UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`1
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`-------------------------x
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`CARDIOCOM, LLC, :
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` Petitioner, : No. IPR2013-00431
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` v. : IPR2013-00449
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`ROBERT BOSCH HEALTHCARE : IPR2013-00451
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`SYSTEMS, INC., : IPR2013-00468
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` Patent Owner. :
`
`-------------------------x
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` VOLUME 1
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` Videotaped Deposition of ROBERT T. STONE, Ph.D.
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` Menlo Park, California
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` Friday, March 7, 2014
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` 9:20 a.m.
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`Job No. 54286
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`Pages: 1 - 243
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`Reported by: Yvonne Fennelly, CCRR, CLR, CSR 5495
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`Bosch Ex. 2007
`Cardiocom v. Bosch IPR2013-00431
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`Bosch Ex. 2009
`Cardiocom v. Bosch IPR2013-00468
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`
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`1
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`-------------------------x
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`CARDIOCOM, LLC, :
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` Petitioner, : No. IPR2013-00431
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` v. : IPR2013-00449
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`ROBERT BOSCH HEALTHCARE : IPR2013-00451
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`SYSTEMS, INC., : IPR2013-00468
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` Patent Owner. :
`
`-------------------------x
`
` VOLUME 1
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` Videotaped Deposition of ROBERT T. STONE, Ph.D.
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` Menlo Park, California
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` Friday, March 7, 2014
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` 9:20 a.m.
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`Job No. 54286
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`Pages: 1 - 243
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`Reported by: Yvonne Fennelly, CCRR, CLR, CSR 5495
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`Bosch Ex. 2007
`Cardiocom v. Bosch IPR2013-00431
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`Bosch Ex. 2009
`Cardiocom v. Bosch IPR2013-00468
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`
`
`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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` Videotaped deposition of ROBERT T.
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`STONE, Ph.D., held at the offices of:
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`2
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` ORRICK HERRINGTON & SUTCLIFFE, LLP
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` 1000 Marsh Road
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` Menlo Park, California 94025
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` (650) 614-7400
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` Pursuant to Notice, before Yvonne Fennelly,
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`a Certified California Realtime Reporter, Certified
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`LiveNote Reporter, and Certified Shorthand Reporter
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`in and for the State of California.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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`3
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` A P P E A R A N C E S
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`ON BEHALF OF THE PETITIONER:
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` WILLIAM D. SCHULTZ, ESQUIRE
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` MERCHANT & GOULD
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` 80 South Eighth Street
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` 3200 IDS Center
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` Minneapolis, Minnesota 55402
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` (612) 332-5300
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`ON BEHALF OF THE PATENT OWNER:
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` BAS de BLANK, ESQUIRE
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` DAVIN M. STOCKWELL, ESQUIRE
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` ORRICK HERRINGTON & SUTCLIFFE LLP
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` 1000 Marsh Road
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` Menlo Park, California 94025
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` (650) 614-7400
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`ALSO PRESENT:
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` Anthony Serventi, a.m. session
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` Greg Mathis, a.m. session
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` Joseph Mourgos, Videographer
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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` C O N T E N T S
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`EXAMINATION OF ROBERT T. STONE, Ph.D. PAGE
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` By Mr. de Blank 8
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` E X H I B I T S
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` (None Marked)
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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` MENLO PARK, CALIFORNIA; MARCH 7, 2014
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` 9:20 A.M. - 4:25 P.M.
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` - - -
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` ROBERT T. STONE, Ph.D.,
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` having been duly sworn, testified as follows:
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` - - -
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` having been duly sworn, testified as follows:
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` - - -
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` THE VIDEOGRAPHER: Here begins Video No. 1
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`in the videotaped deposition of Dr. Robert Stone in
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`the matter of Cardiocom, LLC versus Robert Bosch
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`Healthcare Systems, Incorporated, in the United
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`States Patent and Trademark Office before the Patent
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`Trial and Appeal Board.
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` Case Nos. are IPR 2013-00431, Patent
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`7,921,186, B2.
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` Case No. IPR 2013-00449, Patent No.
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`7,840,420 B2.
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` Case No. IPR 2013-00451, Patent No.
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`7,587,469 B2.
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` And case No. IPR 2013-00468, Patent No.
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`7,516,192 B2.
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` Today's date is March 7th, 2014. The time
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`on the video monitor is 9:22 a.m.
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` The videographer today is Joseph Mourgos
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`PLANET DEPOS
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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`representing Planet Depos.
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` This video deposition is taking place at
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`1000 Marsh Road, Menlo Park, California.
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` Would counsel please voice identify
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`themselves and state whom you represent.
