UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 1
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`UNIVERSAL REMOTE CONTROL, INC.,
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` Petitioner,
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` vs. No. IPR2013-00127
`
` Patent 6,587,067 C1
`
`UNIVERSAL ELECTRONICS, INC.,
`
` Patent Owner
`
` _______________________________________________
`
` DEPOSITION OF ALAN JACK HERR
`
` Palo Alto, California
`
` September 24, 2013
`
`Reported by:
`
`KENNETH T. BRILL
`
`CSR NO. 12797
`
`Job No. 1735109
`
`PAGES 1 - 92
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`312-442-9087
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`Universal Electronics Exhibit 2007, Page 1
`Universal Remote Control v. Universal Electronics, Trial No. IPR2013-00127
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`
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`UNIVERSAL REMOTE CONTROL, INC.,
`
` Petitioner,
`
` vs. No. IPR2013-00127
`
` Patent 6,587,067 C1
`
`UNIVERSAL ELECTRONICS, INC.,
`
` Patent Owner
`
` _______________________________________________
`
` DEPOSITION OF ALAN JACK HERR
`
` Palo Alto, California
`
` September 24, 2013
`
`Reported by:
`
`KENNETH T. BRILL
`
`CSR NO. 12797
`
`Job No. 1735109
`
`PAGES 1 - 92
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`312-442-9087
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`Veritext Chicago Reporting Company
`800-248-3290
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`847-406-3200
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`Universal Electronics Exhibit 2007, Page 1
`Universal Remote Control v. Universal Electronics, Trial No. IPR2013-00127
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`
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 2
`
`UNIVERSAL REMOTE CONTROL, INC.,
`
` Petitioner,
`
` vs. No. IPR2013-00127
`
` Patent 6,587,067 C1
`
`UNIVERSAL ELECTRONICS, INC.,
`
` Patent Owner
`
` ____________________________________________________
`
` Deposition of ALAN JACK HERR, Volume 1, taken
`
`on behalf of Patent Owner, at Greenberg Traurig, LLP,
`
`1900 University Avenue, 5th Floor, Palo Alto, CA,
`
`beginning at 9:44 a.m., and ending at 12:25 p.m., on
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`Tuesday, September 24, 2013, before KENNETH T. BRILL,
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`Certified Shorthand Reporter No. 12797.
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`Universal Electronics Exhibit 2007, Page 2
`Universal Remote Control v. Universal Electronics, Trial No. IPR2013-00127
`
`
`
`A P P E A R A N C E S:
`
`Page 3
`
`For Petitioner
`
` SCHWEGMAN LUNDBERG WOESSNER
`
` BY: THOMAS C. REYNOLDS, ESQUIRE
`
` TIMOTHY E. BIANCHI, M.S.E.E., ESQUIRE
`
` 150 Almaden Boulevard, Suite 750
`
` San Jose, CA 95113
`
` (408) 278-4058
`
` (612) 373-6912
`
` treynolds@slwip.com
`
` tbianchi@alwip.com
`
`For Patent Owner
`
` GREENERG TRAURIG, LLP
`
` BY: ERIC J. MAIERS, ESQUIRE
`
` 77 West Wacker Drive, Suite 250
`
` Chicago, IL 60601
`
` (312) 456-1036
`
` maierse@gtlaw.com
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`Universal Electronics Exhibit 2007, Page 3
`Universal Remote Control v. Universal Electronics, Trial No. IPR2013-00127
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`
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`Page 4
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` INDEX
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`WITNESS EXAMINATION
`
`ALAN JACK HERR
`
`Volume 1
`
` BY MR. MAIERS 6
`
` BY MR. REYNOLDS 85
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` PREVIOUSLY MARKED EXHIBITS
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` PAGE
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`Exhibit 1001 U.S. Patent 6,587,067 B2 11
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`Exhibit 1002 U.S. Patent 4,774,511 53
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`Exhibit 1003 U.S. Patent 4,918,439 81
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`Exhibit 1004 U.S. Patent 4,825,200 76
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`Exhibit 1005 Core Reference Manual 82
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`Exhibit 1006 Article Magnavox unveils
`
` Total Remote Tuning System
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` and second generation
`
` Universal Remote Control 53
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2013-00127
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` PREVIOUSLY MARKED EXHIBITS (continued)
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` PAGE
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`Exhibit 1010 Declaration of Alan J. Herr, Ph.D. 9
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`Page 5
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`Exhibit 2003 U.S. Patent 6,587,067 B2 79
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`
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` Palo Alto, California, Tuesday September 24, 2013
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` 9:44 a.m.
