In The Matter Of:
`
`SAMSUNG ELECTRONICS CO. LTD,
`v.
` REMBRANDT WIRELESS TECHNOLOGIES, LP
`
` ___________________________________________________
`
`DAVID GOODMAN, Ph.D. - Vol. 1
`November 7, 2014
`
` ___________________________________________________
`
`
`
`
`REMBRANDT EXHIBIT 2211
`
`
`
`SAMSUNG ELECTRONICS CO. LTD,
`v.
` REMBRANDT WIRELESS TECHNOLOGIES, LP
`
` ___________________________________________________
`
`DAVID GOODMAN, Ph.D. - Vol. 1
`November 7, 2014
`
` ___________________________________________________
`
`
`
`
`REMBRANDT EXHIBIT 2211
`
`
`
`DAVID GOODMAN, Ph.D. - 11/7/2014
`
`Page 1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO. LTD,
`
`SAMSUNG ELECTRONICS AMERICA, INC.,
`
`SAMSUNG TELECOMMUNICATIONS AMERICA, LLC, and
`
`SAMSUNG AUSTIN SEMICONDUCTOR, LLC;
`
` (SAMSUNG)
`
` Petitioner
`
` V.
`
`REMBRANDT WIRELESS TECHNOLOGIES, LP
`
` Patent Owner
`
` _______________
`
` Case No. IPR2014-00518
`
` Patent 8,023,580
`
` Videotape Oral Examination of:
`
` DAVID GOODMAN, Ph.D.
`
` Location: Pepper Hamilton LLP
`
` New York Times Building
`
` 37th Floor, Eighth Avenue
`
` New York, New York 10018
`
` Date: November 7, 2014
`
` Time: 9:00 a.m.
`
`Reported By:
`
`Greg DiDonato, CSR, RPR, CP, CM, CRR
`
`617-542-0039
`
`Merrill Corporation - Boston
`www.merrillcorp.com/law
`
`REMBRANDT EXHIBIT 2211
`
`
`
`DAVID GOODMAN, Ph.D. - 11/7/2014
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`Page 2
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` November 7, 2014
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` 9:00 A.M.
`
`Videotape Deposition of:
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` DAVID GOODMAN, PH.D.,
`
`called for oral examination by counsel for
`
`Patent Owner, Rembrandt Wireless Technologies,
`
`LP, pursuant to notice, held at the offices of
`
`Pepper Hamilton LLP, The New York Times
`
`Building, 37th Floor, Eighth Avenue, New York,
`
`New York 10018, before Gregory DiDonato of
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`Merrill Corporation, a Notary Public and
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`Certified Realtime Reporter in and for the
`
`State of New York, beginning at 9:06 a.m.,
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`when were present on behalf of the respective
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`
`
`DAVID GOODMAN, Ph.D. - 11/7/2014
`
`Page 3
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`A P P E A R A N C E S
`
`On behalf of the Petitioner, Samsung:
`
` JEFFREY A. MILLER, ESQUIRE
`
` Dickstein Shapiro LLP
`
` 1841 Page Mill Road, Suite 150
`
` Palo Alto, CA 94304
`
` (605) 690-9554
`
` millerj@dicksteinshapiro.com
`
` DANIEL G. CARDY, ESQUIRE
`
` Dickstein Shapiro LLP
`
` 1825 Eye Street NW
`
` Washington, DC 20006
`
` (202) 420-3033
`
` cardy@dicksteinshapiro.com
`
`On behalf of Patent Owner, Rembrandt Wireless:
`
` GEORGE HAIGHT, ESQUIRE
`
` REZA MOLLAAGHABABA, ESQUIRE
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` ANDREW SCHULTZ, ESQUIRE
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` Pepper Hamilton LLP
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`15
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` 19th Floor, High Street Tower
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` 125 High Street
`
`16
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` Boston, MA 02110
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` (617) 204-5150
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` haightg@pepperlaw.com
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` mollaaghababar@pepperlaw.com
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` schultza@pepperlaw.com
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`ALSO PRESENT:
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` David Peloza, Videographer
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`DAVID GOODMAN, Ph.D. - 11/7/2014
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`Page 4
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` P R O C E E D I N G S
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` THE VIDEOGRAPHER: This is the video
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`operator speaking, David Peloza, from Merrill
`
`Legal Solutions. Today's date is November 7,
`
`2014, the time is 9:06. We're at 620 Eighth
`
`Avenue, New York City for the deposition of
`
`Mr. David Goodman in the matter Rembrandt
`
`Wireless Tech versus Samsung Electronics
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`Company, Limited, et al.
