Rough Draft_Victor Shoup.txt
`
` 1
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 ---------------------------------------------
`
` REALTIME AND INTERACTIVE REALTIME
`
` 3 TRANSCRIPT ROUGH DRAFT DISCLAIMER
`
` ---------------------------------------------
`
` 4 IMPORTANT NOTICE:
`
` AGREEMENT OF PARTIES
`
` 5 ---------------------------------------------
`
` We, the party working with realtime and rough
`
` 6 draft transcripts understand that if we
`
` choose to use the realtime rough draft screen
`
` 7 or the printout, that we are doing so with
`
` the understanding that the rough draft is a
`
` 8 noncertified copy.
`
` 9 We further agree not to share, give, copy,
`
` scan or fax or in any way distribute this
`
` 10 realtime rough draft in any form (written or
`
` computerized) to any party. However, your
`
` 11 own experts' cocounsel and staff may have
`
`Page 1
`
`USR Exhibit 2014, page 1
`
`
`
` 1
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 ---------------------------------------------
`
` REALTIME AND INTERACTIVE REALTIME
`
` 3 TRANSCRIPT ROUGH DRAFT DISCLAIMER
`
` ---------------------------------------------
`
` 4 IMPORTANT NOTICE:
`
` AGREEMENT OF PARTIES
`
` 5 ---------------------------------------------
`
` We, the party working with realtime and rough
`
` 6 draft transcripts understand that if we
`
` choose to use the realtime rough draft screen
`
` 7 or the printout, that we are doing so with
`
` the understanding that the rough draft is a
`
` 8 noncertified copy.
`
` 9 We further agree not to share, give, copy,
`
` scan or fax or in any way distribute this
`
` 10 realtime rough draft in any form (written or
`
` computerized) to any party. However, your
`
` 11 own experts' cocounsel and staff may have
`
`Page 1
`
`USR Exhibit 2014, page 1
`
`
`
`Rough Draft_Victor Shoup.txt
` limited internal use of same with the
`
` 12 understanding that we agree to destroy your
`
` realtime rough draft and/or any computerized
`
` 13 form, if any, and replace it with the final
`
` transcript upon its completion.
`
` 14 Case: Apple Inc. vs. Universal
`
` Secure Registry, LLC
`
` 15 Date: February 11, 2019
`
` REPORTER'S NOTE:
`
` 16
`
` Since this deposition has been realtimed and
`
` 17 is in rough draft form, please be aware that
`
` there may be a discrepancy regarding page and
`
` 18 line number when comparing the realtime
`
` screen, the rough draft, rough draft disk,
`
` 19 and the final transcript.
`
` Also please be aware that the realtime screen
`
` 20 and the noncertified rough draft transcript
`
` may contain untranslated steno, reporter's
`
` 21 notes in double parenthesis, misspelled
`
` proper names, incorrect or missing Q/A
`
` 22 symbols or punctuation, and/or nonsensical
`
` English word combinations. All such entries
`
` 23 will be correct on the final certified
`
`Page 2
`
`USR Exhibit 2014, page 2
`
`
`
` transcript.
`
` 24
`
`Rough Draft_Victor Shoup.txt
`
` Court Reporter's Name: Michelle A. Cox
`
` 25 Firm Name: First Legal Deposition
`
` 2
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 EXAMINATION BY
`
` 3 MR. HEFAZI:
`
` 4 Q Good morning, Dr. Shoup.
`
` 5 So Dr. Shoup, I understand you've been
`
` 6 deposed before most recently in another matter
`
` 7 between Apple and Universal Secure Registry; is
`
` 8 that correct?
`
` 9 A That's correct.
`
`Page 3
`
`USR Exhibit 2014, page 3
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 10 Q And have you been deposed in any other
`
` 11 matters?
`
` 12 A No, I have not.
`
` 13 Q Okay. What did you do to prepare for
`
` 14 today's deposition?
`
` 15 A You mean specifically aside from writing
`
` 16 my declarations and such.
`
` 17 Q Correct?
`
` 18 A I met with Apple counsel couple of times
`
` 19 in the last week just to review things I also
`
` 20 on my own reviewed my declaration medleys,
`
` 21 plural and various prior art references and the
`
`Page 4
`
`USR Exhibit 2014, page 4
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 22 USR patents themselves.
