Transcript of PHILIP J. KOOPMAN, JR., Ph.D.
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`Date: January 13, 2015
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`Case: SAMSUNG ELECTRONICS CO, LTD, ET AL v. REMBRANDT
`WIRELESS TECHNOLOGIES, LP(PTAB)
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`Planet Depos, LLC
`Phone: 888-433-3767
`Fax: 888-503-3767
`Email: transcripts@planetdepos.com
`Internet: www.planetdepos.com
`
`Court Reporting | Videography | Videoconferencing | Interpretation | Transcription
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`Exhibit 1319 Page 001 of 106
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`VIDEOTAPED DEPOSITION OF PHILIP J. KOOPMAN, JR., Ph.D.
`CONDUCTED ON TUESDAY, JANUARY 13, 2015
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`1 (Pages 1 to 4)
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` A P P E A R A N C E S
` ON BEHALF OF PETITIONERS:
` JEFFREY A. MILLER, ESQUIRE
` DICKSTEIN SHAPIRO LLP
` 1841 Page Mill Road
` Palo Alto, California 94304
` (650) 690-9500
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` DAN CARDY, ESQUIRE
` DICKSTEIN SHAPIRO LLP
` 1825 Eye Street, NW
` Washington, DC 20006
` (202) 420-2200
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` A P P E A R A N C E S C O N T I N U E D
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`--------------------------------------x
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`SAMSUNG ELECTRONICS CO. LTD.; SAMSUNG :
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`ELECTRONICS AMERICA, INC.; SAMSUNG :
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`TELECOMMUNICATIONS AMERICA, LLC; AND : Case:
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`SAMSUNG AUSTIN SEMICONDUCTOR, LLC, : IPR2014-00518
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` Petitioners, : IPR2014-00519
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` v. :
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`REMBRANDT WIRELESS TECHNOLOGIES, LP, : Patent 8,023,580
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` Patent Owner. :
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`--------------------------------------x
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` Videotaped Deposition of
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` PHILIP J. KOOPMAN, JR, Ph.D.
`
` Pittsburgh, Pennsylvania
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` Tuesday, January 13, 2015
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` 8:58 a.m.
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`Job No.: 72502
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`Pages: 1 - 262
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`Reported by: Constance Lee, RPR, RSA
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` Videotaped deposition of PHILIP J. KOOPMAN, JR,
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`2
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`Ph.D., held at the offices of:
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` ON BEHALF OF PATENT OWNER AND DR. KOOPMAN:
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` PEPPER HAMILTON, LLP
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` 500 Grant Street
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` Suite 5000
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` Pittsburgh, Pennsylvania 15219
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` (412) 454-5000
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` Pursuant to Notice, before Constance Lee,
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`Registered Professional Reporter.
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` GEORGE S. HAIGHT, IV, ESQUIRE
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` PEPPER HAMILTON LLP
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` 125 High Street
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` 19th Floor - High Street Tower
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` Boston, Massachusetts 02110
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` (617) 204-5100
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` ALSO PRESENT:
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` Michael Murphy, Videographer
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Exhibit 1319 Page 002 of 106
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`

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`VIDEOTAPED DEPOSITION OF PHILIP J. KOOPMAN, JR., Ph.D.
`CONDUCTED ON TUESDAY, JANUARY 13, 2015
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`2 (Pages 5 to 8)
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` C O N T E N T S
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`EXAMINATION OF PHILIP J. KOOPMAN, JR., Ph.D. PAGE
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` By Mr. Miller 8
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` By Mr. Haight 256
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` E X H I B I T S
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` (Attached to transcript)
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`KOOPMAN DEPOSITION EXHIBIT PAGE
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` Exhibits 1232 and 1320 Data Network Evaluation 41
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` Criteria Handbook
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` Exhibits 1233 and 1321 Koopman Patent 192
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` 5,450,404
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` Exhibits 1234 and 1322 Koopman Patent 194
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` 5,436,901
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` Exhibits 1235 and 1323 Koopman Patent 195
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` 5,535,212
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` Exhibits 1236 and 1324 Innovative Biometric 252
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` Technology v Toshiba
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` America Information
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` Systems and Authetec
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` order
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` P R O C E E D I N G S
` VIDEOGRAPHER: Here begins tape
`number one in the videotape deposition of Philip
`4 Koopman, in the matter of Samsung Electronics
`Company, LTD, et al. versus Rembrandt Wireless
`Technologies, LP, et al. Filed in the United
`States Patent and Trademark Office Case Nos.
