UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE TRIAL AND APPEAL BOARD
`
`Page 208
`
`AVAYA, INC., )
` )
` Petitioner, )
` ) Case No.
`vs. ) IPR2013-00071
` )
`NETWORK-1 SECURITY ) Patent 6,218,930
`SOLUTIONS, INC., )
` ) Volume II
` Patent Owner. )
`_____________________________)
`
` Irvine, California
` October 25, 2013
`
` Videotaped deposition of DR. GEORGE A. ZIMMERMAN,
`called as a witness by counsel for the Patent Owner in
`the above-entitled matter, pursuant to Notice, taken at
`3 Park Plaza, 20th Floor, Irvine, California, beginning
`at 9:10 a.m. and ending at 3:20 p.m., on Friday,
`October 25, 2013, before Lisa O'Sullivan, California
`Certified Shorthand Reporter No. 7822, RMR, CRR.
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`Job 67223
`Reporter: Lisa O'Sullivan
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` BEFORE THE TRIAL AND APPEAL BOARD
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`Page 208
`
`AVAYA, INC., )
` )
` Petitioner, )
` ) Case No.
`vs. ) IPR2013-00071
` )
`NETWORK-1 SECURITY ) Patent 6,218,930
`SOLUTIONS, INC., )
` ) Volume II
` Patent Owner. )
`_____________________________)
`
` Irvine, California
` October 25, 2013
`
` Videotaped deposition of DR. GEORGE A. ZIMMERMAN,
`called as a witness by counsel for the Patent Owner in
`the above-entitled matter, pursuant to Notice, taken at
`3 Park Plaza, 20th Floor, Irvine, California, beginning
`at 9:10 a.m. and ending at 3:20 p.m., on Friday,
`October 25, 2013, before Lisa O'Sullivan, California
`Certified Shorthand Reporter No. 7822, RMR, CRR.
`
`Job 67223
`Reporter: Lisa O'Sullivan
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` A P P E A R A N C E S O F C O U N S E L
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`Page 209
`
`For Petitioner AVAYA, INC.:
`CROWELL & MORING
`3 Park Plaza, 20th Floor
`Irvine, California 92614
`
`By: JONATHAN LINDSAY, ESQ.
`
`For Patent Owner NETWORK-1 SECURITY SOLUTIONS, INC.:
`
`DOVEL & LUNER
`201 Santa Monica Boulevard, Suite 600
`Santa Monica, California 90401
`
`By: GREGORY DOVEL, ESQ.
`
`For DELL, INC.:
`WINSTON & STRAWN
`200 Park Avenue
`New York, New York 10166
`
`By: MICHAEL SCHEER, ESQ.
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` I N D E X
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`Page 210
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`WITNESS: DR. GEORGE A. ZIMMERMAN
`EXAMINATION PAGE
` BY MR. DOVEL 212, 363
` Afternoon Session 310
` BY MR. LINDSAY 362
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` I N D E X T O E X H I B I T S
`
`FOR THE PATENT OWNER
`NUMBER DESCRIPTION PAGE
`Exhibit 10 Second Declaration of Dr. George 212
` A. Zimmerman
`
`Exhibit 11 Matsuno Japanese Patent 212
` Application, AV-1004
`Exhibit 12 Katzenberg et al. Patent, AV-1001 320
`Exhibit 13 Document Entitled "Figure 3" 241
`Exhibit 14 Woodmas Patent 351
`Exhibit 15 Errata to Volume I of Deposition 354
`
` EXHIBITS PREVIOUSLY MARKED
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`NUMBER DESCRIPTION PAGE
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`Exhibit 6 Figure 5 with Handwritten 310
` Notation
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` IRVINE, CALIFORNIA - OCTOBER 25, 2013
` 9:10 A.M.
`
`Page 212
`
` (Witness is sworn in.)
` MR. DOVEL: Dr. Zimmerman, I've had marked as a
`couple of exhibits I'm going to place in front of you.
`The first is your second Declaration. This will be
`Exhibit Number 10.