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` I'd like the attorneys to introduce
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`themselves starting with Mr. Haight.
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` MR. HAIGHT: George Haight from
`
`Pepper Hamilton on behalf of patent owner
`
`Rembrandt Wireless. With me is Reza
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`Mollaaghababa and Andrew Schultz also from
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`Pepper Hamilton.
`
` MR. MILLER: Jeffrey Miller from
`
`Dickstein Shapiro representing the Samsung
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`Petitioners, and with me is Daniel Cardy, also
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`of Dickstein Shapiro.
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` THE VIDEOGRAPHER: Now swear the
`
`witness.
`
` THE REPORTER: Raise your right hand,
`
`please.
`
` Do you solemnly swear that the
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`09:07:07
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`09:07:15
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`09:07:15
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`617-542-0039
`
`Merrill Corporation - Boston
`www.merrillcorp.com/law
`
`REMBRANDT EXHIBIT 2211
`
`
`
`DAVID GOODMAN, Ph.D. - 11/7/2014
`
`Page 5
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`testimony you will give today will be the
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`truth, the whole truth, and nothing but the
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`truth, so help you God?
`
` THE WITNESS: Yes.
`
`09:07:16
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`WHEREUPON,
`
` DAVID GOODMAN, Ph.D., called as a
`
`witness, and having been first duly sworn, was
`
`examined and testified as follows:
`
`EXAMINATION BY COUNSEL FOR PATENT OWNER,
`
`REMBRANDT WIRELESS TECHNOLOGIES, LP
`
`BY MR. HAIGHT:
`
` Q. Dr. Goodman, good morning.
`
` A. Good morning.
`
` Q. Thank you for being here. My name is
`
`George Haight. I work at the law firm of
`
`Pepper Hamilton. I represent Rembrandt
`
`Wireless in this proceeding.
`
` Have you ever been deposed before,
`
`sir?
`
` A. Yes.
`
` Q. How many times?
`
` A. Probably ten; maybe more.
`
` Q. When was the last time you had your
`
`deposition taken?
`
` A. Towards the end of last year. I
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`09:07:18
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`
`
`DAVID GOODMAN, Ph.D. - 11/7/2014
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`Page 6
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`don't remember exactly.
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` Q. As I'm sure you are aware, there are
`
`a few rules of how today is going to go; just
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`to go over those for a little bit of
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`housekeeping.
`
` I'll be asking you questions
`
`throughout the day. If any part of my
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`question you do not understand, please, ask me
`
`and I will clarify. If you do provide an
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`answer, I will assume you did understand the
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`question. Is that fair?
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` A. Yes.
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` Q. From time to time, your counsel may
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`object to my questions. Unless he
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`specifically asks you to not answer, you
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`should go ahead and answer the question.
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` Today, also, our intent is not a
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`marathon. So, if at any time you feel like
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`you need a break, please, let us know. We'll
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`take them as frequently as we need to. All
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`I'll ask is that if there's a pending
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`question, you'll answer the question before we
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`break. Is that fair?
`
` A. Fair enough.
`
` MR. HAIGHT: Thank you. I'm going to
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`617-542-0039
`
`Merrill Corporation - Boston
`www.merrillcorp.com/law
`
`REMBRANDT EXHIBIT 2211
`
`
`
`DAVID GOODMAN, Ph.D. - 11/7/2014
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`Page 7
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`hand you what we'll mark as Exhibits Goodman-1
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`and Goodman-2.
`
` (Exhibit-1, Notice of Deposition of
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`David Goodman for 518, 3 pages, marked for
`
`identification.)
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` (Exhibit-2, Notice of Deposition of
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`David Goodman for 519, 3 pages, marked for
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`identification.)
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` THE REPORTER: Exhibit 1. Exhibit 2.
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` MR. MILLER: Counsel, can you tell me
`
`which one is which?
`
` MR. HAIGHT: The Notice of Deposition
`
`of David Goodman for the 518 is Exhibit 1.
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` MR. MILLER: Thank you.
`
`BY MR. HAIGHT:
`
` Q. Have you seen this document before,
`
`sir?
`
` A. Yes.
`
` Q. And what is your understanding of
`
`this document?
`
` A. It announces today's event, this
`
`deposition, and it says that it's related to
`
`the IPR, the inter partes review of the, what
`
`we call the '580 patent owned by Rembrandt.
