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` UNITED STATES PATENT & TRADEMARK OFFICE
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` PATENT TRIAL & APPEAL BOARD
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` _____________________________________________
`
` IPR2014-00439
`
` Patent No. 7,365,871
`
` _____________________________________________
`
` IRON DOME LLC
`
` Petitioner
`
` v.
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` E-WATCH, INC.
`
` Patent Owner
`
` _________________________________________________
`
`10
`
` TELEPHONE DEPOSITION OF
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` WINSTON NINH
`
`11
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` JANUARY 27, 2015
`
` _______________________________________________
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` TELEPHONE DEPOSITION OF WINSTON NINH,
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`produced as a witness at the instance of the Petitioner,
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`and duly sworn, was taken in the above-styled and
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`numbered cause on the 27th of January, 2015, beginning
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`at 7:03 a.m. and concluding at 8:14 a.m., before Karen
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`Geddes, CSR in and for the State of Texas, reported by
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`machine shorthand, at the offices of Watts Guerra LLP, 4
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`Dominion Drive, Bldg. 3, Suite 100, San Antonio, Texas,
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`78257, pursuant to the Federal Rules of Civil Procedure
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`and the provisions stated on the record or attached
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`hereto.
`
`Job No: 2004713
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`Fredericks Reporting & Litigation Services - A Veritext Company
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`Page 1
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`Iron Dome, Exh. 1007
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`

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` A P P E A R A N C E S
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`F O R T H E P E T I T I O N E R :
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` S T E V E N Y U , E S Q U I R E ( V i a T e l e p h o n e )
` P . O . B o x 1 0 0 3 4
` G a i t h e r s b u r g , M D 2 0 8 9 8
` P h o n e : ( 2 0 2 ) 2 6 2 - 0 4 2 5
` E - m a i l : S y u @ i r o n d o m e . c o m
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`F O R T H E R E S P O N D E N T :
` R O B E R T C . C U R F I S S , E S Q U I R E
` 1 9 8 2 6 S u n d a n c e D r i v e
` H u m b l e , T e x a s 7 7 3 4 6
` P h o n e : ( 8 3 2 ) 5 7 3 - 1 4 4 2
` F a x : ( 8 3 2 ) 6 4 4 - 6 1 5 2
` E - m a i l : B o b @ c u r f i s s . c o m
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`A L S O P R E S E N T :
` D a v i d M o n r o e
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`Exh. p. 2
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` INDEX
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` PAGE
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`Appearances..................................... 2
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`WINSTON NINH
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` Examination by Mr. Yu .................... 4
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` Examination by Mr. Curfiss................ 27
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`Signature and Changes.......................... 29
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`Reporter's Certificate......................... 31
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` EXHIBITS
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` DESCRIPTION PAGE
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`Exhibit 1006 Page 39 of 58 in the Declaration
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` of Winston Ninh................... 14
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`Exh. p. 3
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` P R O C E E D I N G S
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` MR. CURFISS: Before you start, I just
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`wanted to point out for the record that Mr. David Monroe
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`is also here.
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` MR. MONROE: Good morning.
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` MR. YU: Good morning.
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` WINSTON NINH,
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`having been first duly sworn, testified as follows:
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` EXAMINATION BY COUNSEL FOR PETITIONER
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`BY MR. YU:
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` Q. Dr. Ninh, this is Steven Yu. I'm the attorney
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`who will be asking initially the questions in this
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`deposition, but before we get to the questions, allow me
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`a moment to go over some preliminary matters.
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` The first is: Do you understand that you
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`are under oath to make truthful statements?
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` A. I understand.
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` Q. If I ask you a question and you do not
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`understand it, you can ask me to rephrase it or clarify
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`it.
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` Do you understand that part?
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` A. Yes. I will do so.
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` Q. Okay. What will happen in this deposition is
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`that I'll ask you questions and then you respond to my
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`questions. On occasion after I ask a question, one of
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`Exh. p. 4
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`attorneys -- other attorney may say "objection" with a
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`sworn statement, so when that happens, after the
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`objection is made, you still have to answer my question
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`unless your attorney specifically tells you not to
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`answer my question.
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` Do you understand that for the format for
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`questions and answers?
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` A. Yes, I do.