`
` 23 Q Okay. And you mentioned the declaration
`
` 24 you reviewed those and did you see anything
`
` 25 that you athought was incorrect or inaccurate.
`
` 3
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 No.
`
` 3 Q And you understand the opinions in your
`
` 4 declaration absolutely they are my opinions.
`
` 5 Q And you standby those opinion?
`
` 6 A Absolutely.
`
` 7 Q And you understand I guess the prior art?
`
`Page 5
`
`USR Exhibit 2014, page 5
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 8 MR. SELWYN: Objection; form.
`
` 9 A I I've read and review and understand the
`
` 10 prior art references that are mentioned in
`
` 11 medley.
`
` 12 Q And you also understand the USR patents in
`
` 13 these proceedings?
`
` 14 A I've read and reviewed the U USR patents
`
` 15 and feel competent in my understanding of them.
`
` 16 Q You mentioned you met with Apple counsel a
`
` 17 couple of times.
`
` 18 Is that Mr. Selwyn and Ms. Grewal?
`
` 19 A Yes. And Kalvin Chan and Derrick ^.
`
`Page 6
`
`USR Exhibit 2014, page 6
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 20 Q Did you meet with anyone that was not an
`
` 21 attorney?
`
` 22 A No I did not and you mentioned that you
`
` 23 started preparing or meeting with the attorneys
`
` 24 a couple of weeks ago -- strike that.
`
` 25 When it did you start preparing for your
`
` 4
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 deposition?
`
` 3 A For this particular deposition.
`
` 4 A Correct.
`
` 5 Q I don't know that I know the exact date.
`
`Page 7
`
`USR Exhibit 2014, page 7
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 6 Sometime after my last deposition.
`
` 7 Q Okay. I guess approximately how many
`
` 8 hours would you say you spent reviewing these
`
` 9 materials and preparing it for this deposition?
`
` 10 A Maybe 30 to 40 hours.
`
` 11 Q And other than your declarations the prior
`
` 12 art sited in the prior declarations are there
`
` 13 any other documents that you reviewed in
`
` 14 preparation for youring it deposition today?
`
` 15 A Well I reviewed other documents in
`
` 16 preparing medley, but.
`
` 17 Q My question is focused just on your
`
`Page 8
`
`USR Exhibit 2014, page 8
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 18 deposition?
`
` 19 A Deposition. I don't believe so.
`
` 20 Q Did you review your deposition transcript
`
` 21 from are the prior deposition?
`
` 22 A Yes, I did.
`
` 23 Q And did you see anything inaccurate in
`
` 24 that deposition transcript?
`
` 25 A There were a couple of of typos there that
`
` 5
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 I I did submit a what's it called an errata a
`
` 3 couple of typos.
`
`Page 9
`
`USR Exhibit 2014, page 9
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 4 Q And?
`
` 5 A There was one point which I felt kind of
`
` 6 silly. I did -- there was a question regarding
`
` 7 my interaction with any referral expert witness
`
` 8 referral services and I mentioned one but there
`
` 9 were couple of extra others I actually wasn't
`
` 10 thinking for at the time I didn't mention I ask
`
` 11 tell them to you now I guess.
`
` 12 Q Sure.
`
` 13 The think you mentioned was with Avi
`
` 14 Rubin, Harvard Labs?
`
` 15 A That's correct. I couldn't remember the
`
`Page 10
`
`USR Exhibit 2014, page 10
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 16 names at the time. And the two others are, I
`
` 17 did review that since that time to make sure I
`
` 18 got the names right, GLG Group and Forensis
`
` 19 Group.
`
` 20 Q Okay. But other than on your testimony in
`
` 21 your pursue prior deposition you haven't
`
` 22 submitted any other testimony in the form of a
`
` 23 deposition or declaration or?
`
` 24 A Regarding these proceedings.
`
` 25 Q Just generally?
`
` 6
`
` 1 ROUGH DRAFT - SHOUP
`
`Page 11
`
`USR Exhibit 2014, page 11
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 2 A No.
`
` 3 MR. HEFAZI: Let me mark as Exhibit 1,.
`
` 4 MR. HEFAZI: Counsel I have two copies of
`
` 5 this I might not have two copies of each. So
`
` 6 this is Exhibit 1US patent No. 885-6539.
`
` 7 (Exhibit Type Exhibit
`
` 8 No , Description ,
`
` 9 marked for identification as of this date.)