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` MR. de BLANK: Yes, my name is Bas de Blank
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`with Orrick Herrington Sutcliffe representing Bosch.
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` With me are Davin Stockwell, also from
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`Orrick; Greg Mathis and Tony Servanti from Bosch.
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` MR. SCHULTZ: Good morning, my name is
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`William Schultz with the law firm of Merchant &
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`Gould. I represent Cardiocom, LLC.
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` THE VIDEOGRAPHER: Thank you.
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` The court reporter today is Yvonne
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`Fennelly, representing Planet Depos.
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` Would the court reporter please administer
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`the oath.
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` ROBERT T. STONE, Ph.D.,
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` having been first duly sworn was
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` examined and testified as follows:
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` - - -
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` MR. de BLANK: And just a couple
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`housekeeping matters before we begin.
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` One is, I discussed with Mr. Schultz, we'll
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`conduct the deposition effectively with your
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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`7
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`cross-examination starting today, we'll take a break
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`at the end of the day and continue on next week as
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`discussed.
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` At the end of my examination, which will
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`cover all the different IPRs, Mr. Schultz will have
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`an opportunity to do any redirect examination and he
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`can do it for all patents or any of the IPRs that he
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`wants at that point, rather than doing it at the end
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`of each day. After Mr. Schultz does that, if he
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`wishes to, I'll have the opportunity to do recross,
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`I guess, pursuant to the rules.
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` Is that your understanding?
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` MR. SCHULTZ: That is my understanding.
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`Thank you.
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` MR. de BLANK: Two other quick things; one,
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`we sent an e-mail yesterday afternoon raising
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`certain issues while proceeding with the deposition
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`but just without waiving our rights, any rights we
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`may have on the issues that were discussed in that
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`e-mail.
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` And lastly, I do want to confirm, I think
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`Medtronic had filed appearances or it's indicated a
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`real party of interest in the IPRs also. Are you
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`representing Medtronic for that purpose or -- I just
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`want to make sure there isn't an issue later where
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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`they claim that they weren't.
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` MR. SCHULTZ: Yes, I represent Medtronic as
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`well.
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` MR. DE BLANK: Thank you.
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` EXAMINATION
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`BY MR. de BLANK:
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` Q. Thank you for your indulgence, Dr. Stone.
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` Let me first ask, have you been deposed
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`before?
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` A. Yes, I have.
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` Q. How many times?
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` A. Less than ten, more than five.
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` Q. So I'm going to go through a number of
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`rules, they're probably things you're familiar with,
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`just to make it more easy for both us and
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`importantly for the court reporter.
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` First off, I'll just ask you to please wait
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`until I finish my question before you begin your
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`answer.
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` If you haven't, I'll apologize in advance,
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`I may interrupt just so I can finish the question to
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`make the record clear.
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` Do you understand?
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` A. Yes.
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` Q. And by the same token, I'll do my best to
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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`9
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`make sure that you finish your answer before I ask
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`09:25:02
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`the next question.
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`09:25:03
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` Sometimes people say something and they'll
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`pause and you may be thinking and I may be assuming
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`you finished your answer. If I move on to the next
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`question and you haven't finished your answer,
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`please let me know and I'll give you an opportunity
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`to do so.
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` A. All right.
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`09:25:15
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` Q. If any of my questions are unclear, please
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`09:25:16
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`let me know and I'll do my best to either repeat or
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`rephrase or clarify them. Is that okay?
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` A. Yes.
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`09:25:21
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` Q. And I'll assume if you answer the question
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`09:25:23
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`that you answered to the best of your ability and
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`that you understood the question; is that fair?
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` A. That's fair.
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` Q. Now, you'll have an opportunity to review
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`09:25:27
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`09:25:30
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`the transcript and to comment or correct the record
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`09:25:34
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`if you need to after the deposition.
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` But if you make changes at the end of the
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`deposition, we have -- we can comment on the fact
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`that you've made the changes later.
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`09:25:37
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` So it's important to make sure your answers
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`09:25:45
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`are as full and complete and accurate as you could
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`09:25:48
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
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`10
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`make them.
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` Do you understand that?
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` A. I understand.
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` Q. Sometimes when people have been talking
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`about things for a period of hours or a period of
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`days, something will kind of come back to them and
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`your memory may get refreshed or jogged and you may
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`say, oh, wait a minute I've got more to say now
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`about something we discussed a couple hours ago. If
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`that happens, just let me know and we can address
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`it.
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` We'll take breaks roughly every hour or so,
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`but if you want a break more often, just let me know
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`and I'll do my best to accommodate you.