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` Q. And it's your understanding that you
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`09:10:17
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`617-542-0039
`
`Merrill Corporation - Boston
`www.merrillcorp.com/law
`
`REMBRANDT EXHIBIT 2211
`
`
`
`DAVID GOODMAN, Ph.D. - 11/7/2014
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`Page 8
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`are here to testify on behalf of Samsung,
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`petitioners?
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` A. Correct.
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` Q. In the 518 and 519 IPR proceedings?
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` A. That's my understanding; yes.
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` MR. HAIGHT: Thank you. You can set
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`those aside.
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` (Exhibit-3, Declaration of David
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`Goodman for 518, 74 pages, marked for
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`identification.)
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` (Exhibit-4, Declaration of David
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`Goodman for 519, 74 pages, marked for
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`identification.)
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` THE REPORTER: Exhibit 3. Exhibit 4.
`
`BY MR. HAIGHT:
`
` Q. Now I'm going to hand you what we'll
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`mark as Exhibits 3 and 4.
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` Starting with what's been marked as
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`Exhibit 3, do you recognize that document?
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` A. Yes.
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` Q. What is that Exhibit 3?
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` A. It's a declaration I prepared in
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`support of a petition for inter partes review
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`of the '580 patent.
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` Q. This is the declaration you submitted
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`09:10:19
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
`
`REMBRANDT EXHIBIT 2211
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`
`
`DAVID GOODMAN, Ph.D. - 11/7/2014
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`Page 9
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`in the 518 proceeding?
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` A. Correct.
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` Q. And if you could turn to Exhibit 4.
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` Do you recognize that document?
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` A. Yes.
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` Q. What is that document?
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` A. It's a declaration that I prepared in
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`support of a petition for inter partes review
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`of the same patent.
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` Q. And it doesn't say so on the front
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`page, but do you understand that to be the
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`declaration you submitted in the 519
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`proceeding?
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` A. Yes, I do.
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` Q. Let's turn back to Exhibit 3, which
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`was your declaration for the 518 proceeding;
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`and, specifically, if you could turn to
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`Appendix A, which is page 63 out of 71 of that
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`document.
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` Do you recognize what's in Exhibit A
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`of your declaration?
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` A. Yes; that's my CV, my resume.
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` Q. And is that CV current as of today?
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` A. I could mention one thing that's a
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`little different. So, it says, my employment
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`
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`DAVID GOODMAN, Ph.D. - 11/7/2014
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`Page 10
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`at Polytechnic Institute of New York
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`University. So, somewhere after I prepared
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`this, the Polytechnic Institute became the
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`School of Engineering of New York University;
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`so, it has a new name.
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` Q. Are you still employed by the School
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`of Engineering at New York University?
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` A. Yeah. I'm a professor emeritus. So
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`it is kind of an honorary position. So, I
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`have a desk and access to the library and
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`computer, but I don't get a paycheck.
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` Q. Do you still teach?
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` A. No.
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` Q. What sort of activities do you
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`partake in as a professor emeritus?
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` A. There's an organization called NYU
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`Wireless, which is a growing research center,
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`and I participate in discussions of their
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`research. I work with some of the professors
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`on some of their teaching activities, I guess,
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`give them advice -- because I'm older than
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`most of them, all of them -- and also I've
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`been on various committees, government
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`committees and things, and I suppose in some
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`sense representing the university.
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`09:14:51
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`
`
`DAVID GOODMAN, Ph.D. - 11/7/2014
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`Page 11
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` Q. You mentioned that you had your
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`deposition taken roughly around ten times; is
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`that correct?
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` A. That's what I said; yes.
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` Q. How many of those ten were patent
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`infringement cases?
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` A. Most of them were; there's one that
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`had to do with trade secrets, intellectual
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`property of some sort.
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` Q. How many of the ten times you were
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`deposed were you on the plaintiff's side of
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`the case, if any?
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` A. In depositions, I could remember one,
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`and the others I think were defendants.
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` Q. Defense.
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` A. There might have been another one
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`but, as I sit here, I can remember one.
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` Q. You said the last time you were
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`deposed was about a year ago?
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` A. Yes.
`
` Q. Do you recall what the case was?
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` A. I can recall what the technology was.
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`There were several defendants, and the patent
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`owner was a company called Band Speed, and
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`they were suing a lot of different companies,
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`DAVID GOODMAN, Ph.D. - 11/7/2014
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`in particular, I was representing what they
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`called end-user defendants. That was the most
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`recent deposition before this one.