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` Q. Okay. We'll try to take short breaks every
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`hour, but if you need a break at any time for any
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`reason, just tell us and we'll accommodate your request.
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` So let's start with the deposition
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`questions. Dr. Ninh, could you please state your first
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`and last name and residence address for the record,
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`please.
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` A. First name is Winston -- W-i-n-s-t-o-n. Last
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`name is Ninh, spelled "N" like "Nancy" -- "i" -- "n"
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`like "Nancy" -- "h." "Ninh."
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` My current address is 13827 Shavano Mist,
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`San Antonio, Texas, 78230.
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` Q. Dr. Ninh, you have a copy of a document that's
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`titled "Declaration of Winston Ninh." In the bottom
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`right corner, it says: E-Watch, Exhibit 2015; is that
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`what you see?
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` A. Yes, I see the first page says "Exhibit 2015."
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`Fredericks Reporting & Litigation Services - A Veritext Company
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`Exh. p. 5
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` Q. Okay. And this is the declaration that you
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`submitted for this case; is that correct?
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` A. That is correct.
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` Q. Okay. Please turn to Page 2 of the
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`declaration, and in particular, paragraph 6.
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` A. Okay. I see paragraph 6 on Page 2.
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` Q. You state in your declaration that you had
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`direct knowledge of the FAX-CAM, CAM -- R-I-T -- I'll
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`call that "CAM-RIT" -- and the Mini-RIT product
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`development projects; is that correct?
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` A. That is correct.
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` Q. Please turn to Page 6 of the declaration now.
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` A. I'm on Page 6.
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` Q. There's paragraph "f" where you refer to the
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`"CAM-RIT apparatus."
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` Do you see that?
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` A. Yes.
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` Q. You state in your declaration that the CAM-RIT
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`apparatus had a viewfinder; is that correct?
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` A. Okay. Refer to which paragraph, you're talking
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`about this "e," "f"?
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` Q. Yes. In paragraph "f" --
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` A. "f."
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` Q. -- near the middle, you say that the CAM-RIT
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`apparatus had a viewfinder; is that correct?
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`Fredericks Reporting & Litigation Services - A Veritext Company
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`Exh. p. 6
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` A. I don't recall.
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` Q. This is a -- that it states in your declaration
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`that it had a viewfinder --
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` A. Yes.
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` Q. -- I just want to confirm that that's what it
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`states. Okay.
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` And you further state in your declaration
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`that the CAM-RIT apparatus had a deflection yoke; is
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`that correct?
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` A. I don't recall this correctly.
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` Q. Again, I'm just referring to what you state in
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`your declaration, that it states that it has a
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`deflection yoke; is that correct?
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` A. I don't recall.
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` Q. I'm just asking you whether it states that in
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`your declaration. I'm just reading through your
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`declaration part by part.
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` A. Well, these items has been 20 years ago.
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`Again, there is a flashback of memories there, but
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`there's no way that I can confirm. I mean, if you want
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`me to say yes or no, that will be a definite answer. I
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`don't recall.
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` Q. Okay. Well, I just want to make sure I'm
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`specifically asking about what the content of the
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`declaration, not what you actually recall --
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`Exh. p. 7
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` A. Right.
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` Q. -- that you state in your declaration, in
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`paragraph "f," that a CAM-RIT apparatus had a deflection
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`yoke; is that what it says in your declaration?
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` A. No, I don't recall.
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` Q. Throughout paragraph "f," there's many items
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`that are listed as being components of CAM-RIT
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`apparatus. Did you have personal -- actual personal
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`memory of all of those components when you wrote this
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`declaration?
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` A. You're talking about paragraph "f"?
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` Q. That's correct, paragraph "f" which starts on
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`Page 6, continues on Page 7, and ends on Page 8, and
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`lists a large number of components and capabilities.
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` At the time when you were asked to make
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`this declaration, did you have actual and personal
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`memory that CAM-RIT had all of those components and
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`functions?
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` A. Yes. The CAM-RIT has these components. Again,
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`there are components that are from my memory. It's not
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`vividly came out as a yes or no, but if you list as a
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`detail of those component, for example, video frontend,
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`video interface and so on, those components came back to
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`me vividly that I had involved with the design on those
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`components.