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` The only thing I would ask is if there is a
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`question pending, that you answer the question
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`before you take the break. Is that okay?
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` A. Yes.
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` Q. Okay.
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` I don't think it's going to be an issue in
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`this kind of deposition, but if you have a question
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`about privilege, obviously we will take a break at
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`that point and you can consult with Cardiocom and
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`Medtronic's attorney.
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` You understand that the rules of the
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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`deposition mean that you are not to discuss the
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`substance of your testimony or expected testimony
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`with Cardiocom or Medtronic attorneys during these
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`breaks?
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` A. Yes.
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` Q. Okay.
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` And you expect to follow that rule?
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` A. Yes.
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` Q. Okay.
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` Now, from time to time, Mr. Schultz may
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`object to the questions.
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` If he does, I may rephrase the question or
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`I may not, but you should still give the best and
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`most accurate answer you can unless he instructs you
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`not to answer.
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` A. I understand.
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` Q. Okay.
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` Now, is there any reason you can think of
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`not to begin the deposition?
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` A. No.
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` Q. No medication that might affect your
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`recollection or ability to testify?
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` A. No.
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` Q. Thank you.
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` Did you have an opportunity to prepare for
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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`the deposition?
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` A. Yes.
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`09:27:20
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` Q. About how much time did you spend preparing
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`for today's deposition?
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` A. Cumulative total, probably two days.
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` Q. With whom did you meet to prepare for the
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`deposition?
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` A. Myself and with Mr. Schultz.
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` Q. Was there anyone else that you met with to
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`prepare?
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` A. No.
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` Q. Either telephonically or in other ways?
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` A. There was a representative in Minneapolis
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`that came back to speak briefly, but I don't recall
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`doing any detailed preparations or discussions. We
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`were going to prepare. He asked if I had been
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`deposed before and then basically we discussed the
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`weather in Minneapolis.
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` Q. Got ya.
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` Do you recall whether that was an attorney
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`or a representative from the client or what their
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`role was?
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` A. I'm certain it was an attorney from
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`Merchant & Gould.
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` Q. Do you recall who it was?
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
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` A. No, I don't.
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` Q. Okay.
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` Other than that individual, is there anyone
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`else you met with to prepare for today's deposition?
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` A. No.
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` Q. Do you think you felt you had sufficient
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`time to prepare for today's deposition?
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` A. Yes.
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` Q. And you generated a number of reports --
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`I'm sorry.
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` You generated a number of declarations as
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`part of the IPR petitions; correct?
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` A. Yes.
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` Q. And you felt you had sufficient time to
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`prepare those declarations?
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` A. Yes.
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` Q. The declarations were as full and complete
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`as you could have made them?
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` A. Yes.
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` Q. Your declarations included all the
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`information that you considered to be relevant to
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`the issue of whether or not the Bosch patents were
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`invalid?
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` A. At the time of the declarations, yes.
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` Q. You haven't supplemented or changed or
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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`amended those declarations?
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` A. I don't believe I supplemented those
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`declarations, no.
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` Q. And we'll get to the individual
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`declarations later, but just at a general level, is
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`there anything in the declarations that upon
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`reflection you feel is not accurate or you feel is
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`incorrect?
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` A. I cannot recall any such thing.
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` Q. Okay.
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` If, as we go through the declarations, you
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`encounter something that you think is no longer
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`accurate, just let me know.
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` A. All right.
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` Q. Thank you.
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` When were you retained for the purpose of
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`these IPR proceedings?
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` A. Goodness.
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` I believe sometime in, I can't recall when
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`I first did a report. Either late 2012 or 2013, or
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`early 2013. I did not review that date.
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` Q. No, no, I understand.
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`09:30:00
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` And what was your understanding of what you
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`were being retained for?
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` A. At that time, I was being retained to
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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`15
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`review certain patents, determine if the information
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`that was in them was correct as far as its
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`declarations, finding out if there was other prior
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`art or if someone who was skilled in the arts would
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`really understand and know with respect to
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`obviousness or other factors for the validity of the
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`patents.
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` Q. So is it fair to say, then, that your work
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`in this matter has been directed to the question
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`invalidity as opposed to infringement or some other
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`topic?
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` A. I have not discussed infringement or other
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`topics.
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` Q. Okay. You understand that there is also a
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`district court litigation where Bosch is alleging
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`that Cardiocom infringes the patents you've opined
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`about?
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` A. Yes.
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` Q. But you haven't inquired about that case or
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`the infringement allegations?
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` A. I have not inquired with regard to the
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`infringement allegations.
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` Q. You haven't investigated whether
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`Cardiocom's products practice the patents?