`
`Page 6
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` ALAN JACK HERR, after having been
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` first duly sworn, was examined and
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` testified as follows:
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` EXAMINATION
`
`BY MR. MAIERS:
`
` Q. Dr. Herr, can you please state and spell your
`
`name for the record, please.
`
` A. Alan Jack Herr, A-L-A-N, J-A-C-K, H-E-R-R.
`
` Q. Dr. Herr, have you been deposed before?
`
` A. Yes.
`
` Q. And generally, what matters did those -- on
`
`how many different occasions have you been deposed?
`
` A. In civil court, only once. It was the
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`Panasonic case where the -- they used the ear piece for
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`the ringer and it would ring into your ear sometimes and
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`cause deafness. Everything else has been criminal.
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` Q. And in that Panasonic case, did you testify as
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`an expert?
`
` A. I did deposition as expert, but I never
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`testified.
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` Q. Okay.
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` A. It was settled.
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` Q. Okay. Well, then, just to clarify, maybe we
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`should go over a couple things. So you've taken an
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`oath, and that would be the same oath that you would
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`take in court.
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` A. Yes.
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` Q. So this is testimony --
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` A. Yeah, I understand that.
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` MR. REYNOLDS: I'm sorry, make sure that you
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`wait until Eric's finished with his question, so that
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`the stenographer can get --
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` THE WITNESS: Okay.
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` MR. REYNOLDS: -- a clean record.
`
`BY MR. MAIERS:
`
` Q. That was going to be one of my ground rules
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`too, since he's taking down verbal answers, uh-huhs and
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`unh-unhs and, you know, those kind of semi-verbal
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`answers aren't going to suffice, so we need clear yeses,
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`nos, and make sure to speak clearly.
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` Also, if I ask a question and you provide an
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`answer, I will assume that you understood my question.
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`So if at any point you do not understand a question,
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`please feel free to ask me to clarify or explain, you
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`know, what's unclear about my question. Okay?
`
` A. Yes.
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2013-00127
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` Q. Okay. And are you on any kind of medications
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`today that may inhibit your ability to testify
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`Page 8
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`truthfully?
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` A. No.
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` Q. Dr. Herr, did you prepare for today's
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`deposition?
`
` A. I read the patents.
`
` Q. Okay. When you say "the patents", what do you
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`mean?
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` A. The -- I believe it's the '067, the patent on
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`your side, and then Evans and Rumbolt.
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` Q. Rumbolt, I believe.
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` A. Yeah, Rumbolt, yes, sir.
`
` Q. Did you review Wazniak?
`
` A. Also Wazniak, yes.
`
` Q. Okay. What about the Core User Manual?
`
` A. I read part of the Core Use -- User Manual.
`
` Q. Which part?
`
` A. The paging, the -- page number 12, it's -- in
`
`the manual it's paging.
`
` Q. Okay.
`
` A. I remember the page number from -- I looked it
`
`up.
`
` Q. Did you meet with any attorneys in preparation
`
`for this deposition?
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`312-442-9087
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2013-00127
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` A. I met with both of these gentlemen.
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` Q. Okay. When did you meet with them?
`
` A. Yesterday afternoon.
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` Q. Was that the only occasion that you met with
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`them in preparation for this deposition?