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`Fredericks Reporting & Litigation Services - A Veritext Company
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`Exh. p. 8
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` Q. Okay. Were there some parts of the CAM-RIT
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`apparatus that you state in your declaration that you
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`did not have actual personal memory when you were asked
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`to make this declaration?
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` A. There are items that I don't vividly recall.
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` Q. Was anything given to you to help you remember
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`the items that you did not recall?
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` A. No.
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` Q. What did you rely on to make the statements in
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`your declaration that the CAM-RIT apparatus had all of
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`these components and capabilities?
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` A. It's all come from the memories. There are --
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`when I do the design, there is certain signatures that I
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`can recognize, meaning the way I draw, the way I put
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`down the paragraph, the way I put down the diagrams,
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`those are my design.
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` Q. Okay. When you made those statements in your
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`declaration in paragraph "f," what papers did you rely
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`on? What diagrams or what materials did you rely on to
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`make those statements?
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` A. We have several designs at that time using CAD,
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`for particular all CAD, and some other documentations.
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`There are some drawings in the documentation showing
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`which component I did the design on.
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` Q. Okay. Did you rely on anything else to help
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`Fredericks Reporting & Litigation Services - A Veritext Company
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`Exh. p. 9
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`you remember all the components of the CAM-RIT
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`apparatus?
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` A. No. It's all coming from my memories.
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` Q. Okay. Please turn to Page 6 of the
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`declaration -- we're on Page 6, paragraph "f." You
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`indicate that pages 20 to 31 of your declaration contain
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`hardware schematics; is that correct?
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` A. Okay. I'm checking.
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` (Witness perusing document.)
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` All right. I see the schematics from
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`Page 20 through 31. I cannot tell you by the detail of
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`these design, but by the signature of the drawing, this
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`would be -- it was my design. However, I cannot confirm
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`that this all belong to the CAM-RIT unless I spend some
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`time look into the detail of the schematics.
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` Q. Okay. Let's turn back to your declaration on
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`Page 7, then.
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` A. Okay. I'm on Page 7.
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` Q. Near the middle, your declaration states that
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`the CAM-RIT apparatus had, quote, cellular telephone
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`data and clock interface for control of cell phone and
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`data transfers a liquid crystal display module, end
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`quote.
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` Do you see that?
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` A. Yes.
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`Fredericks Reporting & Litigation Services - A Veritext Company
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`Exh. p. 10
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` Q. I ask you to take some time to review the
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`schematics on pages 20 to 31, the ones you just looked
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`at, and tell me on what page of the schematics shows
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`that part.
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` A. Okay.
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` (Witness perusing document.)
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` What particular module are you looking for,
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`Mr. Yu?
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` Q. I was referring to the cellular telephone data
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`and clock interface for control of cell phone and data
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`transfers; that's what's stated in your declaration.
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` A. I do not find the cellular interface.
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` Q. Did you review pages 20 to 31 of your
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`declaration?
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` A. That is correct. I do not find the cellular
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`interface. There is a related circuitries crypto
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`cutover modems. It could have been that the cellular
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`clockings and the interfaces cellular via crypto logics
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`and some other internal clocking circuitries.
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` Q. Are you saying that it had an interface that
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`could receive a cellular telephone?
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` A. Yes.
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` Q. But in pages 20 to 31, even actually a cellular
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`telephone data and clock interface the control of a cell
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`phone?
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` A. No. The schematic does not show the particular
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`physical cellular telephone interface.
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` Q. Okay. On pages 39 to 44 of your declaration,
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`you state that there's more diagrams hardware schematics
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`of the CAM-RIT apparatus. Will you check those, please.
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` A. Repeat that question, please.
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` Q. Let's turn to Page 8 of your declaration.
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` A. I'm on Page 8.
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` Q. You state that -- at the bottom, pages 39 to 44
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`contain some more hardware schematics of the CAM-RIT
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`apparatus. Would you please review those pages and see
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`if that component is in those pages.
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` A. Okay. I'm looking at pages 39 through 44.
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` MR. CURFISS: Excuse me, Mr. Yu.
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` MR. YU: Yes.
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` MR. CURFISS: Can we take a two-minute
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`break? I am going to make another copy of the
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`declaration so I can follow along with you.