` (Exhibit 10 is marked for identification
` and is appended hereto.)
` THE WITNESS: Okay.
` MR. DOVEL: The next exhibit will be Exhibit
`Number 11, which is a copy of the Matsuno reference.
` THE WITNESS: Thank you.
` (Exhibit 11 is marked for identification
` and is appended hereto.)
` GEORGE ZIMMERMAN, PhD,
` having been first duly sworn,
` was examined and testified as follows:
` EXAMINATION
`BY MR. DOVEL:
` Q. In your Declaration, you state that the Matsuno
`reference teaches that about 8 volts would be available
`at the -- at the subscriber's home when the 48-volt
`power supply is being used; is that right?
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` A. I do state that. I state that, making --
`making a direct inference off of what it describes for
`the 120 volts.
` Q. In preparing for today's deposition, did you
`read your deposition that we took last time, the first
`deposition?
` A. Not in preparing for today's deposition, no.
` Q. Have you read the transcript of the -- of your
`first deposition?
` A. Yes, I have.
` Q. How many times did you read the transcript of
`your first deposition?
` A. A few. Probably not more than three times. It
`was a while ago.
` Q. While reading it, did you make note of any
`errors in the transcript?
` A. Errors in the -- the only errors are the one --
`that I made note of are the ones that I submitted as
`errata early on. I think that was to prepare the final
`transcript.
` Q. When you say "submitted as errata," when was
`that errata submitted?
` A. It was sometime in late July, I believe. And I
`believe that was off of -- if I may correct, I think
`that the copy that I had been reading was -- may not
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`Page 214
`have been the final. But, you know, there were things
`like words that were, you know -- words that were
`phonetically similar but not the same words.
` Q. When you prepared this list of errata, was that
`in handwritten document or a -- was it an electronic
`document?
` A. I believe I emailed them.
` Q. Emailed them to whom?
` A. I believe I emailed them to Jonathan.
` Q. To Jonathan who?
` A. Jonathan Lindsay.
` MR. DOVEL: I'll have to check, Mr. Lindsay. I
`don't think we got those. Did you forward those on to
`us?
` MR. LINDSAY: No. No, we did not submit those
`in this proceeding.
` THE WITNESS: Yeah, I don't recall there being
`anything that -- anything that was -- you know, made a
`technical change in the document. They were all more
`editorial.
`BY MR. DOVEL:
` Q. What do you mean by "editorial" versus
`"technical"?
` A. Sorry. That's language we often use when
`writing -- when writing standards. A technical change
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`might be, say, changing a number from, you know, 8 to 12
`or something like that. An editorial change might be
`there's a typographical error or some words that I may
`have said one word that makes sense, and another word
`that -- and another word that sounds similar showed up
`there.
` Q. You read through the transcript. You made a
`list of errata that you submitted to Mr. Lindsay. Did
`you read through the transcript at any time after that?
` A. I may have -- I may have once. Certainly not
`in -- certainly not in total. In some instances, while
`reading the patent owner's response, where it quoted
`parts of the transcript, I read the part and some of the
`small amount of the surrounding testimony there.
` Q. In reading your transcript, did you notice
`anything that you believed was erroneous?
` MR. LINDSAY: Objection. Cumulative.
` THE WITNESS: I don't -- I don't recall. There
`wasn't -- there wasn't anything that came out sort of
`egregious that I didn't -- that wasn't -- you know,
`there were some instances where, as questioning went on,
`thoughts became clearer for answers, but those are all
`reflected in the transcript.
`BY MR. DOVEL:
` Q. Is there any reason that we can't rely upon
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`your testimony in the first deposition, your transcript?
` A. I don't think so. There are some instances
`where, since the first deposition, in reviewing Matsuno,
`I saw things in the text there that I had not been
`previously aware of. You know, for example, the voltage
`drop that's in the text of Matsuno that you referenced
`earlier.
` Q. All right. When you say you saw some things in
`Matsuno that you hadn't noticed earlier, is there any
`reason that any of your answers -- withdrawn.