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` Q. How many of those ten depositions
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`were within the last years?
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` A. Two or three, maybe.
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` Q. Do you remember what those cases
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`were?
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` A. Sorry, not as I sit here.
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` Q. Do you remember the technologies
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`involved?
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` A. Obviously, I'm having trouble
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`remembering out of these ten which ones were
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`the last.
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` Q. I'm not trying to test your memory.
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` A. I'm sorry. Mr. Haight, I'm trying to
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`help you.
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` Q. Have you ever done any prior
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`consulting work, litigation based or not, with
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`Samsung?
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` A. Yes.
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` Q. When was that?
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` A. I would guess about five years ago
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`some attorneys from Samsung asked me to help
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`them with something. It didn't go very far, I
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`DAVID GOODMAN, Ph.D. - 11/7/2014
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`think.
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` Q. Was it a litigation matter or --
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` A. I think it was a litigation matter
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`and, as I recall it, it had to do with
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`cellular technology.
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` Q. Were you formally engaged by Samsung
`
`at that point?
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` A. I think so; yes.
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` Q. And, roughly, how far, you said it
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`didn't go very far, do you know how far it
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`went?
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` A. The last I heard, I think the
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`litigation was stayed, and I haven't heard
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`that it revived or maybe settled. I don't
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`know.
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` Q. Did you provide an expert report in
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`that?
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` A. No.
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` Q. If you could turn to, I guess, back
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`to the beginning of your declaration, page 3,
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`which is page 6 of 71 of what's been marked as
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`Exhibit 3.
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` And in paragraph 12, it states that
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`in 2000-2001, you supervised the Master of
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`Science Research of Richard Lavery.
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`DAVID GOODMAN, Ph.D. - 11/7/2014
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`Page 14
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` What was the extent of your
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`involvement in that supervision?
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` A. I suggested a master of science topic
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`to him, and aroused his interest in working on
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`this; and, also, suggested, pretty much
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`directed him on how to proceed, because he
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`hadn't done research before. He was the top
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`student at the university, or certainly in my
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`department.
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` So, I was helping him along. And
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`then suddenly one day, I don't know, I saw a
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`flash in his eyes, and he suddenly realized
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`why he was doing it and how to proceed -- he's
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`a very bright guy -- and I as a professor
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`helped him along, and then he could take it,
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`pick up the ball and run with it himself.
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` Q. Would you say that supervisory role
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`was mostly administrative or were there
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`technical aspects to it?
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` A. It was definitely technical.
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` Q. Definitely technical?
`
` A. Yes.
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` Q. In what way was it technical?
`
` MR. MILLER: Objection; form.
`
` A. In the sense that most of my
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`DAVID GOODMAN, Ph.D. - 11/7/2014
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`interaction with him had to do with discussing
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`the technology, explaining the technology to
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`him, and then saying why there was new
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`knowledge required, why this new knowledge
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`would be helpful; and then how to investigate
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`the problem that I thought would be of
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`interest to him and to other people.
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` Q. And is it fair to say that the
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`problem that you were looking into was
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`throughput optimization for wireless data
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`transmission?
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` A. Yes.
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` Q. And how would you describe generally
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`what throughput optimization is?
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` A. In wireless communication, there are
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`changing transmission conditions. So, it
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`depends on where you are relative to the other
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`transmitter and receiver. And it also depends
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`on the environment; so, what other transmissions
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`are taking place.
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` And what you would like to do, or
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`this particular aspect of this that I
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`suggested to optimize, is how much data you
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`can push through this wireless, what we call
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`the wireless channel in any amount of time.
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`DAVID GOODMAN, Ph.D. - 11/7/2014
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` And it turns out that if the
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`conditions are bad, it's harder to send data.
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`And the way in which you should do it is
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`different than if the conditions are good.
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` So, if it was very noisy here, I
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`might be speaking louder or speaking slower
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`than if we were in a quiet room, and I could
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`speak more quickly, and you could understand
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`me.
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` And in this case, the adjustments we
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`were talking about are called modulation and
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`coding and, particularly, the coding part, how
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`much coding you should do to make the
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`transmissions more robust in bad conditions,
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`and then how to maybe make them less robust
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`when that's not necessary, and then you could
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`transmit faster, because protecting the
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`transmissions takes up time and resources.
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` Q. So, is it fair to say that the
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`throughput optimization is more based around
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`the coding of the transmission?