`
` 10 Q Okay. So this is Shoup Exhibit 1US patent
`
` 11 No. 885-6539. And you've seen this document
`
` 12 before?
`
` 13 A Yes, I have.
`
`Page 12
`
`USR Exhibit 2014, page 12
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 14 Q And I'm going to call this the 539 patent
`
` 15 you'll understand that I'm referring to this
`
` 16 exhibit here, correct?
`
` 17 A Yes.
`
` 18 Q And you've read all of the 539 patent,
`
` 19 correct?
`
` 20 A Yes, I have.
`
` 21 Q And when was the raft time that you read
`
` 22 the 539 patent?
`
` 23 A You mean when is with is the last time I
`
` 24 read it from front to back.
`
` 25 Q Let's start there?
`
`Page 13
`
`USR Exhibit 2014, page 13
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 7
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 A That might have been a while certainly
`
` 3 during the preparation of medley read through
`
` 4 it several times. I don't know that during my
`
` 5 preparation for this deposition I may have
`
` 6 focused more on the claims and relevant
`
` 7 portions of the specification as they pertained
`
` 8 to electricity claims.
`
` 9 Q But you did review this patent as it it
`
` 10 pertains to your deposition?
`
` 11 A Mainly focusing on the claims themselves
`
`Page 14
`
`USR Exhibit 2014, page 14
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 12 and the relevant parts of the specification.
`
` 13 Q Okay. And you understand the claims of
`
` 14 this patent?
`
` 15 A Yes.
`
` 16 Q Okay. And how long would you say you
`
` 17 spent looking and reviewing this '539 Patent
`
` 18 during your preparation for your deposition
`
` 19 today?
`
` 20 A It's hard to attach a particular number.
`
` 21 Q Just an approximate ballpark?
`
` 22 MR. SELWYN: Objection; form.
`
` 23 A Much of the time I spent reviewing this
`
`Page 15
`
`USR Exhibit 2014, page 15
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 24 was in conjunction with reviewing the
`
` 25 declarations that medley pertaining to the '539
`
` 8
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 Patent. So it's hard to say how much time I
`
` 3 spent on each one of those.
`
` 4 Q Okay. In combination reviewing the
`
` 5 declaration and the '539 Patent, how many hours
`
` 6 would you say you spent?
`
` 7 A Well I said I spent 20 to 30 hours in
`
` 8 total. Let's say, 15.
`
` 9 Q Okay.
`
`Page 16
`
`USR Exhibit 2014, page 16
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 10 A Ten to 15 and that's a ballpark estimate
`
` 11 as you call it.
`
` 12 MR. HEFAZI: Let me know mark asShoup
`
` 13 Exhibit 2 patent No. 593-0767 to WEBER lieu
`
` 14 with us the at he will.
`
` 15 (Exhibit Type Exhibit
`
` 16 No , Description ,
`
` 17 marked for identification as of this date.).
`
` 18 And if you it don't mind can we just call this
`
` 19 REBER.
`
` 20 Q Certainly certainly.
`
` 21 (Exhibit Type Exhibit
`
`Page 17
`
`USR Exhibit 2014, page 17
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 22 No , Description ,
`
` 23 marked for identification as of this date.)
`
` 24 Q Okay. And the REBER this is one of the
`
` 25 references you're relying on in challenge the
`
` 9
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 '539 Patent, right?
`
` 3 A Yes.
`
` 4 Q Okay. And you've read all of the REBER?
`
` 5 A Oh, yes.
`
` 6 Q And when was the last time you reviewed
`
` 7 REBER?
`
`Page 18
`
`USR Exhibit 2014, page 18
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 8 A Saturday.
`
` 9 Q And how long you spend reviewing REBER?
`
` 10 A On Saturday,.
`
` 11 A Four hours.
`
` 12 Q And how long in total course both in
`
` 13 \repeat\reaping your declaration and preparing
`
` 14 nor this deposition have you spent reviewing
`
` 15 Reber?
`
` 16 A I can't give a specific number to that.
`
` 17 Q Would have it have been more or less than
`
` 18 ten hours?
`
` 19 A Let's say more than ten.
`
`Page 19
`
`USR Exhibit 2014, page 19
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 20 Q More than 20 hours?
`
` 21 A I'm not sure.