`
` A. Yes.
`
` Q. For how many hours roughly did you meet with
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`them yesterday?
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` A. I'm not sure total -- the total working time,
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`about five hours of working time. Not counting lunch,
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`getting lost getting there, stuff like that.
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` Q. Dr. Herr, I'm going to place in front of you
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`what has been marked as -- previously marked as
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`Universal Remote Control Exhibit 1010.
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` MR. MAIERS: I've only got one for you guys.
`
` MR. REYNOLDS: That's good.
`
`BY MR. MAIERS:
`
` Q. Do you recognize this document?
`
` A. Yes.
`
` Q. What is this document?
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` A. I believe you call it -- it's a deposition;
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`right?
`
` Q. I'm sorry?
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` A. I'm not sure the -- it's my Declaration that
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`I -- I did in February, I believe --
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`312-442-9087
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`Veritext Chicago Reporting Company
`800-248-3290
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`Universal Electronics Exhibit 2007, Page 9
`Universal Remote Control v. Universal Electronics, Trial No. IPR2013-00127
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` Q. Feel free to flip through, you know, if you're
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`unclear on the date, you can --
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` A. No, I -- yeah, it was -- like February -- it
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`was filed like the 20 -- it was filed the same day we
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`finished it.
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` Q. Okay. If you turn to Bates page 18.
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` A. Programmable universal remote control serves,
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`this --
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` Q. The page, not the paragraph.
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` A. Oh, okay.
`
` Q. Do you see at the bottom --
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` A. Yeah.
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` Q. -- where it says the page?
`
` A. Yes, sir. Back side.
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` Q. You'll see that it's dated January 25th,
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`2013. Do you see that?
`
` A. Yes.
`
` Q. So it's fair to say that you completed this
`
`Declaration prior to the filing of the petition?
`
` A. Yes, I finished it about 3:00 o'clock that
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`morning --
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` Q. Okay.
`
` A. -- because they --
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` Q. And to be fair, I think a little bit confusion
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`here lies in the fact that when you refer to the filing
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`312-442-9087
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`Universal Electronics Exhibit 2007, Page 10
`Universal Remote Control v. Universal Electronics, Trial No. IPR2013-00127
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`
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`date, I believe that's actually the filing date of the
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`'067 patent that's on the cover of your Declaration --
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`Page 11
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` A. Okay, yeah.
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` Q. -- the February 23rd, 2001.
`
` A. Yeah.
`
` Q. Okay. If I could direct your attention to
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`Appendix B of your report. It's the last page.
`
` A. Yes, sir.
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` Q. And by report, I mean Declaration, I'm sorry.
`
`What is Appendix B to your Declaration?
`
` A. It's a list of the patents related to it, Core
`
`Reference Manual, and a public -- a press release of
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`Magnavox on their second generation Universal Remote
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`Control for T.V. sets and stereos.
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` Q. You say it's a list of patents related to it.
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`What is "it"?
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` A. Related to the first exhibit, 1001, the '067
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`patent by Darbee and all.
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` Q. And you see at the top it says: The following
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`is a list of documents reviewed in forming the --
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` A. Yes.
`
` Q. -- opinions discussed in this Declaration?
`
` A. Mm-hmm, yes, sir.
`
` Q. Is that an exhaustive list?
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` A. It's an exhaustive list for what's contained
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2013-00127
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`in this document. I've looked at a lot of other
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`documents including press releases, magazines, like
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`video, stuff like that, stereo magazines at the time.
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` Q. Okay.
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` A. I do not remember all of them.
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` Q. So --
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` A. This is like a year -- it's almost six months
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`ago.
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` Q. Right. And you don't recall -- do you recall
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`specifically any of those other documents that you may
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`have reviewed?
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` A. Video magazines.
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` Q. What specifically video --
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` A. Not saying the magazine -- video.
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` Q. Oh, okay.