`IPR2014-00518 and IPR2014-00519.
` Today's date is Tuesday, January 13th,
`2015, and the time on the video monitor is 8:58
`a.m.
` The videographer today is Michael
`13 Murphy representing Planet Depos. This video
`deposition is being taking place at 500 Grant
`Street, Pittsburgh, PA 15219.
` Will all counsel please voice identify
`yourselves.
` MR. MILLER: Hi. This is Jeffrey
`19 Miller representing the Samsung petitioners in the
`IPR proceedings. With me is Daniel Cardy.
` MR. HAIGHT: George Haight on
`behalf of Rembrandt Wireless Technologies. The
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` E X H I B I T S C O N T I N U E D
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`witness Dr. Koopman.
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`KOOPMAN DEPOSITION EXHIBIT PAGE
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` VIDEOGRAPHER: The court reporter
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` Exhibits 1237 and 1325 Innovative 253
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`PREVIOUSLY MARKED EXHIBIT PAGE
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` Exhibits 2208 and 2302 Declaration of Dr. 11
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` Philip Koopman, Ph.D.
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` Exhibit 2209 and 2303 Embedded Communication 31
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` Protocal Options
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` Exhibits 1218 and 1317 Declaration of Jon 25
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` Mears
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`today is Connie Lee representing Planet Depos.
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` Would you please swear in the witness.
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` PHILIP J. KOOPMAN, JR.
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` a witness herein, having been first duly sworn,
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`was examined and testified as follows:
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` EXAMINATION BY COUNSEL FOR THE PETITIONER
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` BY MR. MILLER:
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` Q. Good morning, Dr. Koopman.
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` A. Good morning.
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` Q. Thank you for being here this morning.
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`I'd like to start off by finding out whether or not
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`you've actually ever had your deposition taken before?
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` A. Yes, I have.
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` Q. About how many times?
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` A. I'd have to check my CV for an exact
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`number, but round number is ten.
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` Q. Ten. So you know the general ground
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`rules?
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` A. I do.
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` Q. So I'll -- I'll just reiterate the ones
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 1319 Page 003 of 106
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`

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`VIDEOTAPED DEPOSITION OF PHILIP J. KOOPMAN, JR., Ph.D.
`CONDUCTED ON TUESDAY, JANUARY 13, 2015
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`9
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`3 (Pages 9 to 12)
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`that I find most important.
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` A. Okay.
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` Q. The first is, is that while I've never
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`worked with Connie, our court reporter, I'm sure she's
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`terrific. But as great as I'm sure she is, there's no
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`way she's going to be able to take down every word if
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`everyone in the room is talking over each other. And
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`so I'd would appreciate it, and I'll do my best at
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`this too, is if I'm speaking, if you can let me finish
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`and I'll do my best to let you finish as well. Is
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`that okay?
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` A. Okay. No problem.
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` Q. Also, we -- this deposition is being
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`taking -- being taken for two different inter partes
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`review proceedings, which I'm sure you understand;
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`right?
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` A. Yes.
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` Q. And so the very nature of that is going
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`to require that sometimes we -- we have two different
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`exhibits that are oftentimes the same that are being
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`numbered differently. And I know that's a little
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` A. I understand.
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` Q. Great.
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` So I'm going to start by have --
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`providing you with copies of the declarations you
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`filed or that you prepared in each of the IPR
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`proceedings that we're here to discuss today.
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` The first, which was filed in the IPR
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`2014-00518 proceeding was marked as Exhibit 2208. And
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`the second was filed in the IPR proceeding case number
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`IPR 2014-00519, and that was marked as Exhibit 2302.
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` (Exhibits 2208 and 2302 were
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`entered for reference.)
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` MR. HAIGHT: Thank you.