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` MR. YU: Okay. Let's go off the record and
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`take a break here.
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` MR. CURFISS: Thank you.
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` (Recess 7:28 a.m. to 7:34 a.m.)
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`BY MR. YU:
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` Q. So I had asked Dr. Ninh to review pages 39
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`through 44 of the declaration, and the question was: Do
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`any of the hardware schematics in those pages show,
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`quote, a cellular telephone data and clock interface the
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`control of a cell phone and data transfers, end quote?
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` A. Yes. On Page 39 -- I'm looking on Page 39,
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`there are several block diagrams and several control
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`lines are relating to fax phone controls, particular tip
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`rings and phone and so on. Those are block diagram
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`represents a piece of hardware that connect it together.
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`There may not be any schematic left on those block
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`diagram, but it does shows a certain hardware
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`configurations.
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` Q. Okay. So you are saying on Page 39 that in
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`that block diagram there is a part that shows a cellular
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`telephone data and clock interface control of cell phone
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`and data transfers?
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` A. Yes. The block diagram that shows the
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`interface through the cellular -- cellular or the phone
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`line system.
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` MR. YU: I'll have the court reporter hand
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`Dr. Ninh her copy of page 39.
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` THE WITNESS: SURE.
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` MR. YU: And let's go off the record while
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`we do that.
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` (Off the record briefly. )
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`BY MR. YU:
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` Q. Dr. Ninh, the court reporter has handed you a
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`sheet. Can you confirm that this sheet is a copy of
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`Page 39 of your declaration?
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` A. Yes. The page is 39.
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` Q. On that sheet corresponding to page 39 of your
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`declaration, will you please mark with a big circle that
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`component where you indicated the cellular telephone
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`interface module.
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` A. (Witness complies.)
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` Okay. I did.
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` Q. What you marked, are there any specific
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`indications or writings in that marked portion that
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`identifies that as being a cellular telephone interface
`
`module?
`
` A. I just draw a circle and put a star on the
`
`circle.
`
` Q. Okay. And what does the star indicate?
`
` A. It indicate the cellular interface.
`
` Q. Okay. Now please give those sheets back to the
`
`court reporter so she can mark them as Exhibit 1006 for
`
`the record, and let's go off the record for a moment so
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`she can do that.
`
` (Off the record briefly.)
`
` (Exhibit 1006 was marked.)
`
`BY MR. YU:
`
`Fredericks Reporting & Litigation Services - A Veritext Company
`(512) 640-6040
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`Page 14
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`Exh. p. 14
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` Q. Dr. Ninh, turn to Page 8 of your declaration
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`again.
`
` A. I'm on Page 8.
`
` Q. And in particular, paragraph "g" and "h"
`
`referring to the Mini-RIT.
`
` A. Okay.
`
` Q. Referring to paragraph "g," I'm going to read
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`through several items at once. Please just wait until I
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`finish listing all the items before answering the
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`question.
`
` Did you state in your declaration that the
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`Mini-RIT apparatus had a digital camera, video circuitry
`
`for processing information generated by the digital
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`camera, PCMCIA circuitry, and a programmable sequence
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`instruction unit; is that correct?
`
` A. That is correct.
`
` Q. Okay. And the next paragraph, paragraph "h,"
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`again I'm going to read through several items all at
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`once. Please wait until I finish listing them before
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`answering the question.
`
` You state in your declaration that the
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`Mini-RIT apparatus had a digital camera with digital
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`signal processing, electronic light control, gain
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`control, balance control, red/blue level control, light
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`compensation control, shutter speed control, and tracing
`
`Fredericks Reporting & Litigation Services - A Veritext Company
`(512) 640-6040
`
`Page 15
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`Exh. p. 15
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`light control.
`
` Is that correct?
`
` A. That is correct.
`
` Q. Please turn to Page 9 of your declaration and
`
`paragraph "j" referring to the Mini-RIT, and tell me
`
`when you are there.
`
` A. I am on Page 9.
`
` Q. Again I'm going to read through several items
`
`at once. Please wait until I am finished listing them
`
`before answering the question.
`
` You state in your declaration that the
`
`Mini-RIT apparatus had a camera, audio circuitry/logic,
`
`video circuitry/logic, an electronic viewfinder, a
`
`device for enabling alphanumeric input, cellular
`
`telephone, and power supply.
