:
`
`
`
`Did you review the '573 patent prior to the
`
`deposition?
`
`A.
`
`
`I'm nOt sure what you mean by that. What
`
`
`
`
`frame did yoa have for that?
`
`MR. MARSH: Okay.
`
`
`For the record when
`
`
`
`
`to the '573, it's U.S. patent 5,191,573.
`
`Q.
`
`When you were reviewing the '573 patent,
`
`sorry, let's stop, start the question again.
`
`
`You mentioned that figure 1 O"
`
`the '573 patent
`
`
`set forth that a hard disk was part 0.
`
`
`
`che second
`
`
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000028
`
`
`
`
`
`is a second memory —— wha'
`I said was the specifica
`
`
`
`
`discusses in figure 1, wi
`re'erence co figure 1 i
`
`
`
`
`
`
`
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 28
`
` Is that correct?
`
`
`MS. FUKUDA: Objection to form.
`
`
`
`lHfi W lNfiSS: No. What
`
`
`
`
`I said was that there
`
`the second party's system does have a
`
`discusses, it discusses tqree memories.
`
`
`And then later on in the specification it
`
`
`discusses a so—called second memory 0: a second party.
`
`
`
`
`
`don't believe it ties that back to any specific
`%ut
`
`
`
`
`parts 0
`figure 1.
`
`
`
`But presumably if it's tied to anything it
`
`
`must be tied to some memory in figure 1.
`
`
`BY MR . MARSH:
`
`Q.
`
`
`The figure legend you replicate in your
`
`
`"The first party system
`declaration scaces as follows:
`
`
`
`(components on the le a side 0
`
`
`
`the figure) are
`
`
`
`
`
`
`connected to the second party's system (components on
`
`
`
`the right side of she figure) by telephone lines."
`
`
`
`Does Lhac figure legend that you reproduced
`
`
`help clarify whether the second party has a hard disk as
`
`its memory?
`
`
`
`
`MS. FUKUDA: Objection to form.
`
`
`
`
`
`lHfi W lNfiSS:
`would agree Lhac the figure
`
`
`
`
`
`
`
`
`forth here,
`
` say,
`
`the —— the right—land side which
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000029
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`Page 29
`
`
`
`hard disk 60. That —— but whether or no
`
`second memory is —— is no: discussed,
`
`
`
`
`
`
`
`
`
`spec.
`
`
`BY MR. MARSH:
`
`Q.
`
`A.
`
`correct.
`
`Is a hard disk memory?
`
`
`
`
`It's a —— hard disk is a type 0: memory,
`
`Q.
`
`
`
`Is the hard disk in figure l
`
`that you provided
`
`
`
`on page lO 0‘
`' your declaration labeled as being part 0:
`
`the second party's system?
`
`A.
`
`I don't understand the question.
`
`Q.
`
`
`In figure l, hard disk labeled 60,
`
`
`
`right—hand side of
`the figure.
`
`
`
`is on the
`
` Is that correct?
`
`
`
`Yes, i: is.
`
`
`
`In the legend under figure 1,
`
`the legend
`
`A.
`
`Q.
`
`
`states "The first party's system (components on the left
`
`
`side of
`
`the figure) are connec:ed to the second party's
`
`
`
`
`system (components on the right side of
`
`
`the figure) by
`
`
`
`
`
`the figure. And I have identified that in —— in
`
`
`
`telephone Iines."
`
`
`Is hard disk 60 part Of
`
`the second party's
`
`
`MS. FUKUDA: Objection to form.
`
`
`
`
`
`
`
`lHfi W lNfiSS:
`t is a component on the right
`
`
`
`
`
`
`
`
`(800) 869—9132
`
`Merrill Corporation — San Francisco
`www.merrillcorp.com/law
`
`PAGE 000030
`
`
`
`
`
`JOHN P. J. KELLY, Ph.3.
`
`—
`
`12/4/2013
`
`the —— in the caption,
`
`Page 30
`
`
`in the figure 1 caption as part
`
`
`o:
`
`the second party's system.
`
`
`
`
`BY MR . MARSH:
`
`
`
`Q.
`
`
`Given your understanding of the '573 pa
`
`
`
`
`how is payment transmitted Irom the second party
`
`
`
`first party, according to the patent?
`
`MS. FUKUDA: Objection to jorm.
`
`
`
`lHfi W lNfiSS: Well,
`
`the claim, claim ',
`
`
`:or
`
`
`
`example, says "transferring money electronica"y via a
`
`t
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