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` Q. Have you had a chance to look at those
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`two different exhibits?
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` (Witness reviews document.)
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` A. Yes, these look like the two reports I
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`filed.
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` Q. Thank you.
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` Can you tell me if there are any
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`differences substantively between the two reports?
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` A. I -- I think there's a footnote that
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`confusing. But we're -- we're going to have to work
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`with each other on that. Is that okay?
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` A. Sure. As long as I understand when
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`two documents are supposed to be the same, then
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`I'll be fine.
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`somehow ended up in one or the other, but I --
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`there -- I don't intend there'd be any substantive
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`differences that I recall.
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` Q. Okay. Other than the case number and
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` Q. All right. That's in both of our
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`5 maybe the footnote?
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`interests, so we'll do our best on that.
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` Are you under -- is there any reason that
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`we should be aware of that would prevent you from
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`testifying truthfully today?
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` A. I -- I should be fine.
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` Q. And one more thing, I'm -- I'm going to
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`be asking you questions today, obviously you've seen
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`this process before. And I'll do my best to ask
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`questions that are clear and make sense. But if I ask
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`you a question that you don't understand, could you
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`please let me know, and I'll try to ask it a different
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`way.
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` A. Sure.
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` A. Case number, stuff like that. Yeah.
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` Q. Okay.
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` A. I don't -- I -- as I sit here, I can't
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`recall any substantive difference.
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` Q. Okay. Just so our lives are a little bit
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`easier today, what I'd like you to be able to do is
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`use Exhibit 2208; and if it's okay with you, I'd like
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`to just use that one today so that we don't have to
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`reask the same question over and over again for the
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`other declaration.
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` A. Sure, that's fine with we. If for
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`some reason something I'm not thinking of comes to
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`18 mind, I'll let you know but --
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` Q. You under -- I want you to understand
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`that if you answer a question, every -- everyone is
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`going to be -- be under the belief that you understood
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`the question. Is that -- do you understand that?
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` Q. Thank you.
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` A. -- as far as I know, we can just talk
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`about one and that should cover everything.
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` Q. Okay. And I'll try to identify both.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 1319 Page 004 of 106
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`

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`VIDEOTAPED DEPOSITION OF PHILIP J. KOOPMAN, JR., Ph.D.
`CONDUCTED ON TUESDAY, JANUARY 13, 2015
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`13
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` A. I'll -- I'll assume you mean both.
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` Q. Yeah.
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` A. Okay, no problem.
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` Q. So if you could turn to Exhibit 2208,
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`5 which is also 2302, I have a couple of -- we're going
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`to be spending a lot of time in this document today,
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`obviously. But I'd to actually like to start by
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`looking at Paragraph 1.
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` A. Okay.
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` Q. The first Paragraph, it starts off saying
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`that you've been retained by the patent owner,
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`Rembrandt.
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` A. Yes.
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` Q. Do you see that?
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` Do you know when you were retained?
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` A. I looked it up, as I recall, it was
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`about three months ago.
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` Q. Do you recall who reached out to you?
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` A. Oh, boy. I don't remember. There --
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`there were several people involved. I don't
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`remember who this was, the first phone call was.
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` Q. I saw in your CV though it looks like you
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` Q. And before you started work on this case,
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`had you ever heard of this guy?
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` A. No.
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` Q. That guy being Mr. Bremer?
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` A. Mr. Bremer, right.
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` Q. Okay. Thank you.
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` So -- now you said you did some work this
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`week. Was that done in preparation for your
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`deposition today?
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` A. Yes.
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` Q. Can you tell us what you did to prepare
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`for your deposition?
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` A. I spent a couple hours reading
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`documents on Monday night, and then I had a meeting
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`yesterday afternoon, evening for a few hours.
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` Q. Was that meeting with Mr. Haight?
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` A. Yes.
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` Q. What documents did you review to prepare?
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` A. I looked at my declaration and went
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`back to look at the patents. I looked through some
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`pieces of some other things, you know, I don't --
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`if -- if the list is important, I can try to
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`do do some expert witness things, so it's not --
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`wasn't something that came completely out of the blue;
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`right?