`
` Is that all correct?
`
` A. That is correct.
`
` Q. And you further state in your declaration that
`
`this apparatus enabled a user to acquire and frame an
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`image using the electronic viewfinder, capture the
`
`framed image to produce a digitized framed image,
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`optionally input and view alphanumeric information,
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`selectively recall the digitized framed image from
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`memory, and thereafter selectively transmit an
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`digitized -- transmit -- sorry, correction -- transmit
`
`Fredericks Reporting & Litigation Services - A Veritext Company
`(512) 640-6040
`
`Page 16
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`Exh. p. 16
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`the digitized framed image and optionally alphanumeric
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`information for reception by a remote receiving station.
`
` Is that all correct?
`
` A. That is all correct.
`
` Q. When you were asked to make this declaration,
`
`did you have actual personal memory that the Mini-RIT
`
`apparatus had all of those components and functions?
`
` A. I have very vivid memories of these designs on
`
`these products, yes.
`
` Q. Did you use anything to help you remember those
`
`components and functions?
`
` A. Again, the recalls comes from the schematics,
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`recall comes from the functionality that I remembers,
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`and, again, the design was very specific. That's why it
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`remains in my memory vividly for most of the parts.
`
`There are some parts that I cannot recall.
`
` Q. All right. Please turn to Page 9 of your
`
`declaration. We're on paragraph "j."
`
` You indicate that Pages 45 to 58 of your
`
`declaration contains hardware schematics; is that
`
`correct?
`
` A. Let me check.
`
` (Perusing document.)
`
` Yes. Page 45 to 58 indicates the hardware
`
`for Mini-RIT.
`
`Fredericks Reporting & Litigation Services - A Veritext Company
`(512) 640-6040
`
`Page 17
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`Exh. p. 17
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` Q. Turning back to Page 9 of your declaration --
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` A. I am on Page 9.
`
` Q. -- in the middle of paragraph "j," do you see
`
`where your declaration states that the Mini-RIT
`
`apparatus had a cellular telephone?
`
` A. Okay. What is your question?
`
` Q. I asked you to take some time to review the
`
`diagrams on pages 45 to 58, and tell me on what pages of
`
`the diagrams shows that cellular telephone.
`
` A. Of these pages, there is no cellular interface
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`diagram.
`
` Q. Have you reviewed all of pages 45 through 58
`
`looking for that cellular telephone?
`
` A. Yes, I have gone through pages. I have not
`
`seen -- I do not see the cellular interface diagram.
`
` Q. How about a cellular telephone diagram?
`
` A. I'm looking. (Perusing document.)
`
` On Page 47, there is a small block diagram
`
`called "Cutover Modem" into "Crypto Interface." Again,
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`the communication -- the data communication could be
`
`routed in several ways. Cellular data can go through
`
`the cutover modem and other paths, so that's block
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`diagram may represents a path to the cellular modems.
`
` Q. Does the diagram on Page 47 show a cellular
`
`telephone itself, not just the interface?
`
`Fredericks Reporting & Litigation Services - A Veritext Company
`(512) 640-6040
`
`Page 18
`
`Exh. p. 18
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` A. There is a small block diagram called "Cutover
`
`Modem."
`
` Q. Is the Cutover Modem a cellular telephone?
`
` A. It could be.
`
` Q. Was it intended to indicate that it is a
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`cellular telephone specifically?
`
` A. I do not recall that the block diagrams.
`
`Again, these block diagrams could be the first ideas
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`came out and it represents a certain hardware
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`configurations.
`
` Q. So is the Cutover Modem specifically referring
`
`to a cellular telephone or is that a general reference
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`to a modem?
`
` A. It is a general representation of data transfer
`
`across the telephone line. It cannot specifically call
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`out as a cellular modem.
`
` Q. Okay. Let's turn back to Page 8 of your
`
`declaration.
`
` A. I'm back on Page 8.
`
` Q. Page 8, you state in paragraphs "g" and "h"
`
`that pages 32 to 38 contain some additional diagrams of
`
`the Mini-RIT apparatus. I'll ask you to take some time
`
`to review those pages, 32 to 38, and see if any of those
`
`pages show a cellular telephone.