` Is there any reason that any of the answers you
`gave in your first deposition should not be relied upon
`as accurate and correct?
` MR. LINDSAY: Objection. Cumulative.
` THE WITNESS: Well, I mention that because I'd
`have to sit down and really go through the detail of
`that.
` But there were a number of cases in the --
`there were a number of questions that I recall in the --
`in the first deposition, but don't recall with enough
`specificity to tell you, that asked me, for example:
`Does Matsuno discuss X? Does Matsuno discuss Y? And,
`you know, it's possible that some of those things that I
`saw in Matsuno later, that I was able to find there, I
`may have answered and did not discuss it.
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` A more correct answer in those cases might be,
`you know, at this time, not to my knowledge. And as you
`go on reading something, you tend to -- you tend to be
`able to find more things in it. Usually, you don't
`remove things that you found in it before.
`BY MR. DOVEL:
` Q. You told me about possibilities. Have you
`identified any instance when you answered a question in
`your first deposition where you now think, well, that
`answer is wrong?
` A. I have neither sat down to review recently with
`that in mind nor has that really been something I've
`been charged to do. But, you know, as a result of that
`fact, no, I haven't identified any particular instances.
` Q. Now, as I understand your Declaration, you said
`that Matsuno's discloses that there is 120 volts
`available at the power source, and that drops to 80
`volts when we got to the subscriber's home; is that
`right?
` A. That is correct.
` Q. And what is responsible, as you understand it,
`for that voltage drop?
` A. That's the current going across the loop
`resistance of the line.
` Q. In order to then determine what that voltage
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`drop was, you said: Well, we'll subtract 120 minus 80.
`That means it's a 40-volt drop; right?
` MR. LINDSAY: Objection. Misstates prior
`testimony.
` THE WITNESS: That would be how I would
`calculate that voltage drop.
`BY MR. DOVEL:
` Q. Now, if we've got the same circumstance and now
`we switch in the 48 volts, then you said: Well, if it's
`a 40-volt drop, the 48s would then drop 40 volts down to
`8 volts at the home. Is that right?
` A. If I were -- if I were feeding under the --
`under the same circumstances. That is what I stated in
`here. I did not enter into a long, complicated
`discussion of how there's actually a whole family of
`curves you could be on.
` Q. Well, just explain to me. When I read that, I
`was, well, frankly confused that anyone with a --
`spending even a couple years in electrical engineering
`would do that calculation. So I want to see how you did
`it.
` MR. LINDSAY: Objection. Argumentative.
` MR. DOVEL: Let me go ahead and get my question
`out.
` Q. Is it the case that if you've got 120-volt
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`supply and it results in 80 volts after we cross the
`subscriber loop and if we use 48 volts, it's going to
`result in the same 40-volt drop?
` A. If I have the -- if I have the same level of
`current, it will. If I have a constant current source
`there -- and Matsuno actually discusses constant current
`sources in places -- that would be the drop I would get.
`But as I had said earlier, a more correct set of
`calculations would be an entire family of currents.
` They end up with essentially the same result.
`The 48 volts is insufficient to power the device.
` Q. Isn't the correct way to -- isn't the --
`withdrawn.
` The voltage drop is proportional to that
`resistance; right?
` A. The voltage drop is proportional to the product
`of that resistance and the current.
` Q. So it's proportional to resistance; right?
` MR. LINDSAY: Objection. Cumulative.
` THE WITNESS: It's proportional to the product
`of the resistance and the current.
`BY MR. DOVEL:
` Q. Well, the voltage is equal to the current times
`the resistance; right?
` A. The voltage drop is equal to the current times
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`the resistance, yes.
` Q. All right. Now, is it the case that if --
`doesn't that mean that if we go from 120 volts to 80
`volts, we've had a one-third voltage drop; right? 33
`percent voltage drop; correct?
` A. That is correct.
` Q. So if we go from 48 volts with a 33 percent
`voltage drop, we would get down to 32 volts, not 8
`volts; right?