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` A. It was out of the blue in terms of it
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`being a cold call.
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` Q. Yeah.
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` A. But you know the -- I -- I do not
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`publicly advertise by expert witness, but as a
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`professor university, most of us get these calls
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`all the time, so it was nothing unusual to be
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`called.
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` Q. Okay. And from the time that you've been
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`retained up until you -- this -- dec -- these two
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`declarations were prepared, about how much time did
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`you put into this case?
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` A. It was about 45 hours excluding this
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`week. So -- let me say it a different way. I -- I
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`billed for about 45 hours and -- and haven't done
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`this week yet.
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` Q. Have you ever talked to the inventor of
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`the '580 patent?
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` A. Not that I can recall.
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`remember, but it was mostly -- it was mostly the
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`documents -- some of the documents that are in my
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`appendix of materials. So I looked at the patents.
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`I looked at a couple pages of Dr. Goodman's -- I
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`think it was his deposition. I know I looked at
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`his declaration as well. I read my article again.
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`And I may have looked at some of the other stuff.
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`I don't recall the whole list.
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` Q. Do you remember what pages of
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`Dr. Goodman's deposition you looked at?
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` A. I -- I don't remember. I mean, I --
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`at one point I read the whole thing, just not this
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`week.
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` Q. Did you ever -- it's not listed here, but
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`I'm just wondering. Did you ever look at any of the
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`expert reports that were prepared in the litigation
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`that's going on between Rembrandt and Samsung?
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` A. I have not seen those -- well, let
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`19 me -- let me clarify that. I -- I think I looked
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`at a couple paragraphs from Dr. Akl's report,
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`A-K-L, which were summarizing our phone
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`conversation. But beyond that, I have not looked
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 1319 Page 005 of 106
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`

`
`VIDEOTAPED DEPOSITION OF PHILIP J. KOOPMAN, JR., Ph.D.
`CONDUCTED ON TUESDAY, JANUARY 13, 2015
`
`17
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`5 (Pages 17 to 20)
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`19
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`at any of that material.
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` Q. So you had a phone conversation with
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`Dr. Akl?
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` A. Yes, this is a few months ago. Well,
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`a few weeks ago. I don't remember exactly when. I
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`would have to look it up.
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` Q. When you spoke to him, did you understand
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`that he had been retained by Rembrandt in the
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`litigation?
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` A. Yes, that was my understanding.
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` Q. Who set that call up?
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` A. Again, there were -- there were -- the
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`litigation folks were involved. I don't know who
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`exactly told me, but -- but it was a phone call
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`that had been set up, you know, at the request of
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`litigation folks.
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` Q. In your work in this matter, who retained
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`you?
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` A. I was actually retained both by
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`litigation and by the IPR. The litigation folks
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`contacted me first, and I did a couple hours work
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` Could you turn, please, to Paragraph 5 of
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`your declaration. That's Exhibit 2208 and 2302.
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` A. I'm sorry, Paragraph 5?
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` Q. Yes.
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` A. Not page 5. Okay. Okay. Got it.
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` Q. In that paragraph -- I'm summarizing;
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`tell me if my summary is wrong. You talked about you
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`worked with some students on embedded networks, and
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`there's a reference to a controller area network.
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`Or -- testbeds?
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` A. Yes.
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` Q. Do you see that? Can you tell us what a
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`controller area network testbed is?
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` A. Controller area network is a protocol
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`widely used in automobiles and -- and many other
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`things from Bosch. And by testbed, I mean we
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`bought some personal computers and installed CAN
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`interface cards in them and used it for experiments
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`on embedded networks.
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` Q. Now, out of curiosity, why did you buy
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`this piece of equipment?
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` A. I do research in embedded networking,
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`for them, almost nothing, and then I switched over
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` Q. Uh-huh.
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` A. And I have not done any litigation
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`work since I started IPR.
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` Q. Do you remember who on the litigation
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`side you worked with?
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` A. I remember Mr. Engellenner's name.
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` Q. When was the last time you spoke to
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` A. He was on the phone when -- he was on
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`the phone yesterday to talk about Dr. Akl's
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`declaration, just to make sure I -- I remembered
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`the conversation.
