Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
`
` 1
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` 1 ROUGH DRAFT - Goodman
`
` 2 ----------------------------------------------
` REALTIME AND INTERACTIVE REALTIME
` 3 TRANSCRIPT ROUGH DRAFT DISCLAIMER
` ----------------------------------------------
` 4 IMPORTANT NOTICE:
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` 5 ----------------------------------------------
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` transcript upon its completion.
` 14 Case: Rembrandt vs. Samsung
` Date: November 19, 2014
` 15 REPORTER'S NOTE:
`
` 16 Since this deposition has been realtimed and
` is in rough draft form, please be aware that
` 17 there may be a discrepancy regarding page and
` line number when comparing the realtime
` 18 screen, the rough draft, rough draft disk,
` and the final transcript.
` 19
` Also please be aware that the realtime screen
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` may contain untranslated steno, reporter's
` 21 notes in double parenthesis, misspelled
` proper names, incorrect or missing Q/A
` 22 symbols or punctuation, and/or nonsensical
` English word combinations. All such entries
` 23 will be correct on the final certified
` transcript.
` 24
` Court Reporter's Name: Michelle A. Cox
` 25 Firm Name: Sound Depo
`
`

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` 2
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` 1 ROUGH DRAFT - Goodman
`
` 2 THE VIDEOGRAPHER: Good morning. Today's
`
` 3 November 19, 2014. The time is approximately
`
` 4 9:11. This is the continuing deposition of
`
`Page 1
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
` 5 Dr. David Goodman.
`
` 6 We are on the record at this time.
`
` 7 If you want to re-swear or reaffirm the
`
` 8 witness, please.
`
` 9 DAVID GOOMAN, called as a witness, having been duly
`
` 10 sworn by a Notary Public, was examined and
`
` 11 testified as follows:
`
` 12 EXAMINATION BY
`
` 13 MR. ENGER:
`
` 14 Q Dr. Goodman, could i direct your attention
`
` 15 to Exhibit 2 OF your non-infringement report.
`
` 16 A Which is my copy?
`
` 17 Okay. Sorry.
`
` 18 Q Paragraph 51, please. Paragraph 51 of
`
` 19 your non-infringement report contains the
`
` 20 results of what you call your first test; is
`
` 21 that fair?
`
` 22 A Yes.
`
` 23 Q And during the first test, each of the
`
` 24 Samsung S3 and Note 3 devices were connected to
`
` 25 each of an EDR enabled Bluetooth headset and a
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`

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` 3
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` 1 ROUGH DRAFT - Goodman
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` 2 non-EDR enabled Bluetooth headset and the power
`
` 3 usage was measured over the course of a
`
` 4 ten-minute cellular phone call, right?
`
` 5 A Yes.
`
` 6 Q The phone was using both Bluetooth and
`
` 7 cellular, correct?
`
` 8 A Yes. Bluetooth -- yes that's correct.
`
` 9 Q Was -- for the cellular parts was it using
`
` 10 three 3G or 4G?
`
`Page 2
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
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` 11 MR. MILLER: Objection; form.
`
` 12 A I don't know.
`
` 13 Q And it was also using Wi-Fi?
`
` 14 A The Wi-Fi was on. I don't know that there
`
` 15 was any Wi-Fi communication going on.
`
` 16 Q So there could have been Wi-Fi
`
` 17 communication, there could not have been
`
` 18 communication you just don't know?
`
` 19 A I -- that's correct.
`
` 20 Q How was it decided to perform a ten-minute
`
` 21 test?
`
` 22 A I felt that the power drain wouldn't
`
` 23 change from more than -- if the test went on
`
` 24 longer than ten minutes. They were suggesting
`
` 25 a much longer test, and I felt that wasn't
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`