`
` A. Okay. I'm looking at 32.
`
`Fredericks Reporting & Litigation Services - A Veritext Company
`(512) 640-6040
`
`Page 19
`
`Exh. p. 19
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` (Perusing document.)
`
` From Page 32 to 38, I do not see the
`
`diagram for the cellular.
`
` Q. Okay. Please now turn to Page 4 of your
`
`declaration, paragraph "d," which refers to the FAX-CAM
`
`apparatus.
`
` Tell me when you get there.
`
` A. I'm on Page 4.
`
` Q. Yes. Page 4, paragraph "d," which refers to
`
`the FAX-CAM apparatus.
`
` A. Okay.
`
` Q. You state here that the FAX-CAM apparatus
`
`included a processor.
`
` Is that correct?
`
` A. That is correct.
`
` Q. And you further state that the processor had
`
`multiple functionalities that you list in your
`
`declaration in paragraph "d."
`
` Is that correct?
`
` A. Let me read.
`
` (Perusing document.)
`
` Okay. Paragraph "d" spans several pages.
`
`You want me to confirm all those items are yes in
`
`general, making a general statement?
`
` Q. What I'd like you to confirm is that you state
`
`Fredericks Reporting & Litigation Services - A Veritext Company
`(512) 640-6040
`
`Page 20
`
`Exh. p. 20
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`in your declaration that the processor was configured to
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`perform all of those functionalities that you list in
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`paragraph "d."
`
` Is that correct?
`
` A. That is correct. The processor has configured
`
`for those functions.
`
` Q. Please now turn to Page 5 of the declaration.
`
` A. I'm on Page 5.
`
` Q. Near the middle of that block paragraph, it
`
`reads, quote, control dialing functions of the telephone
`
`and the cellular telephone, control the telephone line
`
`communications, control the cellular telephone
`
`communications, end quote.
`
` Is that correct?
`
` A. The entire system was designed to process the
`
`cellular -- the data through cellular interface.
`
` Q. So that's what the processor was configured to
`
`do; is that correct?
`
` A. Yes. The processor, in general, there are
`
`several processors configuring for that functions.
`
` Q. Further down on the same page, the declaration
`
`reads, quote, control sending of an image over the
`
`cellular telephone, end quote.
`
` Is that correct?
`
` A. Okay. Repeat that question, please.
`
`Fredericks Reporting & Litigation Services - A Veritext Company
`(512) 640-6040
`
`Page 21
`
`Exh. p. 21
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` Q. Further down on the same page, the declaration
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`reads, quote, control sending of an image over the
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`cellular telephone.
`
` Is that what your declaration states?
`
` A. Yes, that is true.
`
` Q. Further down three lines, your declaration
`
`reads, quote, control receiving of an image over the
`
`cellular telephone.
`
` Is that correct?
`
` A. That is correct.
`
` Q. Are those functions relating to sending and
`
`receiving an image over the cellular telephone referring
`
`to functionalities of the processor?
`
` A. Repeat that question again.
`
` Q. Are those functions relating to sending and
`
`receiving an image over the cellular telephone, are
`
`those referring to the functionalities of the processor?
`
` A. The cellular modem would be the media that
`
`transfer the data. The processor functions is to
`
`collecting imagings, compress it, decompress it, or
`
`whatever needed to transmit through the cellular media.
`
` Q. But what you state in your declaration there,
`
`those are functions of a processor?
`
` A. That is correct, but again, depends on which
`
`processor you're talking about. There are several
`
`Fredericks Reporting & Litigation Services - A Veritext Company
`(512) 640-6040
`
`Page 22
`
`Exh. p. 22
`
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`processor in the design, but in general, the processor
`
`that I declare would be for doing those functions, yes.
`
` Q. Were those functions for sending and receiving
`
`an image over the cellular telephone important to the
`
`FAX-CAM project?
`
` A. The data would be, for example, the capturing
`
`data would be at the low level, those are the picture
`
`elements. After that, there are some other processor
`
`that doing the compression, decompression, encryption,
`
`decryptions, and formatting to the cellular format.
`
`Those are all the functions that belonging to the image
`
`processing processor, if you will.