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` Q. About how long were you on the phone with
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`Dr. -- Dr. -- excuse me. How -- about how long were
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`you on the phone with Mr. Engellenner yesterday?
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` A. Wow, I didn't time it. 30 minutes.
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`It was only a very short portion of the day.
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` Q. That was during the time you were working
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`with Mr. Haight to prepare for today?
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` A. Yes.
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` Q. Thanks.
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`and -- and back then did quite a bit of research in
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`it. And in fact, the customer for some of that
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`research was Bosch, who invented controller area
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`networking.
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` Q. So --
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` A. I -- I wanted to have a realistic way
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`to -- to do my experiments.
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` Q. Can you give us a brief technical
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`description of what a controller area network is.
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` A. It's -- it's a complicated subject, so
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`I can be very brief. This is a two-hour lecture,
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`which I don't think you want.
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` Q. You're right.
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` A. But the -- but -- we can go get the
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`PowerPoint off the web, but the -- the simple
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`version -- and if I'm not being deep enough, let me
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`know -- is that in -- in cars they wanted a
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`particular fairly standardized network protocol
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`that needed some specific characteristics, such as
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`prioritization, and so some folks came up with one
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`way to decide who gets to transmit next on the
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`network. It uses a technique called binary
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Exhibit 1319 Page 006 of 106
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`

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`VIDEOTAPED DEPOSITION OF PHILIP J. KOOPMAN, JR., Ph.D.
`CONDUCTED ON TUESDAY, JANUARY 13, 2015
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`countdown with bit dominance and -- to determine
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`which message goes next, based on priority. And
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`it's optimized for things that look like cars, in
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`terms of network speed, physical characteristics,
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`and maximum network length. And -- and there's --
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`there's a lot more, of course.
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` Q. Of course.
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` When you said prioritization, you used
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`that term, can you tell us what you mean by that.
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` A. By prioritization, in some networks,
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`what you want to do is make sure that high priority
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`12 messages are always transmitted before low priority
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`13 messages and CAN -- the binary countdown
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` A. Okay, oh, you want me to explain?
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` Q. Yes.
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` A. You know, actually my -- the paper I
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`wrote in the early '90s does a pretty good job of
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`it, but I mean, I could just read out of the paper.
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`I'm not quite sure what you're looking for.
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` Q. I don't have the paper. Just generally
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`speaking --
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` A. Okay.
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` Q. -- what's the difference?
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` A. Generally speaking -- of course there
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`are many differences. I'm not going to get them
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`all sitting here. But as an example, in a
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`characteristic of CAN is specifically intended to
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`14 master/slave system, you're going to expect that
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`provide that functionality.
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` Q. Is another word for this called
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`controller area network testbed a CAN bus?
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` A. I think there's a problem with the
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`question in that testbed is not part of the usual
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`phrase.
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` Q. Okay. Well, is another word for
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`controller area network a CAN bus?
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`there's a master, and the master queries the slave
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`nodes, and they're only going to respond when
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`they're queried, and they're going to send their
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`data back to the master. Whereas on CAN, at the
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`time in the '90s, CAN was often called
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`peer-to-peer. And the reason people would say that
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`is, there's no master, you can just send the data
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`wherever you want, whenever you want; although the
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` A. Some people call it that, yes.
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` Q. What about you?
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` A. Usually I call it CAN, because the N
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`stands for network and bus would be redundant.
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` Q. Okay.
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` A. But I've probably called it CAN bus at
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`some point, because so many people do.
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` Q. Okay. Well, I'll -- I'll -- I'll try to
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`just say controller area network, how about that?
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` A. I'm okay with either one. I will -- I
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`will know what you mean either way.
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` Q. Is a controller area network, does it
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`operate in a master/slave arrangement?
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` A. It is not typically considered
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`15 master/slave. It's considered binary countdown.
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` Q. Do you have an understandsing as to what
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`the difference is between a master/slave network and a
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`whenever is conditioned by the fact there's this
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`prioritization mechanism that arbitrates if there
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`are multiple concurrent transmitters.