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` A. Radio and T.V. times. CES, there's a CES
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`magazine that existed in those days, it was actually
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`a -- like a little -- a newspaper, mini newspaper.
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` Q. Okay.
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` A. I've looked at that on microfilm.
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` Q. Do you know, was that an annual magazine that
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`was released when they had their big conference every
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`year, or was it ongoing?
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` A. I think it came out every three months, I'm
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`not sure.
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`312-442-9087
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`Universal Electronics Exhibit 2007, Page 12
`Universal Remote Control v. Universal Electronics, Trial No. IPR2013-00127
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` Q. Okay. Were those documents that you reviewed
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`Page 13
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`on your own initiative?
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` A. Yes.
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` Q. But your review of those documents did not
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`influence any of your opinions contained in your
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`Declaration?
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` A. No, everything that's in this Declaration is
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`in the Appendix.
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` Q. Okay. Prior to signing and submitting your
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`Declaration, did you have any conversations with
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`Universal Remote Control's attorneys?
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` A. I don't think I've ever talked to anyone --
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`the universal controls are your guys' --
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` Q. No, Universal Remote Control is the petitioner
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`in this matter.
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` A. No. The only people I've talked to is --
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`well, who are the attorneys --
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` Q. Well, as far as I'm aware, Mr. Reynolds and
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`Mr. Bianchi are Universal Remote Controls --
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` A. Okay, okay.
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` Q. -- attorneys.
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` A. And I also talked to --
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` Q. And they have litigation counsel, which I am
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`not I aware of what their names are.
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` A. The other one I talked to on this project at
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`Universal Electronics Exhibit 2007, Page 13
`Universal Remote Control v. Universal Electronics, Trial No. IPR2013-00127
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`their site was Greg Sharp -- Sarp -- how do you
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`pronounce his last name?
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` MR. BIANCHI: Stark.
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` THE WITNESS: Stark. I'm sorry, it's been a
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`long time ago, and it was kind of a stressful time. My
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`mother died this day.
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`BY MR. MAIERS:
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` Q. I'm sorry to hear that.
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` A. So that's -- I have -- if I stop and think a
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`little bit, I have -- that's the reason why I'm trying
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`to remember.
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` Q. Sure.
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` A. And make it accurate.
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` Q. Mm-hmm. Did any of those conversations with
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`any of Universal Remote Control's attorneys influence
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`any of your opinions reflected in your report, on your
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`Declaration?
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` A. No. It was the other way. I was explaining
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`things to them.
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` Q. Okay.
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` A. Technical things.
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` Q. Did you review prosecution histories of the
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`'067 patent in preparation for -- I'm sorry, in forming
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`the opinions in your Declaration?
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` A. No, I had not seen them at this time. The
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`only thing I've -- well, what's a prosecution?
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` I saw the original that was filed against
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`them, or against.
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` Q. Let's take a step back. So when I say
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`prosecution history, I'm referring to the paper history
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`of the back and forth between the applicant and the
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`patent office in the process of obtaining the '067
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`patent.
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` A. The only thing I saw was -- I guess there's an
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`initial filing by your side. And that was included when
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`it was sent -- I go through New, which is -- or New
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`Experts, which is a firm that finds expert witnesses.
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` And they sent me a copy of it and a list of
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`attorneys on both sides to make sure I didn't have any
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`conflicts. And I knew no one, but they sent the
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`original to me. They always send it to you initially to
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`make sure you have no conflicts with anyone.
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` Q. When you say there is an initial filing by our
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`side --
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` A. It's -- it showed that filed with a court, a
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`plaintiff and a defendant.
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` Q. Okay. You're talking about the lawsuit and
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`not the inter partes review proceedings?
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` A. I have -- it's been a long time and I --
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` Q. Okay.
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` A. -- I'd get on a computer and find it.
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` Q. Okay.
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` A. What went back and forth I didn't know about
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`at that point.