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` 1 ROUGH DRAFT - Goodman
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` 2 necessary, that -- just my own professional
`
` 3 judgment, that ten minutes would be sufficient
`
` 4 to find out information we needed. We wanted
`
` 5 to find or we wanted to learn, which was what
`
` 6 would be the difference in the power
`
` 7 consumption with these two different headsets.
`
` 8 Q Now, does ten minutes of operation
`
` 9 represent the normal use of a cell phone during
`
` 10 battery charges?
`
` 11 A I don't have any information on the normal
`
` 12 use of phone. It's probably my use of a phone.
`
` 13 I might have a few phone calls two-minute phone
`
` 14 calls in the day and charge battery at night,
`
` 15 but that's just me.
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`Page 3
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
` 16 Q Most people don't charge their cell phone
`
` 17 every ten minutes?
`
` 18 A No. Maybe some people talking for longer
`
` 19 than ten minutes and some people don't talk at
`
` 20 all during the day. Me, I just have a brief
`
` 21 couple of phone calls.
`
` 22 Q How was the power usage measured in the
`
` 23 power testing?
`
` 24 A As I -- sitting here I don't recall I read
`
` 25 the specifications of a power measurement
`
`

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` 1 ROUGH DRAFT - Goodman
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` 2 device that was used by NTS. So I saw -- I
`
` 3 think I was directed to a website, but I -- I'm
`
` 4 totally blank, blank as to a company that
`
` 5 produced it. The one thing that did stick
`
` 6 to -- in my mind was very meticulous
`
` 7 instructions about how to connect the powerless
`
` 8 device to the telephone because it's a little
`
` 9 tricky. You have your battery there and the
`
` 10 battery is being drained of power, or power is
`
` 11 being consumed from to the battery. And
`
` 12 somehow you have to take the battery out and
`
` 13 put something else in and connect it in.
`
` 14 So they gave meticulous instructions on
`
` 15 how to do that.
`
` 16 Q You didn't cite the website that tells you
`
` 17 how to use the equipment in your report, did
`
` 18 you?
`
` 19 A I did not.
`
` 20 Q You said you do not know what equipment
`
` 21 was used to perform the power testing?
`Page 4
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
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` 22 MR. MILLER: Objection; form.
`
` 23 A I don't remember.
`
` 24 Q Was the battery removed to test the power?
`
` 25 A I don't remember. I don't remember.
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` 2 Q Can you describe the configuration of the
`
` 3 power meter relative to the device under test?
`
` 4 A As I recall the power meter was a lot
`
` 5 bigger than device under test. And it was
`
` 6 connected by some LEEDS or wires to the device.
`
` 7 That's as much as I remember.
`
` 8 Q Do you recall if the power meter was
`
` 9 connected in series or in parallel with the
`
` 10 battery?
`
` 11 A I don't -- I don't recall.
`
` 12 Q Was the battery the only source of power
`
` 13 for S3 and Note3 devices under test?
`
` 14 A Yes.
`
` 15 Q Were the S3 and the Note devices connected
`
` 16 to any other equipment during the test?
`
` 17 A Other than what's described here in the
`
` 18 power meter?
`
` 19 Q Yes, sir.
`
` 20 A Not to my knowledge.
`
` 21 Q There's nothing connected via the USB
`
` 22 port?
`
` 23 A Not to my knowledge.
`
` 24 Q How often were measurements made during
`
` 25 your tests?
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`

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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
` 1 ROUGH DRAFT - Goodman
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` 2 A I don't remember. I think it's about ten
`
` 3 times a second, just looking at these chart.
`
` 4 Q So about every 100 hundred milliseconds
`
` 5 you took a sample?
`
` 6 A I believe that's how the power meter was
`
` 7 working.
`
` 8 Q How was it decided to take measurement
`
` 9 every hundred millimeter second?
`
` 10 A I think NTS decided to do that. It seem
`
` 11 odd okay.
`
` 12 Q What's the typical duration of a basic
`
` 13 Bluetooth packet?
`
` 14 A I'm sorry, I don't remember. I'd have to
`
` 15 look it up in my notes, in the Bluetooth
`
` 16 specification. I remember some of the time
`
` 17 scales in Bluetooth, but I can't give you an
`
` 18 answer now.
`
` 19 Q If the Bluetooth packet duration is less
`
` 20 than the 100 milliseconds sampling time you
`
` 21 used for your testing, how do you know you're
`
` 22 measuring the power consumed during the
`
` 23 transmission of each packet?
`
` 24 A I suggested these tests in order to find
`
` 25 out how much power is being consumed during,
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`