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` Q. So I'm curious why you put Paragraph 5 in
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`your declaration. Can you just give me an explanation
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`for that.
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` (Witness reviews document.)
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` A. Oh, I was explaining about some of the
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`experience I've had doing networking. That's one
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`of my experiences, and in other paragraphs I
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`explained other of my experiences.
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` Q. Okay. Thank you.
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` In -- in reviewing your declaration and
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`some of the documents that are in this case, I've seen
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`reference to media -- media access controller or MAC.
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`Can you tell me what your understanding of a MAC is?
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` A. In that context -- that acronym M-A-C
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`binary countdown network like those used in controller
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`18 means different things, but in that context, it's
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`area networks?
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` A. If we're going in generalalities, like
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`how I would teach my course, yes.
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` Q. Please.
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`19 media access control. And, again, at the very high
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`level, the idea is that you have a shared wire, you
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`have multiple transmitters who potentially may want
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`to transmit at the same time. They have data to
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 1319 Page 007 of 106
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`

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`VIDEOTAPED DEPOSITION OF PHILIP J. KOOPMAN, JR., Ph.D.
`CONDUCTED ON TUESDAY, JANUARY 13, 2015
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`send at the same time, I should say. And someone
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`has to go next. And the MAC -- MAC as a concept is
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`the concept of figuring out who gets to go next.
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`And we use the word protocol associated with that.
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`The protocol is the procedure for figuring out who
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`goes next. And again, that's very high level, very
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`simplified.
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` Q. I'm going to provide you a copy of an
`
`exhibit that's already been marked. Actually, there's
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`two exhibits. One is Exhibit 1218.
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` MR. HAIGHT: Thank you.
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` Q. And the other is Exhibit 1317.
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` (Exhibits 1218 and 1317 were
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`entered for reference.)
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` A. Thank you. These both look the same
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`to me.
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` Q. Thanks. In that case, if they weren't,
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`that would be my fault.
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` A. Okay.
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` Q. I'm going to work off of Exhibit 1218,
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`but I wanted you to have 13, the other one there, just
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`in case.
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` Q. So for lack of a better word, what I
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`think of this is as the article, and maybe we'll call
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`the other one your paper. How's that?
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` A. Sure, if we want to call them that.
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`But the paper came first.
` Q. Yeah.
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` A. Okay.
` Q. I understand that.
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` A. Okay. Okay. That's fine.
` Q. I will be helplessly confused if we call
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`them the same thing.
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` A. Okay. No problem.
` Q. So -- so before we -- we got the exhibit
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`out, and we had that little discussion, we were
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`talking and you were -- you were providing your
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`understanding of what a media access controller is?
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` A. Uh-huh.
` Q. And you gave an -- an explanation, and on
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`the -- in the first page of your article, which is
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`page 46 of the magazine.
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` A. Uh-huh.
` Q. There's a statement that says, "At the
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` A. I understand.
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` Q. Now, there's a declaration attached to
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`this from a librarian, but if you turn to the third
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`page of the exhibit there's an -- there's an article
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`on the Embedded Systems Programming journal. Within
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`that there's an article written by Bhargav Upender and
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`Philip Koopman.
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` A. Right.
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` Q. The -- the author listed as Philip
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`Koopman, I assume that's you?
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` A. That is me. And I recognize this
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`article as the one I did way back then.
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` Q. I was asking you about media access
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`controller.
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` A. Uh-huh.
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` Q. And on page 46 of your article --
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` A. Uh-huh.
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` Q. -- and we should probably try to come up
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`with a common parlance, because I know that in your
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`declaration you attached another version of this
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`article.
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` A. Right.
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`heart of the LAN is the media access protocol."
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` A. I'm sorry, I didn't -- I didn't find
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`it yet.
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` Q. It's all the way at the bottom of the
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`first column.
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` A. I got it. Uh-huh.
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` Q. The article states, "At the heart of the
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`LAN is the media access protocol, which picks the next
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`transmitter for access to the shared" -- I apologize,
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`I can't read that word -- "work medium, typically a
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`wire."
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` A. Yeah.
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` Q. I think network medium, "shared network
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`14 medium, typically a wire, fiber or RF frequency."