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` A. I have not investigated that.
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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` Q. You haven't determined whether or not the
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`Cardiocom products that Bosch accuses were
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`16
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`successful or not successful?
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` A. No.
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` Q. You said that by late 2012 or early 2013,
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`you were asked to consider some Bosch patents. I
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`just want to make sure, so there are four patents
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`that we are talking about as this IPR, and I refer
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`to them by their last three numbers, the '186, '420,
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`'469, and '192 patents; is that fair?
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` A. That's fine. But when you ask me a
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`question, I will need to have them in front of me.
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`I don't keep numbers memorized.
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` Q. Oh, no, no, I understand that. If you need
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`the patents, then I'll get them.
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` But the question I -- the very broad one
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`is: Are those four patents among the patents that
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`you reviewed when you began working in late 2012 or
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`early 2013?
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` A. If my memory is correct on those numbers,
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`yes.
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` Q. Okay.
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` Do you know approximately how much time
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`you've spent working on these Cardiocom IPR
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`petitions?
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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` A. I personally don't keep track of the time.
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`09:32:27
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`I have a clerk, an office manager who takes my
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`hours, puts them in, submits them, and I try not to
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`17
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`pay attention too much to that other than making
`
`sure I get my numbers in.
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` Q. Of course.
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` Do you have a general sense of how many
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`09:32:37
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`hours this was, on the order of tens or hundreds or
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`more?
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` A. Certainly more than tens.
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`09:32:47
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` Could be between one and 200 at this point.
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`09:32:50
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`I could not recall for sure.
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`09:32:55
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` Q. And you're being paid by Cardiocom for your
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`09:32:58
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`time?
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` A. That's correct.
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` Q. What is your rate?
`
` A. $350 an hour.
`
` Q. Do you have an idea or sense of how much
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`either you -- either bills you've submitted to
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`Cardiocom or how much Cardiocom has actually paid
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`you?
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` A. I would have to ask my clerk for that
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`answer.
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` Q. So the $350 an hour rate, do you do other
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`consulting work other than this litigation?
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
`CONDUCTED ON FRIDAY, MARCH 7, 2014
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` A. Yes.
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` Q. What is the rate that you charge in that
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`other consulting work?
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` A. For all, except a very old case, it's all
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`at $350 an hour.
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` A. I started at $250 an hour. It was retained
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`through a search firm and they do a markup, so in
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`reflection, overly generous with the client.
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` Q. So you will not make that mistake again.
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` A. No.
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` Q. Have you done any other work for Cardiocom
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`or Medtronic other than this litigation?
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` By this litigation, I mean either the
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`the patent office.
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` A. In years past, I have done some consulting
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`work for Medtronic. I don't believe anything
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`regarding any litigation.
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` Q. Okay.
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` So you haven't done any -- just to make
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`sure I understand, you have done technical
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`consulting work for Medtronic, but not acting as a
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`09:34:22
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`consultant in a legal proceeding?
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`09:34:25
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` A. That's correct.
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` Q. Okay.
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` And you said that was in years past.
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` Do you recall when that was?
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` A. The last time would have been 2010, 2011.
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` Q. What type of technology did that relate to?
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` A. It related to cardiac -- well, catheters in
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`general.
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` Q. Did that have anything to do with remote
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`patient monitoring?
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` A. No.
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` Q. Other than the -- sorry, and in the
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`technical consulting work for Medtronic, is that
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`ongoing or is that completed?
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` A. That's completed.
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` Q. And what was the rate you billed Medtronic
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`for that technical consulting work?
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` A. At that time, it was $250 an hour.
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` Q. And do you have a sense of approximately
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`how much Medtronic paid you for that work?
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` A. Yes. $50,000.
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` Let me make a correction. That was
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`$50,000. The reason I know it's that, it was a
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`fixed bid on a feasibility study, so an hourly rate,
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`but that was my retail billing rate at that time.
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` Q. Sure.
`
` So you've not done any legal -- not
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`legal -- I'm sorry, I apologize. I understand
`
`you're not an attorney, I don't mean legal
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`consulting in the sense of legal work. You haven't
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`done any consulting for Medtronic or served as an
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`expert for Medtronic in a litigation matter?
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` A. No, I don't believe so.
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` Q. Let me ask about a case in particular, is
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`the case Medtronic MiniMed v. Animas, have you heard
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`of that?
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` A. Oh, sorry. Yes.
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` Correction.
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` Q. All right.
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` A. Let's make a correction. I am currently
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`working with Animas and just not even thinking of
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`Medtronic at the time. Sorry, working for MiniMed
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`and they've been bought by Medtronic. So, yes, I am
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`working on that case and have been doing consulting
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`for Medtronic versus MiniMed.