`
` 22 Q You've reviewed it sufficiently such that
`
` 23 you believe you understand Reber, correct?
`
` 24 A I have a good understanding of Reber.
`
` 25 Q Okay. Let's turn to figure one of Reber.
`
` 10
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 Okay. And figure one is a block diagram
`
` 3 of Reber's transaction system; is that right?
`
` 4 A That's correct.
`
` 5 Q And in figure one there's an end user 26.
`
`Page 20
`
`USR Exhibit 2014, page 20
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 6 Do you see that?
`
` 7 A Yes, I do.
`
` 8 Q And there's a dashed box around a number
`
` 9 of the items in figure one.
`
` 10 Does that represent the end users
`
` 11 location?
`
` 12 A Yeah. The last time I remember reviewing
`
` 13 this and reading through references and user
`
` 14 location 24. And I to be to be honest I don't
`
` 15 know if it's a bug in the diagram but I
`
` 16 couldn't find a anything labeled 24.
`
` 17 Q Okay. But as a person ever skill in the
`
`Page 21
`
`USR Exhibit 2014, page 21
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 18 art do you understand Figure 1 that the dashed
`
` 19 box surrounding certain elements to represent
`
` 20 the user's location?
`
` 21 MR. SELWYN: Objection; form.
`
` 22 A Since it wasn't specified in this the
`
` 23 diagram I haven't really I don't have an
`
` 24 opinion on what the dashed box represents. I
`
` 25 just certainly can took the words user location
`
` 11
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 in the specific to mean what they ordinarily
`
` 3 mean.
`
`Page 22
`
`USR Exhibit 2014, page 22
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 4 Q So I guess you don't have an opinion as to
`
` 5 whether the dashed box surrounding certain
`
` 6 items in figure one is the user location?
`
` 7 MR. SELWYN: Objection; form.
`
` 8 A Since the dashed box isn't labeled, and
`
` 9 since I did not to the best of my knowledge I
`
` 10 don't remember reading audition like the dashed
`
` 11 box represents such and such, I don't really
`
` 12 have an opinion.
`
` 13 Q Okay. So it's your opinion that once
`
` 14 skilled in the art looking at figure one and
`
` 15 reading the the specification wouldn't be
`
`Page 23
`
`USR Exhibit 2014, page 23
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 16 unable to determine whether or not the dashed
`
` 17 box represents user location?
`
` 18 MR. SELWYN: Objection; form.
`
` 19 A All I can say is my first impression that
`
` 20 may be reasonable but I withhold an opinion.
`
` 21 Q Okay. Okay. So within the dashed box
`
` 22 there's a box labeled 34. That's the display
`
` 23 device, correct?
`
` 24 A Box labeled 34., that's correct.
`
` 25 Q And that would be like a computer monitor;
`
` 12
`
` 1 ROUGH DRAFT - SHOUP
`
`Page 24
`
`USR Exhibit 2014, page 24
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 2 is that right?
`
` 3 A Let's -- well for example in figure eight
`
` 4 of the Reber patent, 34 is identified as that
`
` 5 embodiment is identified as a computer monitor.
`
` 6 Q Okay. And that computer monitor would be
`
` 7 at the he's location?
`
` 8 A That seems reasonable.
`
` 9 Q At box 32 there's a network access
`
` 10 apparatus, that connection connects to the
`
` 11 electronic network?
`
` 12 A Yes.
`
` 13 Q And that network access apparatus would it
`
`Page 25
`
`USR Exhibit 2014, page 25
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 14 be fair to say that's also at the user
`
` 15 location?
`
` 16 A Right.
`
` 17 So I think it's helpful to look at
`
` 18 Figure 8 in conjunction with the discussion of
`
` 19 Figure 8 at Column 10 of Reber at Line 9, where
`
` 20 it says, Figure 8 is an illustration of an
`
` 21 example of the data reader 30 and the network
`
` 22 access apparatus 32 at the user location.
`
` 23 So that is consistent with the assertion
`
` 24 that's at the user location.
`
` 25 And then it continues to say, in this
`
`Page 26
`
`USR Exhibit 2014, page 26
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 13
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 example, the network apparatus 32 comprises a
`
` 3 personal computer network 140, which you can
`
` 4 see labeled in Figure 8.
`
` 5 Q There's also a data reader in figure one
`
` 6 labeled 30 I I guess that also appears in
`
` 7 Figure 8 as item 30?