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` A. Yes, I do.
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` Q. I'm curious, is -- is that statement
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`about a media access protocol, is that synonymous, so
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`to speak, with the definition you gave us for a media
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`access controller?
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` A. I think it's consistent and, at this
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`point, I have to point out these are not
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 1319 Page 008 of 106
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`

`
`VIDEOTAPED DEPOSITION OF PHILIP J. KOOPMAN, JR., Ph.D.
`CONDUCTED ON TUESDAY, JANUARY 13, 2015
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`necessarily exactly my words. And if you want to
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`know what I said, we have to go back to the paper
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`rather than the article.
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` Q. Well, we're going to be talking about the
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`paper.
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` A. I -- it's consistent, but these are
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`not necessarily my words. I would want to refer to
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`the paper to tell you what I said, instead of what
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`the editor changed it to.
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` Q. Well, let me ask you this, when the --
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`when the editor made changes, did you get a chance to
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`sign off on those changes?
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` A. No.
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` Q. Why not?
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` A. That's just not how it worked. It's a
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`16 magazine. It's not a scholarly journal.
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`exhibit that's been previously marked as Exhibit 2209,
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`and I don't have a copy of it, but it was also
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`submitted as Exhibit 2303.
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` MR. HAIGHT: Counsel, you
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`referred to this as the article. I assume this is
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`what you meant to be the paper?
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` MR. MILLER: Yes. I told you I
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`was going to get confused.
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` Q. Do you have your paper in front of you?
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` A. Yes, I do.
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` I want to clarify a previous answer.
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`It might have been the case that Bhargav saw a
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`draft of this. I know I didn't see it, but I was
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`second author. But at any rate, I never sat down
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`and -- and vetted the changes.
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` Q. Okay. And you also never told the
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` Q. Well, did he make any changes to the
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`17 magazine, Embedded Systems, that there was a problem
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`article that you disagreed with?
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` A. He made some changes that may have --
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`that I know for sure changed wording. And in --
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`you know -- in some cases, it -- it depends on the
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`with anything in it?
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` A. I -- I -- I -- you know, after it was
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`published, I don't think I sat down and read it
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`critically to do that, but the answer to your
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`question is I never went back and told -- told them
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`the editor made whatever changes they made to this
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`article, do you recall whether or not you told the
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`editor you didn't agree with what he did?
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` A. I don't think I saw it until it got
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`published, and there was no point -- I -- I did not
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`review this article in detail with that in mind.
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` Q. Do you know who the editor was?
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` A. I'd have to go back to the front. Let
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`13 me see if it's in here. There were several editors
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`17 might have been Lindsey Vereen or maybe someone
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`else, I'm not really -- I don't -- I don't recall.
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` Q. Why don't I give you a copy of your
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`article.
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` A. Thank you.
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` Q. Providing a copy to the witness of an
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`situation. So if you're asking me if these are my
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`words, like I want to go see what I wrote. But I
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`don't see anything in here that I disagree with. I
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` Q. Okay. Well, anyway, going back to a
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`think it's generally consistent with what I said.
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`in your article -- this is from the magazine --
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` A. Uh-huh.
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` Q. -- the media access protocol, you don't
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`disagree with what is stated there; do you?
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` A. The -- the sentence we just -- let me
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`read it again.
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` (Witness reviews document.)
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` A. I think saying at the heart of the LAN
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`-- LAN is a little colorful, but I don't disagree
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`with the point that's being made there. I don't --
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`I don't see anything technically incorrect about
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`that sentence.
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` Q. On page 56 -- 56 of your article --
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`starting -- and -- and we're probably going to be
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`talking about this paragraph a fair amount today, but
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`in the last column all the way at the bottom, the last
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`paragraph that starts with -- I'll just read it --
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`"for our embedded systems we have found that CSMA/CA,
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`particularly RCSMA, is a good choice. While your
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Exhibit 1319 Page 009 of 106
`
`

`
`VIDEOTAPED DEPOSITION OF PHILIP J. KOOPMAN, JR., Ph.D.
`CONDUCTED ON TUESDAY, JANUARY 13, 2015
`
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