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` A. In this work, Lavery looked at the
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`coding. And then we have a colleague,
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`Professor Goldsmith at Stanford who was
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`looking at modulation, adaptive modulation
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`DAVID GOODMAN, Ph.D. - 11/7/2014
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`techniques, and we spent some time together
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`putting these two things together, doing
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`adaptive modulation and coding.
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` Q. That's a very nice segue. Thank you.
`
` In paragraph 14, you mentioned that
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`you and Mr. Lavery collaborated with Professor
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`Goldsmith. Is that the collaboration you were
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`just discussing?
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` A. Exactly, yes.
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` Q. And what was the extent of your
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`personal collaboration in that project?
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` A. I had an opportunity to spend a month
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`at Stanford, I was on sabbatical a few years
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`after Lavery submitted his thesis, and I knew
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`Goldsmith's work, and she introduced me to a
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`graduate student who was working on adaptive
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`modulation.
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` And so, her graduate student and I,
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`essentially, combined -- I showed him, I gave
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`him -- Lavery was off working somewhere, but
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`he sent us some of his computer programs --
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`and somehow the Stanford student put it all
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`together.
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` Q. And you mentioned the work that was
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`being done at Stanford is adaptive modulation.
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`DAVID GOODMAN, Ph.D. - 11/7/2014
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`What is adaptive modulation?
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` A. Adaptive modulation talks about how
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`much information, how much information you can
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`send through a channel, just as I was saying
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`about coding, but now you can change the
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`waveforms that you transmit.
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` So, we talk about multilevel
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`modulation. So, it would be very nice if I
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`could select from one of 256 different
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`waveforms, which might happen if there's a
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`microwave tower on the roof here, and it can
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`see another microwave antenna somewhere else,
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`they can choose from 256 different waveforms,
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`send one of them, and one out of 256 would
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`represent 8 bits.
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` However, if you're walking around
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`with a cell phone, and you're in an
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`environment where there are a lot of other
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`cell phones, the receiver couldn't distinguish
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`256 different things. So, you would use a
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`modulation technique that sends fewer
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`waveforms.
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` So, depending -- so, if the cell
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`phone example, depending on where you are, if
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`you're next to the tower, you can probably
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`DAVID GOODMAN, Ph.D. - 11/7/2014
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`send more. If you're further away, you better
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`change to a modulation technique that uses
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`fewer.
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` Q. So, is it fair to say that the
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`modulation portion of the work that you were
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`doing would alter the waveform going through,
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`but the coding is more about the transmission
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`of that waveform?
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` MR. MILLER: Objection; foundation.
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` A. I would put it a little differently.
`
` Q. Please, go ahead.
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` A. So, before I choose a waveform, I
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`have -- we're talking about digital
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`transmission here. So, essentially, I'm
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`sending numbers.
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` And so, I have to choose which number
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`to send, and I'm sending a sequence of
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`numbers. And, in coding, I can start with the
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`information that I want the receiver to get,
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`and then I can add some, what we call
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`redundancy. So that if the signal doesn't
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`arrive perfectly or if the demodulator doesn't
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`understand exactly which waveform is there,
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`the receiver still might be able to get the
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`message.
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`DAVID GOODMAN, Ph.D. - 11/7/2014
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` For example, there's a lot of
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`redundancy in our English language; so,
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`there's a lot of extra stuff. And I noticed
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`rereading my report, I saw a few typographical
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`errors, but it's pretty obvious, I could
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`correct them pretty quickly.
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` And so, the coding is taking the
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`source information and adding additional
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`information, which we call redundancy, and
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`creating another set of numbers. So, there's
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`a new set of numbers that's longer than the
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`old set. And then the modulation technique
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`transmits one of the numbers.
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` Q. And I meant to ask you this before,
`
`but just to backtrack. You mentioned there
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`were a few typos. Aside from those typos, is
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`there anything in your declaration that in
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`your review you would change or is incorrect?
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` A. Yeah. I don't know if I could find
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`it, but there's one word that I would change
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`besides the --
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` Q. Besides the typos?
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` A. Yes. I think it's in the second one.
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` Q. That would be Exhibit 4, the 519?
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` A. I think so. Let me see if I could
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
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`REMBRANDT EXHIBIT 2211
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`
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`DAVID GOODMAN, Ph.D. - 11/7/2014
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`Page 21
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`find it.
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` THE WITNESS: Do you plan to
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`introduce the patent '508 as an exhibit?
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` MR. HAIGHT: Yes. I can do it now,
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`If that would help you.
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` THE WITNESS: It has to do with two
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`claims, and if I can see the claim, I can
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`probably find where they are in the report.