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` Q. Sure. How about this, can I direct your
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`attention to paragraph number 22 of your --
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` A. Sure.
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` Q. -- Declaration.
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` A. Yes, sir.
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` Q. Bear with me for a second.
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` If you'll look about halfway down in that
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`paragraph, the sentence starting "In comparing", where
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`you state, "In comparing the claims of the '067 patent
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`to the known prior art, I have carefully considered the
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`'067 patent and the prosecution history of the '067
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`patent based on my experience and knowledge in the
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`relevant field."
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` A. Yeah.
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` Q. So is it accurate or is it inaccurate that you
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`reviewed the prosecution history in an eff- --
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` A. What I knew of that at the time was just the
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`initial that was sent, that show someone is suing
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`someone else in -- that's what I thought the prosecution
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`history is.
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` Q. Okay. So when you refer to prosecution
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`history here, you were not referring to the original
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`application as filed by the patent owner, or any of the
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`series of back and forth communications with the patent
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`office prior to the issuance of the patent, is that
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`right?
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` MR. REYNOLDS: Objection, form.
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` THE WITNESS: Could you ask that question
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`again, so --
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`BY MR. MAIERS:
`
` Q. Sure. When you refer to properties -- use the
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`words the "prosecution history of the '067 patent" here
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`in paragraph 22, when you use those words, you were not
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`referring to the -- the back and forth communications
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`with the U.S. Patent Office prior to the issuance of the
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`'067 patent?
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` A. You're talking about the jack- -- what they
`
`call the jacket?
`
` Q. Right. Or the file wrapper they sometimes
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`call it too.
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` A. File -- I don't think I've ever seen the file
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`wrapper on this. Before I take anything as an expert
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`witness, I Google it to see what's there.
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` Q. Okay.
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` A. Because I'm trying to make sure I'm not
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`working for a patent troll.
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` Q. Okay.
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` A. And I Google the attorneys, the company, stuff
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`like that.
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` Q. Okay.
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` A. That's what I did. Is that appropriate answer
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`for -- you're looking for?
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` Q. As long as it's the truth.
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` A. Yeah. Part of it is, see, I'm looking at this
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`as an engineer, and what you refer to in buzzwords may
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`mean -- you know, to me they mean different things in
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`the context of an engineer.
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` Q. Mm-hmm. And just -- just to -- to clarify, so
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`you're not aware, for example, of any rejections that
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`the U.S. Patent and Trademark Office may have issued
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`relevant to this patent or its application?
`
` A. Not that I remember.
`
` Q. Okay.
`
` A. I may have seen something, but I don't
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`remember.
`
` Q. Okay. So are you aware that the '067 patent
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`is currently the subject of ongoing litigation between
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`the patent owner and the petitioner?
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` A. Yes, sir.
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` Q. Okay. Are you aware that by the time you
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`signed this Declaration the parties had submitted
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`briefing on claim construction in that matter?
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` A. No.
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` Q. Okay. So you didn't consider any of the claim
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`construction briefing between the parties?
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` A. I do not believe so.
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` Q. Okay. Have you been made aware since signing
`
`your Declaration that that District Court, in fact,
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`entered an Order construing the claims?
`
` A. I was told verbally yesterday that there was.
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` Q. Okay.
`
` A. Okay.
`
` Q. But you haven't seen or reviewed the text of
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`that Order, have you?
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` A. I was e-mailed this morning a list of the
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`claims that we interpret to, but I didn't have a chance
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`to read it.
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` Q. Okay.
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` A. So I haven't read it yet, it's like two pages,
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`that's what I've got. It's just two pages showing the
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`claim is slightly rewritten, the original and the --
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` Q. Okay.
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` A. But it's not like a whole thing, like a judge
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`would show.
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` Q. Okay.
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` A. I'm sorry, it's been a long time since --
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` Q. No, that's fair enough.
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` Okay. Referring again to your Declaration and
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`specifically I'd like to refer now to Appendix A of your
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`Page 20
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`Declaration.