`
` Q. So were those functions important for the
`
`FAX-CAM project?
`
` A. Absolutely. Without those functions, you just
`
`cannot transfer the data.
`
` Q. So can you tell me why those functions were
`
`important?
`
` A. There are certain format that you re-conforming
`
`to the transferred media, again, for example, the
`
`processing of the data is to compress the data to make
`
`the data smaller, and the cellular format has certain
`
`protocols that we have to conform to, and therefore, the
`
`processor will take the image and format it into
`
`whatever the protocol are required by the cellular
`
`Fredericks Reporting & Litigation Services - A Veritext Company
`(512) 640-6040
`
`Page 23
`
`Exh. p. 23
`
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`system or the modem data modulation and demodulation
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`protocols. Those functions are important because
`
`without it, you cannot transfer the data across the
`
`transferred media.
`
` Q. Are you saying that the processor was important
`
`for image processing for transmitting and receiving over
`
`the cellular network?
`
` A. That is correct.
`
` Q. At the time, did the FAX-CAM apparatus actually
`
`have a cell phone?
`
` A. We had a cell phone, yes, up to the best of my
`
`knowledge as of today.
`
` Q. If you'd turn to Page 3 of your declaration --
`
` A. Say it again.
`
` Q. Please turn to Page 3 of your declaration.
`
` A. Page 3. I'm on Page 3.
`
` Q. Here you state that Pages 11 through 15 of your
`
`declaration contain conceptual schematics for FAX-CAM.
`
` Do you see that?
`
` A. Yes.
`
` Q. And turning to Page 4 now, paragraphs "c" and
`
`"d" --
`
` A. I'm on Page 4, "c" and "d."
`
` Q. -- you state that Pages 16 through 18 contain
`
`more diagrams of FAX-CAM.
`
`Fredericks Reporting & Litigation Services - A Veritext Company
`(512) 640-6040
`
`Page 24
`
`Exh. p. 24
`
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` Do you see that?
`
` A. Right.
`
` Q. And then turning to Page 6 of your
`
`declaration --
`
` A. Okay.
`
` Q. -- you state that Page 19 contains another
`
`diagram for FAX-CAM.
`
` Do you see that?
`
` A. Yes, I saw it.
`
` Q. I'll ask you now to take some time to review
`
`the diagrams on Pages 11 through 19 of your declaration
`
`and tell me if any of those diagrams show a cellular
`
`telephone.
`
` A. Okay. I'm looking.
`
` (Perusing document.)
`
` Through Page 11 through 19. On Page 12,
`
`there is a block diagram on Page 12, and on one of the
`
`block diagram -- on the two block diagrams show RJ-11,
`
`those are the interface to the cellular modem also.
`
` Q. Okay. So on Page 12, which block shows a
`
`cellular telephone?
`
` A. If you look at the two block diagram with the
`
`word "RJ-11," those are the interface to the cellular
`
`modem.
`
` Q. Okay. You say RJ-11 is an interface, but is
`
`Fredericks Reporting & Litigation Services - A Veritext Company
`(512) 640-6040
`
`Page 25
`
`Exh. p. 25
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`there an actual cellular telephone in that diagram?
`
` A. No, there isn't any actual cellular modem in
`
`this diagram. It show an interface.
`
` Q. I'm referring back to Page 11, you said this is
`
`another block diagram. Is there an interface for a
`
`cellular telephone in this diagram?
`
` A. The RJ-11 would be the interface to the
`
`cellular modem.
`
` Q. Is there an actual cellular telephone in that
`
`diagram other than the interface?
`
` A. No.
`
` Q. I'd like the reporter to hand you back
`
`Exhibit 1006, the one that she marked. Please tell me
`
`when you get that back.
`
` A. I have it.
`
` Q. Okay. You had marked with an asterisk a part
`
`that you said is a cellular interface; is that correct?
`
` A. There are two sections on that circlings
`
`diagrams. One is the interface to a smaller block
`
`diagram. The interface is what you see there on
`
`Page 12, RJ-11. The other block diagram could represent
`
`a cellular modem.
`
` Q. On that Exhibit 1006 where you put the
`
`asterisk, is there actually a cellular phone in that
`
`diagram?
`
`Fredericks Reporting & Litigation

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