`
` 8 A That's correct.
`
` 9 Q And that would also be at user location at
`
` 10 the end users location?
`
` 11 A In some embodiments, yes.
`
`Page 27
`
`USR Exhibit 2014, page 27
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 12 Q Does Reber disclose any embodiments where
`
` 13 it's not at the user location?
`
` 14 A Yes.
`
` 15 Q Can you show me where that is?
`
` 16 A So for example, as Reber discloses the
`
` 17 second data so I'm looking at column four, line
`
` 18 21. Where it says alternatively the second
`
` 19 data element is generated in the second network
`
` 20 access apparatus 32 in this case the second
`
` 21 data element would be prestored in the network
`
` 22 access apparatus 32 or it can be generate bid a
`
` 23 code generator associated with the network
`
`Page 28
`
`USR Exhibit 2014, page 28
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 24 access apparatus 32 preferable the second data
`
` 25 almost which say time itinerary varying now the
`
` 14
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 second dashed box element is something chosed
`
` 3 earlier is something that can be read by the
`
` 4 data reader, also the other thing that can be
`
` 5 read by the decade reader we can look at
`
` 6 references and citations is the first data
`
` 7 element and later on column four alternatively
`
` 8 the first data element in response to a user
`
` 9 input device of the net this network access
`
`Page 29
`
`USR Exhibit 2014, page 29
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 10 apparatus 32 in this case at end user 26 it
`
` 11 initiate a transaction based upon second
`
` 12 viewable delayed by pit display device 34.
`
` 13 Q So let's break that down a bit.
`
` 14 Network network access apparatus 32 is in?
`
` 15 A Anarchy.
`
` 16 Q Where in this disclosure does it teach
`
` 17 that the data reader 30 is not within the user
`
` 18 location?
`
` 19 A Well, it's my opinion and understanding of
`
` 20 the Reber patents the embodiment of which a
`
` 21 data reader is present is to read the first and
`
`Page 30
`
`USR Exhibit 2014, page 30
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 22 second data elements required for the
`
` 23 transaction, and that's one embodiment, maybe
`
` 24 even a preferred embodiment.
`
` 25 However, the Reber patent also discloses
`
` 15
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 in the points that I've cited at Column 4, line
`
` 3 21 and Column 4, line 50 that there are other
`
` 4 embodiments which the first and second data
`
` 5 elements are generated without the use of.
`
` 6 Q Okay. So you're not saying --
`
` 7 MR. SELWYN: I don't think he finished his
`
`Page 31
`
`USR Exhibit 2014, page 31
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 8 answer.
`
` 9 Q I'm sorry, could you --
`
` 10 A I think I did finish.
`
` 11 Q Okay. So you're not saying the data
`
` 12 reader would be located somewhere else, you're
`
` 13 just saying that in certain embodiments there
`
` 14 might not be a data reader; is that what
`
` 15 you're --
`
` 16 MR. SELWYN: Objection., form.
`
` 17 A I think a person of ordinary skill in the
`
` 18 art would see the various embodiments presented
`
` 19 in Reber and come to the conclusion that the
`
`Page 32
`
`USR Exhibit 2014, page 32
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 20 data reader is used where needed and not used
`
` 21 where needed depending on the goals and
`
` 22 engineering constraintsf building a particular
`
` 23 embodiment.
`
` 24 Q I'm just talking about Reber's disclosures
`
` 25 in figure one there's a data reader shown I'm
`
` 16
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 asking you in the embodiment of figure one?
`
` 3 A Mm-hmm.
`
` 4 Q Is the data reader at the users location?
`
` 5 MR. SELWYN: Objection; form.
`
`Page 33
`
`USR Exhibit 2014, page 33
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 6 A Be in the embodiment of figure one there
`
` 7 is a data at users location as the
`
` 8 alternatively embodiment disused emwhere in the
`
` 9 Reber item column one fours alternatively
`
` 10 embodiment which do not especially entail a
`
` 11 data reader.
`
` 12 Q Okay. But in the embodimentless that are
`
` 13 shown with the data reader the data reader is
`
` 14 at the users location, right?
`
` 15 MR. SELWYN: Objection; form.
`
` 16 A All I can say that the embodiment shown in
`
` 17 figure one shows a data reader.