` A. If I have a constant impedance load at the --
`at the subscriber end. I don't have a -- I don't have
`the specifications to what the impedance looks like at
`that subscriber end. If it's the same in both cases,
`then sure. But if it's actually set up to take a
`constant amount of current, I'd have the -- I'd have the
`40-volt drop.
` Q. Well, what -- if we look at the 120, that's
`telling us the voltage to ground at one end of that
`system; right?
` MR. LINDSAY: Objection. Form.
` THE WITNESS: The 120 is both the voltage to
`ground and the voltage between the tip and the ring
`line, since one of them is at ground.
`BY MR. DOVEL:
` Q. Then if we go to the other side, the 80 volts
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`is -- is that the voltage to ground also?
` MR. LINDSAY: Objection. Form.
` THE WITNESS: The 80 volts at the other side is
`the voltage offered between the tip and the ring lines.
`BY MR. DOVEL:
` Q. So we're looking at the voltage between the tip
`and the ring lines at one side versus at the other side;
`right?
` A. That's correct, yes.
` Q. And the difference in voltage is a result of
`that -- as you said, the resistance that's in the wire?
` MR. LINDSAY: Objection. Misstates prior
`testimony.
` THE WITNESS: The difference is a result of the
`voltage drop across the resistance of the subscriber
`loop. Yes.
`BY MR. DOVEL:
` Q. If we have 48 volts rather than 120 volts on
`that system, that would suggest that that same
`subscriber loop -- that we would wind up with 32 volts
`at the -- at the equipment end; right?
` A. As I said before, to complete the circuit, you
`have to make assumptions as to what's the load
`impedance. If I assume that the load is a constant
`resistive impedance, in that case, then I would get the
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`answer that you're suggesting.
` If I assume that the load is a -- is requiring
`a constant current draw -- and like I said, Matsuno does
`speak a little bit about constant current sources -- I
`would get the 80 volts -- I'm sorry -- the 40-volt drop.
` Q. Well, when you did this calculation, what does
`Matsuno say is going on at the subscriber end?
` A. He doesn't say what the impedance is at the
`subscriber end, to my knowledge. I did not see that
`there.
` Q. Does Matsuno then teach that the voltage drop
`is -- for 40 volts goes down to 8, or does it teach you
`that it goes down to 32, or does he not say anything one
`way or the other?
` A. Matsuno teaches that the voltage drop for the
`120 volts, when the -- when it's supplying enough
`current to have the access device operational in minimal
`communications, is 40 volts. Matsuno actually didn't
`talk about that -- about what's happening with the
`48 volts. But from that -- from that discussion, the
`120 volts, you can infer a family of both power draw at
`the access device and loop resistance.
` And the most likely one and the easiest one to
`actually -- to discuss and demonstrate and, therefore,
`is in my Declaration, is an 80-volt drop.
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` As I said before, there's a whole family of
`them. And if I want to assume that the access device is
`a constant resistance load, I would get the
`two-thirds/one-third split that you have there, which
`ends up being a different voltage drop, but you're still
`delivering a -- you're still requiring a -- if you look
`at the 120 volts, you're delivering roughly 13 watts, if
`you assume that the loop resistance is as Dr. Knox has
`said, which is fairly short.
` The more reasonable loop resistance, you're
`still delivering numbers in the order of, you know, 5
`or -- 5 watts, which is more than has been there. I
`mean, I could go on for quite a while. It's just the
`number of various possibilities, they're all pretty far
`out of the range of that was being discussed in
`Dr. Knox's Declaration.
` Q. Well, let's focus on just one step at a time.
`Let's first focus on what the calculation of the voltage
`is going to be at the subscriber end.
` A. Okay.
` Q. You would agree, sir, that based on what
`Matsuno discloses, if we start with 48 volts and if
`there's a one-third drop, that's going to suggest that
`there's going to be 32 volts at the subscriber end, not
`8 volts; right?