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` 1 ROUGH DRAFT - Goodman
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` 2 what I consider, a normal use of a Bluetooth --
`
` 3 the Bluetooth capability in Samsung devices.
`
` 4 And I think that these power measurements
`
` 5 convey that.
`
` 6 Q You remember my question?
`Page 6
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
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` 7 A Your question was -- well, if the
`
` 8 packet -- so, yeah your question is that I'm
`
` 9 measuring -- somebody measuring over 100
`
` 10 milliseconds and the Bluetooth packet is --
`
` 11 that one packet is the transmitted in less than
`
` 12 100 milliseconds, and how do I know how much
`
` 13 power is being consumed by Bluetooth is that
`
` 14 it?
`
` 15 Q Yes.
`
` 16 A I don't remember the packet size in
`
` 17 Bluetooth, but I remember your question.
`
` 18 My interest was how much power. I wasn't
`
` 19 particularly interested in how much power was
`
` 20 being consumed in one Bluetooth packet. I was
`
` 21 interested in how much power, on average, is
`
` 22 consumed in the normal use of Bluetooth EDR
`
` 23 device compared with Bluetooth Basic Rate
`
` 24 device.
`
` 25 Q Do you agree your testing would not
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`

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` 1 ROUGH DRAFT - Goodman
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` 2 measure power consumed during a Bluetooth EDR
`
` 3 packet?
`
` 4 MR. MILLER: Objection; form.
`
` 5 A During one Bluetooth packet EDR?
`
` 6 Q Yes, sir.
`
` 7 A I don't think that information is here.
`
` 8 Q And you're testing doesn't reveal the
`
` 9 amount of power consumed during one Basic Rate
`
` 10 packet?
`
` 11 A Yeah. The same answer, yes.
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`Page 7
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
` 12 Q What exactly is being measured every 100
`
` 13 milliseconds?
`
` 14 A It's the power. People use the term
`
` 15 consumption. It's the power consumed in watts
`
` 16 during that period. The power exerted in
`
` 17 watts.
`
` 18 Q Did you measure the voltage in milliwatts?
`
` 19 A I haven't seen any voltage.
`
` 20 Q Did you measure the current in
`
` 21 milliseconds?
`
` 22 A I don't recall what happens inside this
`
` 23 machine, but the device that's used reports the
`
` 24 power, and we know that the power is related to
`
` 25 voltage and current. And I don't recall
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` 1 ROUGH DRAFT - Goodman
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` 2 whether there are separate measurements of
`
` 3 those two that are then multiplied together.
`
` 4 Q Were you measuring average power or
`
` 5 instantaneous power?
`
` 6 A I think it was averaged over -- at least
`
` 7 what was reported was averaged over, I think,
`
` 8 100 milliseconds.
`
` 9 Q You said that Exhibit 7, 8, 15 and 16
`
` 10 measure the results of your first test, fair?
`
` 11 A It would says that, yes.
`
` 12 Q And that's accurate, to the best of your
`
` 13 knowledge?
`
` 14 A To the best of my knowledge, it's
`
` 15 certainly true.
`
` 16 Q And I think it's fair to say the best of
`
` 17 your knowledge applies to every question I ask
`Page 8
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
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` 18 today.
`
` 19 A Thank you. I don't have to qualify it.
`
` 20 Q And the chart on Page 21 of your reports
`
` 21 shows the results of the first test?
`
` 22 A Yes.
`
` 23 Q The chart on Page 21 also shows the
`
` 24 results of your first test, right?
`
` 25 MR. MILLER: Objection; form.
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`