`
`Page 34
`
`USR Exhibit 2014, page 34
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 18 Q Okay. And you don't see any embodiment
`
` 19 that shows a data reader at a location other
`
` 20 than the end users location?
`
` 21 MR. SELWYN: Objection; form.
`
` 22 A Can you real estate the question, please.
`
` 23 MR. HEFAZI: You don't see any embodiment
`
` 24 that shows a data reader at a location other
`
` 25 than the user location.
`
` 17
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 MR. SELWYN: Objection to form.
`
` 3 A That's a question that I wasn't at the top
`
`Page 35
`
`USR Exhibit 2014, page 35
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 4 of my whether or not there was a data reader
`
` 5 present at any other locations, was not a issue
`
` 6 that I considered in preparing medley and
`
` 7 preparing my mappings.
`
` 8 Q Okay?
`
` 9 A To the best of my knowledge I don't recall
`
` 10 one as I said that wasn't a top priority for
`
` 11 analyzing.
`
` 12 Q And you mentioned you know first data
`
` 13 element and a second data element let's discuss
`
` 14 that for a second.
`
` 15 There's a device here labeled device 40.
`
`Page 36
`
`USR Exhibit 2014, page 36
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 16 Do you see that this is figure one?
`
` 17 A Yes.
`
` 18 Q And device 40 that's used -- well, strike
`
` 19 that.
`
` 20 There's also a device in figure one
`
` 21 showing device 52.
`
` 22 Do you see that?
`
` 23 A Just a moment. Fifty-two, yes.
`
` 24 Q Okay. And device 40 examples cuff device
`
` 25 40 are -- strike that.
`
` 18
`
` 1 ROUGH DRAFT - SHOUP
`
`Page 37
`
`USR Exhibit 2014, page 37
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 2 Examples of the device 40 in figure one
`
` 3 are shown as figures two through four reader;
`
` 4 is that right?
`
` 5 A Those are some examples, yes.
`
` 6 Q Okay. And some examples of device 52 are
`
` 7 also shown in figure five through seven of
`
` 8 Reber, correct?
`
` 9 A Those are some examples, yes.
`
` 10 Q Okay. Now, to initiate a transaction, the
`
` 11 end user needs to generate two types of data a
`
` 12 first data element and a second data element;
`
` 13 is that right?
`
`Page 38
`
`USR Exhibit 2014, page 38
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 14 A That's correct and the for the record and
`
` 15 second data element are generated at the users
`
` 16 location, correct.
`
` 17 A I believe that's correct.
`
` 18 Q And to generate the second data element,
`
` 19 the user can scan machine readable on device
`
` 20 40; is that correct.
`
` 21 A Repeat the question.
`
` 22 Q So to generate the second data element the
`
` 23 user can scan the machine readable data labeled
`
` 24 36 in figure one within device 40?
`
` 25 A That's one possible embodiment. As I also
`
`Page 39
`
`USR Exhibit 2014, page 39
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 19
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 already mentioned at Column 4, Line 1, Reber
`
` 3 says alternatively, the second data element is
`
` 4 generated within the network access apparatus
`
` 5 32. I won't read the rest of it.
`
` 6 Q Okay. So the network apparatus is another
`
` 7 way, in your opinion, to generate the second
`
` 8 data element, right?
`
` 9 A That's correct.
`
` 10 Q Okay. And to generate the first data
`
` 11 element, the user can scan the machine readable
`
`Page 40
`
`USR Exhibit 2014, page 40
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 12 50 on device 52?
`
` 13 Q That's one possible embodiment. As I
`
` 14 already mentioned another embodiment disclosed
`
` 15 at Column 4, line 50, is that alternatively the
`
` 16 first data elements is generated in response to
`
` 17 a user initiated user event, you see device of
`
` 18 the network access apparatus 32.
`
` 19 Q You mentioned embodiment a couple of
`
` 20 times.
`
` 21 You agree that Reber discloses multiple
`
` 22 embodiments?
`
` 23 A Okay, yes.
`
`Page 41
`
`USR Exhibit 2014, page 41
`
`
`
`Rough Draft_Victor Shoup.txt
`
` 24 Q Do you agree there's multiple of
`
` 25 embodiment in discussed in the Reber patent?
`
` 20
`
` 1 ROUGH DRAFT - SHOUP
`
` 2 A Yes.
`
`
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