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` MR. LINDSAY: Objection. Asked and answered.
` THE WITNESS: Well, so Matsuno doesn't disclose
`what the impedance is at the subscriber end, to my
`knowledge, so I can't agree with your statement as you
`posited it.
` If you add the assumption that the subscriber
`end is a constant resistance source, then I -- or
`likewise were to show me that in Matsuno, then I might
`agree with it. But, you know, you asked: Does Matsuno
`disclose it? Not to my knowledge.
`BY MR. DOVEL:
` Q. Based on what Matsuno discloses -- withdrawn.
` Is it the case, then, that you cannot --
`Matsuno doesn't disclose whether the calculation should
`arrive at 8 volts or at 32 volts?
` A. Matsuno does not -- it does not definitively
`disclose that. Because Matsuno uses constant current
`sources, the most consistent interpretation with Matsuno
`would be a -- would be a 40-volt drop.
` Q. If we look at Paragraph 27 of Matsuno --
` A. Okay.
` Q. It describes the reason for the voltage drop
`from 120 to 80 volts in Paragraph 27; right?
` A. Yes. At the end of the -- near the end of the
`paragraph, yes.
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` Q. Does Matsuno say that the reason for the
`voltage drop from 120 to 80 is because of the voltage
`drop of the digital subscriber line 12 and the voltage
`drop of the transistors 24a and 24b?
` A. That is what it says.
` Q. And do you agree that that's what Matsuno
`discloses, is the basis for the voltage drop from 120 to
`80?
` MR. LINDSAY: Objection. Cumulative.
` THE WITNESS: I would agree with that.
`BY MR. DOVEL:
` Q. The voltage drop from 120 to 80 is not because
`of the resistance of whatever equipment is attached at
`the subscriber end; right?
` A. As I said earlier, that voltage drop is
`primarily because of the weak resistance of the
`subscriber line. But the resistance of the -- the
`resistance of what's at the subscriber end plays a part
`in determining that because it relates to the current
`draw that it's seen over that resistance.
` Q. The voltage drop from 120 to 80 is not a
`reflection of the resistance of the equipment at the
`subscriber end; right?
` MR. LINDSAY: Objection. Form.
` THE WITNESS: It is not a -- it is not a direct
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`function of that, no. That's correct.
`BY MR. DOVEL:
` Q. Direct or indirect?
` A. It's complicated because it's related, as I
`said before and as we went through with the -- with the
`examples of various assumptions of what the -- what
`resistance the subscriber end could present.
` Q. What this tells us is that a 40-volt drop
`between the 120 and 80 is not solely the result of the
`resistance from the subscriber line; right? There's two
`components to it.
` A. And the second component that you're suggesting
`is?
` Q. Well, Matsuno says there are two components.
`One is the resistance of the subscriber line. The other
`is the voltage drop caused by the transistors 24a and
`24b; right?
` A. That is correct. That -- that would generally
`not be a very -- we would not expect that to be a very
`large voltage drop.
` Q. Well, I'm going to get to the magnitude in a
`second.
` A. But I would agree that there's two components.
`But I would say that it would be predominantly the
`voltage drop of the subscriber line, and the other one
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`is really much more of a secondary factor.
` Q. Well, we're going to discuss that in some
`detail. Maybe you'll agree at the end of the day; maybe
`you won't.
` A. Okay.
` Q. But you would agree that this 40-volt drop is
`comprised of two things: One is the resistance of the
`subscriber line, the other is what's going on with those
`transistors; right?
` MR. LINDSAY: Objection. Cumulative.
` THE WITNESS: I would agree that that's the
`case. At this point, we have a disagreement as to which
`one's the dominant effect, but yes.
`BY MR. DOVEL:
` Q. Well, Matsuno itself doesn't expressly state
`which one is the dominant effect; right?
` A. Not there. One in ordinary -- one of ordinary
`skill in the art, though, wouldn't be providing
`120 volts just to drop a whole bunch of it across a
`transistor at the supply station.
` Q. Well, we're going to get to that.