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` Q. Okay.
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` So --
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` A. Sorry, Medtronic versus Animas.
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` Q. So you are currently doing other consulting
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`work for Medtronic in litigation?
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` A. That's correct.
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` Q. Okay.
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` And that's ongoing? That's continuing?
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` A. The Animas, yes.
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` Q. And do you recall about how much Medtronic
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`has paid you in that litigation?
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` A. Same answer. No, I don't know that.
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` Q. In general, what kind of percentage of your
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`income is related to your consulting in legal
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`matters?
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` A. For the past year, it's probably close to
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`50 percent.
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` Q. So other than the work for Medtronic and
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`Cardiocom that we discussed, this case and the
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`Animas case, have you done any other -- sorry, and
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`the technical consulting for Medtronic, any other
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`work for Cardiocom?
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` A. Let's back up.
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` There was another, there was an Insulet,
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`Medtronic versus -- sorry, yes, Medtronic MiniMed
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`versus Insulet. That is a completed case.
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` Q. Okay.
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` And did you testify in that case?
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` A. No.
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` Q. Did you submit a declaration in that case?
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`VIDEOTAPED DEPOSITION OF ROBERT T. STONE, Ph.D., VOLUME 1
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` A. Yes.
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` Q. And you were working on behalf of Medtronic
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`in the Insulet litigation?
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` A. That's correct.
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` Q. Okay.
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` So other than the technical consulting work
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`you've done for Medtronic and the litigation
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`consulting you've done in the Animas and Insulet
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`cases and the work you're doing for them in this
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`case, have you done other work for Cardiocom or
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`Medtronic?
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` A. Not to my recollection.
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` Q. Had you heard of Cardiocom before this,
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`before you became involved in the litigation?
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` A. No.
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` Q. Have you done any work for Bosch?
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` A. Yes.
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` Q. Okay.
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` When was that?
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` A. Again, I want to say that's 2010 through --
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`I'm trying to remember when that was completed.
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`2011.
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` Q. And what was the nature of that work?
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` A. It was a redesign to eliminate
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`electromagnetic interference for the Health Buddy
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`system.
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` Q. So you've actually worked for Bosch on the
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`Health Buddy products?
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` A. Yes.
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` Q. So you're familiar with the Health Buddy
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`products?
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` A. Yes.
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` Q. And you were familiar with the Health Buddy
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`products before this case began?
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` A. Yes.
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` Q. Did you notify Bosch or any representative
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`for Bosch that you were going to start doing work
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`for Cardiocom against Bosch related to Health Buddy
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`products?
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` A. At the time I did not know that it was
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`related to the Health Buddy products, so the answer
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`is no.
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` Q. Had you told Cardiocom's attorneys that
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`you'd previously worked for Bosch on the Health
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`Buddy products?
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` A. I believe that I had.
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` Q. Did you tell them that before they retained
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`you?
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` A. I don't recall.
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` Q. But they --
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` A. I usually have that discussion, so I don't
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`recall the details of that discussion.
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` Q. So what was your involvement with the Bosch
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`Health Buddy product?
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` A. I was initially the vice president of R&D
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`and then later the CEO of the company that did the
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`design, so I advised and directed the engineers who
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`were actually working on the issue.
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` Q. Okay.
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` So you received confidential information
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`about the operation of the Health Buddy product,
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`information that would not be publicly available?
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` A. Yes.
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` Q. And I assume you had nondisclosure
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`agreements with Bosch about not discussing or
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`disclosing that information?
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` A. That's correct.
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` Q. And that period that was in, started in
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`2010 and continued in 2011?
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` A. Yes.
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` Q. Okay.
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` Was that work ever formally terminated?
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` A. Yes.
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` Q. When was that?
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` A. 2011.
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` Q. How was it ended?
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` A. The design was submitted to Bosch and the
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`program stopped, and we were done.
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` Q. Did you have any -- sorry.
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` Okay.
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` So you were familiar with the Bosch Health
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`Buddy product?
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` A. I was familiar with parts of the Health
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`Buddy product, not the overall product.
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` Q. You understood it did remote patient
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`monitoring?
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` A. I did.
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` Q. You understood that it had the capability
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`of doing what's called group overview charts in the
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`patents, that kind of thing?
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` A. Actually, I only saw the device itself, the
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`remote portion of the device. I had no interaction
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`with what was done with the information when it got
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`to the other end.
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` Q. Okay.
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` So you understood the device had a screen
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`that could display questions to users, you would
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`select a response?
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