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` MR. HAIGHT: Sure.
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` Mark this as Exhibit-5.
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` (Exhibit-5, U.S. Patent 8,023,580, 19
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`pages, marked for identification.)
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` THE REPORTER: Exhibit 5.
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` THE WITNESS: Thank you.
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`BY MR. HAIGHT:
`
` Q. Do you recognize what's been handed
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`to you as Exhibit 5?
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` A. Yes.
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` Q. What is that?
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` A. This is what I've been referring to
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`as the '580 patent. United States Patent
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`entitled, "System And Method Of Communication
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`Using At Least Two Modulation Methods," the
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`inventor is Gordon Bremer, and issued in
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`September 20th, 2011.
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`617-542-0039
`
`Merrill Corporation - Boston
`www.merrillcorp.com/law
`
`REMBRANDT EXHIBIT 2211
`
`
`
`DAVID GOODMAN, Ph.D. - 11/7/2014
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`Page 22
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` Q. And it's your understanding that that
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`patent is the subject of these IPR
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`proceedings?
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` A. Yes. Sorry. There's one word in 230
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`paragraphs.
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` Q. I understand.
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` A. It appeared twice in some other
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`context.
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` Q. It's a needle in a haystack, I'm
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`sure.
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` A. Yeah. I'm sorry about that.
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` Q. Did the patent help you at all find
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`it?
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` A. I thought it did, but...
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` Yeah. I think one of the places is,
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`I think, paragraph 258. That's on page 57.
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`It's 57 of 518. Sorry.
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` Q. That's exhibit?
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` A. Exhibit 3.
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` Q. And what was the error there?
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` A. If you look at -- well, so that the
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`error was that, it says that station 22 can
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`receive PPM stroke DQPSK transmissions, and
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`the word "receive" should be "transmit."
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` And there's another claim, I found
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`09:39:00
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`617-542-0039
`
`Merrill Corporation - Boston
`www.merrillcorp.com/law
`
`REMBRANDT EXHIBIT 2211
`
`
`
`DAVID GOODMAN, Ph.D. - 11/7/2014
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`Page 23
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`claim 77 when I looked at the patent. And
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`then there's an earlier claim or claim
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`limitation that says the same thing, and I
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`guess I cut and pasted my explanation from one
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`to the other; so, they both have the same,
`
`require the same correction.
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` (Pause.)
`
` Q. Okay. We can move on, if you don't
`
`think you're going to be able to find it. It
`
`may come up later.
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` A. Yeah. I think you'll find the text
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`is the same, because the claim or the claim
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`limitation is the same, and it requires the
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`same adjustment, the word "receive" should
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`have been "transmit."
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` Q. Now, just circling back on the
`
`conversation we were having before.
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` Would you agree with me that an
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`encoding process is different than the
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`modulation process?
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` A. Yes.
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` Q. When you're encoding a signal, you're
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`not altering the underlying waveform; is that
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`correct?
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` A. I wouldn't say, I wouldn't say what
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`617-542-0039
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`Merrill Corporation - Boston
`www.merrillcorp.com/law
`
`REMBRANDT EXHIBIT 2211
`
`
`
`DAVID GOODMAN, Ph.D. - 11/7/2014
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`you did to explain the coding and modulation.
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` So, I would talk about encoding
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`information rather than encoding a signal.
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`So, I would somehow encode the information,
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`and then represent that information as some
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`sort of waveform.
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` Q. So, would it be correct to say that
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`encoded information can be sent using
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`different waveforms?
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` MR. MILLER: Objection; form.
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` A. I'm sorry. I've read so many student
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`essays and exam papers. If a student wrote
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`that, I wouldn't think it's entirely accurate.
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`I think I know what, I might guess what the
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`student is trying to say.
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` First of all, there have to be
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`different waveforms or you wouldn't transmit,
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`you wouldn't be sending any information.
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` So, Alice in Wonderland, I wish my
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`cat would purr and meow. If it only purrs, I
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`don't know what is going on. If it purrs and
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`meows, I have some information. So, you have
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`to have more than one waveform.
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` So, I think you might have meant a
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`different set of waveforms, or did you mean --
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`09:44:48
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`09:44:50
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`617-542-0039
`
`Merrill Corporation - Boston
`www.merrillcorp.com/law
`
`REMBRANDT EXHIBIT 2211
`
`
`
`DAVID GOODMAN, Ph.D. - 11/7/2014
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`Page 25
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