` Let me just be clear, though. You agree that
`Matsuno doesn't expressly state: Well, the 40-volt drop
`from 120 to 80, it's predominantly the result of the
`subscriber line; very little of it is the transistors.
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` It doesn't say that; right?
` MR. LINDSAY: Objection. Cumulative.
` THE WITNESS: I don't see that statement there.
`Yes.
`BY MR. DOVEL:
` Q. The purpose of these transistors -- withdrawn.
` Let's take a look at -- well, the purpose of
`these transistors is to make certain that we're
`delivering 80 volts at the home and not 120; right?
` A. No.
` Q. What's the purpose of those transistors?
` A. The purpose of those transistors are to
`regulate a constant current source. Those transistors
`don't have any sense feedback from the home, and
`therefore, their purpose could not be to make sure that
`we have only 80 volts at the home.
` Q. If it's the case that the subscriber line is,
`say, 200 feet, then you would agree that if we've got a
`40-volt drop, that subscriber line is not responsible
`for most of that 40-volt drop; right?
` MR. LINDSAY: Objection. Insufficient
`hypothetical.
` THE WITNESS: I believe you're postulating
`there that the disclosure in Matsuno of an 80-volt -- of
`a 40-volt drop is constant for every subscriber line
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`that there is. And I did not see any such disclosure in
`Matsuno.
` I understood the disclosure in Matsuno, when it
`came to the voltage at the subscriber line -- the
`voltage at the subscriber's home to be for some typical
`subscriber lines that would be in the application. I
`did not take it to apply to every subscriber line.
`Therefore, I wouldn't expect to see only 80 volts if the
`subscriber line were, you know, atypically short.
`BY MR. DOVEL:
` Q. Let's assume that we've got a relatively short
`subscriber line. You would agree, then, that if we
`start with 120 volts, that that -- those transistors
`could be used to produce the voltage in the home so that
`it's 80 volts; right?
` MR. LINDSAY: Objection. Insufficient
`hypothetical.
` THE WITNESS: No, I would not agree with that.
`As I said before, they require a sense point to do that,
`and there is no sense lead that I could see in the
`diagrams or in the disclosure.
`BY MR. DOVEL:
` Q. Well, you mean a sense point if you were trying
`to get it exactly 80 volts; right?
` A. Even approximately. There's none -- there is
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`Page 230
`no indication that the supplies or those transistors had
`any direct knowledge of what the loop resistance was.
` Q. But the person designing it's going to have an
`idea about what the loop resistance is, typical loop
`resistance; right?
` MR. LINDSAY: Objection. Form.
` THE WITNESS: There is -- the person designing
`the equipment may understand a typical loop resistance,
`but would not understand the specific loop resistance to
`which the device was connected to in an instant.
`BY MR. DOVEL:
` Q. So the person designing it would understand
`that -- what the typical loop resistance is and
`therefore would design it so that in a typical
`situation, it would deliver 80 volts or -- as it says,
`80 volts or less to the home; right?
` MR. LINDSAY: Objection. Form.
` THE WITNESS: Well, the person who would be
`designing it for would not -- would not, in my
`familiarity with designing equipment for telephone
`companies -- and I spent five years delivering equipment
`for digital subscriber lines to telephone companies, and
`actually one of them was NTT. The designer would
`actually be concerned with the worst case, not the
`typical.
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`Page 231
` And so they would design this to make sure that
`it could, in fact, supply the current to those
`worst-case loops. Typically, worst case is somewhere in
`the 90 percentile region.
`BY MR. DOVEL:
` Q. Well, worst case, if one wanted to -- if one
`was concerned about having too much voltage in the home,
`the worst case would be when you've got a short
`subscriber loop; right?
` A. If one were concerned of that, that would be
`the case. But for one designing this equipment, one
`would be concerned about providing the functionality.
`Otherwise, they just simply avoid providing any current
`at all.
` Q. You've got to be concerned about both things;
`right?