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` A. Yes, sir.
`
` Q. What is Appendix A?
`
` A. Appendix A is a copy of my resume that's on
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`file with New, it's my resume, my legal resume.
`
` Q. Since your Declaration was dated January of
`
`this year, are there any updates that you need to make
`
`to your -- your C.V.?
`
` A. I've worked engineering wise on two new
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`projects, but they're -- they're included in the general
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`areas here.
`
` Q. Okay. What are those two new project --
`
`technically speaking, what do those two new projects
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`concern?
`
` A. One is a miniaturized antenna for direct T.V.
`
`transmission for indoor use --
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` Q. Mm-hmm.
`
` A. -- to eliminate ghosting. And the other one
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`is a mesh networking system that uses a different
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`modulation technique to allow deeper penetration through
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`foliage, like trees.
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` Q. Okay. I'd like to discuss a little bit your
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`professional experience. Maybe we'll start with the
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`oldest chronologically, which you can correct me if I'm
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`wrong, at least as listed on the C.V. appears to be your
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`work at Bell Telephone Laboratories.
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` A. Yes.
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` Q. Did your work at Bell Telephone Laboratories
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`involve any design of remote controls?
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` A. No, I -- I was a central office architect.
`
` Q. Okay. What about your work at Wavetek
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`Corporation, did that involve any design of remote
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`controls?
`
` A. No. That was a voice response systems.
`
` Q. And now you are currently employed for
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`MicroIndustrie, Inc.?
`
` A. I am MicroIndustrie, Inc.
`
` Q. Okay. You are the managing director, it says
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`here.
`
` A. Yeah.
`
` Q. And now for MicroIndustrie, Inc., you have
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`designed some remote controls or remote control systems,
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`is that correct?
`
` A. Yes, sir.
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` Q. Specifically, what kinds of remote controls
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`did you design with MicroIndustrie?
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` A. Remote control transmitters for car alarms,
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`the equivalent of universal car alarm transmitters that
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`can talk to more than one alarm; house alarm systems;
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`the person -- you may have seen it on T.V. where they
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`have the older people with the pendant, the original
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`one, emergency call --
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` Q. Mm-hmm.
`
` A. -- I designed that.
`
` Q. Okay.
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` A. I don't know if remote control cars and trains
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`count, but --
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` Q. Sure.
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` A. -- I figured out one time, just in -- with the
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`variance in just car alarms, I had almost 70 designs
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`over a period of 15 years.
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` Q. The remotes that you design -- remote controls
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`that you designed for trains and cars, were those
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`universal remote controls?
`
` A. No, those -- those were specific.
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` Q. Okay. What about the -- the elderly pendant?
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` A. The pendant was a specific one. It was for
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`one manufacturer.
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` Q. Okay. And what about the house alarm remote
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`control?
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` A. Actually, it's more than house alarms. It was
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`like window alarms, stuff like that. So they had to go
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`Page 23
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`to different brains. It's 20 years ago, so I'm trying
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`to remember. They went to two different manufacturers,
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`two different communications protocols.
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` Q. Mm-hmm.
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` A. So it's -- it's a universal but it's here
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`because it's only two major communications protocols,
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`but that was 20-something years ago. Protocols haven't
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`changed since then.
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` Q. The remote controls for the trains and cars
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`that you designed, were those wired or were they
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`wireless remotes?
`
` A. Everything in that list I gave you was
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`wireless.
`
` Q. Okay. You said the remote control for the car
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`alarms was a Universal Remote Control?
`
` A. Okay. There's two categories, actually, maybe
`
`three depending on how you count it. One is directly
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`for an individual manufacturer or model. It's actually
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`even model, okay. Second we built a demo unit that was
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`used at CES to show people how you could scan anyone's
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`car alarm transmitted when they're using it, or garage
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`door opener.
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` Q. Mm-hmm.