` A. Matsuno is concerned about the safety, and he
`doesn't really -- there's not a -- in my experience with
`electrical codes, there isn't a real material difference
`between an 80-volt circuit and a 120-volt circuit, from
`a safety standpoint. Both of them are considered --
`well, they're not considered low-voltage circuits. I
`don't know whether they're mid-voltage or high-voltage.
`Depends on the region.
` Q. If your goal was to be able to deliver
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`80 volts, you might have 120-volt circuits, you'd have
`some extra head room; right?
` MR. LINDSAY: Objection. Form.
` THE WITNESS: I might. That would be a lot of
`head room.
`BY MR. DOVEL:
` Q. Is it the case that in a -- when we're talking
`about equipment, that the amount of voltage required for
`the typical ISDN equipment for minimal operation is on
`the order of 28 volts?
` A. If you're -- if you're only talking about
`powering a -- you know, powering a minimal NT1, and
`usually that's in Europe, that would be the case, but
`that's not really the situation that Matsuno is
`describing.
` Q. Well, Matsuno's just talking about NT1s; right?
` A. Matsuno is talking about powering NT1s that
`also are powering -- powering DTE in the event of a
`power failure.
` Q. Would one -- withdrawn.
` If we've got a subscriber loop that is a couple
`hundred feet, what would you anticipate that the voltage
`drop would be from 120 volts?
` MR. LINDSAY: Objection. Insufficient
`hypothetical.
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` THE WITNESS: I don't know. It would depend
`upon the gauge and resistance per foot of the copper
`itself.
`BY MR. DOVEL:
` Q. You don't have any idea?
` A. Well, the -- it would be small. It would be
`substantially less than 40 volts, unless you were trying
`to draw a large amount of current over it. I mean, if
`the access device itself had a very low impedance, then
`you could drop. You know, it's just a matter of the
`ratios of the impedances between the line and the access
`device.
` If the access device maintained this
`relationship that it has in -- that Matsuno describes
`for the 120 volts, where it appears to have an impedance
`that's roughly twice the impedance of the line, then you
`would have the same 40-volt drop.
` Q. Well, again you're assuming that, twice, that
`this transistor is doing very little, and most of it's
`for the line; right? That's your assumption?
` MR. LINDSAY: Objection. Cumulative.
` THE WITNESS: My assumption is that most of
`that's for the line and the transistor doesn't have a
`lot of drop on it. And that assumption is made because
`it's inconsistent with practices in power supply design,
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`where anything that you drop over that transistor is a
`loss of efficiency in that power supply design.
` And it would absolutely be silly to design a
`power supply to have a low efficiency. Somebody has to
`pay the electric bill, and they're not going to do it by
`burning up these transistors.
`BY MR. DOVEL:
` Q. So let's go back to my example. We've got a
`couple hundred feet of resistance. We've got -- let's
`assume we're using a -- you talked about Class 1,
`Class 2, Class 3 devices; right?
` MR. LINDSAY: Objection. Foundation.
` THE WITNESS: I talked about those in reference
`to the devices that Dr. Knox had posited.
` Those actually are Class 1, Class 2, and
`Class 3 power-over-Ethernet devices, which, to be fair,
`we'd actually require yet another additional piece of
`equipment consuming power between the Matsuno power
`delivery device and those devices to even connect them
`up. But they represent sort of power consumption of
`different types of telephones.
`BY MR. DOVEL:
` Q. Let's assume we've got, then, attached as our
`access equipment, some -- a device that uses relatively
`low power. We're only going 200 feet. What would you
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`anticipate the voltage drop would be?
` MR. LINDSAY: Objection. Insufficient
`hypothetical. Form.
` THE WITNESS: You know, I'd have to -- I'd have
`to know a lot more about the -- about how the
`termination worked in that device for power delivery.
`I'm afraid I -- I'm afraid that was one of the reasons
`why it was -- you know, we were talking earlier about
`this family of curves that you get based upon the
`resistance offered. You don't -- you don't actually
`know what -- I don't actually know what
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