`
` A. And then they'd come back and steal the car or
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`rob the garage. And it was built as a demo units for
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`dealers and for the CES show to demonstrate why you
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`needed what they call code hopping, so each successive
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`one had a different code or a different CRC so that they
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`couldn't record a signal and then come back and rob a
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`house.
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` Q. That -- that second one, so that one wasn't
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`preprogrammed --
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` A. No.
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` Q. -- within --
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` A. It's -- it did exactly the same thing as the
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`way you learn an IR, only it learned an RF.
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` Q. Okay. And then the third category you said
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`there were three categories, you said there was a single
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`and then there was the learning type that you just --
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` A. Yeah, and then we've been working on it on and
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`off for the code hopping ones. It will listen to it,
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`learn what the code hopping is, and then anticipate the
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`next one in the hop. Or -- you have to anticipate any
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`one of the next 16 because the way they work, they allow
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`up -- in case you accidentally push your button in your
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`pocket accidentally --
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` Q. Mm-hmm.
`
` A. -- or you open a car that's out of -- if it's
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`a multi-car device, if you open a car away from, say,
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`the first one, so they allow up to 16 so you have to
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`figure out to you to get it to one of the 16. That's
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`been an ongoing project off and on. It was never
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`implemented into a product. It's used for
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`demonstration, testing.
`
` Q. Okay. Even of those -- those two types of --
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`let me step back.
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` So even in the case of the second category
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`that you mentioned, that was the learner?
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` A. Mm-hmm.
`
` Q. And then the third category that you said
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`attempted to anticipate the code hopping?
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` A. Yeah, it would listen and it would learn the
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`codes that were being sent to it.
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` Q. Mm-hmm.
`
` A. And it would try to anticipate the next codes.
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` Q. Right. In either of those two categories did
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`those remotes involve a preprogrammed library of codes,
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`or were they pure learners?
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` A. One of them was a pure learner. And the other
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`one knew what the protocol was. They knew what were the
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`I.D. bits and what were the -- and in alarms or other
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`things you have an I.D. or identification and then you
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`have control bits.
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` Q. Mm-hmm.
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` A. They knew which was which so they knew what to
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`analyze in one version of it.
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` Q. Okay. Did it know those -- what did you call
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`them, I.D. bits?
`
` A. Yeah, the code number of the device, the car
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`number.
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` Q. Did it know those for multiple different
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`models and manufacturers of car alarms?
`
` A. Okay. It's for multiple cars, but it was a
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`code -- a similar code structure that was done for the
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`OEM or the after market. I worked in the after market.
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`Okay.
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` And so in reality it was the same codes.
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`There were some minor modifications that a bit might
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`mean something else, but it still was the same number of
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`bits, the same error correcting and stuff like that.
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` Q. So was that for a single manufacturer of an
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`after market --
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` A. Yeah.
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` Q. -- alarm?
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` A. Remcor, R-E-M-C-O-R, Technical Products.
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`They're in San Diego. It was sold under Street Smart
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`brand. I'm trying to remember all the brands. I didn't
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`pay attention. I know what the model numbers are,
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`but --
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` Q. Mm-hmm.
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`
`Universal Electronics Exhibit 2007, Page 26
`Universal Remote Control v. Universal Electronics, Trial No. IPR2013-00127
`
`
`
`Page 27
`
` A. -- you know, they would basically, you know,
`
`one day they'd be shipping the same -- you know, two
`
`days apart the same alarm with different stickers on it.
`
` Q. Sure. Have you ever designed a Universal
`
`Remote Control for a television?
`
` A. No.
`
` Q. Have you ever designed a Universal Remote
`
`Control for a VCR?
`
` A. No.
`
` Q. How about a DVD player?
`
` A. No.
`
` Q. If you can turn to your -- the first page of
`
`your C.V., the very last bullet on that page, it says
`
`"Transmitter Remote Control."
`
` A. First page, t
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