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` 1 ROUGH DRAFT - Goodman
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` 2 A Sorry. You asked.
`
` 3 Q I'm asking if the chart on Page 21 shows
`
` 4 the results your first test?
`
` 5 A I said yes.
`
` 6 Q The plot on Page 22 shows the results of
`
` 7 your first test?
`
` 8 A You didn't say that first time.
`
` 9 Q Does the plot on Page 22 also show the
`
` 10 results of your first test?
`
` 11 A Yes. The several plots there.
`
` 12 Q Watts are on the Y axis?
`
` 13 A Correct.
`
` 14 Q Time is on the X axis?
`
` 15 A Yes.
`
` 16 Q And do you know if the watts that are
`
` 17 being plotted here were actually measured by
`
` 18 the power meter or were they calculated by
`
` 19 multiplying the current times the voltage?
`
` 20 A I don't know. That's what ended up on the
`
` 21 spreadsheet.
`
` 22 Q What we see here in the plots on Page 22
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`Page 9
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
` 23 the results of one ten-minute test for each of
`
` 24 the S3 and the Note3, correct?
`
` 25 A Would you repeat the question, the results
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` 1 ROUGH DRAFT - Goodman
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` 2 of?
`
` 3 Q If you did one test for the S3, and that's
`
` 4 shown at top, and one for the Note3 shown at
`
` 5 the bottom?
`
` 6 MR. MILLER: Objection; form.
`
` 7 Please let me object.
`
` 8 Objection; form.
`
` 9 THE WITNESS: I beg your pardon.
`
` 10 Q You can answer the question now.
`
` 11 A I might say there were two tests, one with
`
` 12 with the Basic Rate device and the other with
`
` 13 the EDR device.
`
` 14 Q So there were a total of 4 10-minute
`
` 15 samples during which you collected data, two
`
` 16 for the S3 and two for the Note 3?
`
` 17 A Yes.
`
` 18 Q Were there other ten-minute samples for
`
` 19 the S3 and the Note3 that did not find their
`
` 20 way in your report?
`
` 21 A I don't have any knowledge of it.
`
` 22 Q Is it typical to only do one sample per
`
` 23 test?
`
` 24 A Would you explain the question.
`
` 25 Q What's the sample size for your power
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`

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` 1 ROUGH DRAFT - Goodman
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` 2 testing under the "first test"?
`Page 10
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
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` 3 A Would you explain what do you mean by
`
` 4 "sample size"?
`
` 5 Q I think we established that you ran one
`
` 6 Basic Rate test and one ten-minute EDR test for
`
` 7 the S3, right?
`
` 8 A That's correct.
`
` 9 Q Why didn't you run, for example, five
`
` 10 Basic Rate tests for to the S3 and five Basic
`
` 11 Rate tests -- five EDR tests for the S3?
`
` 12 A In my judgment, 10 -- 10 minutes si
`
` 13 sufficient. I mean, you could say there were
`
` 14 10 1-minute tests each time or something. I
`
` 15 could have said that.
`
` 16 I just judged that that would be
`
` 17 sufficient to give an indication of how much
`
` 18 power is used when communicating in Basic Rate
`
` 19 or EDR and be table to compare them.
`
` 20 Q When you're doing your research, do you
`
` 21 typically just have one sample to prove your
`
` 22 opinions, or do you typically use multiple
`
` 23 samples?
`
` 24 A I'd like to qualify my answer for my
`
` 25 colleagues who might want to hear this. I
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` 1 ROUGH DRAFT - Goodman
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` 2 don't conduct research to prove my opinions.
`
` 3 Is conduct research to find out what basic
`
` 4 phenomena exist. Then I form opinions based on
`
` 5 what I learned from experiments and I would say
`
` 6 the same thing here, you know I formed an
`
` 7 opinion based on the measurements rather than
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
` 8 starting with an opinion and you know there are
`
` 9 predictions sometimes and sometimes predictions
`
` 10 are confirmed sometimes predictions are
`
` 11 disconfirmed.
`
` 12 Q I guess I want to know, in your research,
`
` 13 do you typically perform experiments with only
`
` 14 one sample or do you typically use multiple
`
` 15 samples?
`
` 16 MR. MILLER: Objection; form.
`
` 17 A The experiments are performed. I think
`
` 18 about have an adequate sample size to find out
`
` 19 what what I'm trying to learn.
`
` 20 So, again, I could have -- I guess I could
`
` 21 have run and. Maybe it was suggested that we
`
` 22 run a 50-minute test. So would that be five
`
` 23 ten-minute samples? In my mind that might be
`
` 24 10 5-minute samples a ten-minute test might be
`
` 25 2-minute samples. Or we have 6,000 samples
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`

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` 15
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` 1 ROUGH DRAFT - Goodman
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` 2 here of power measurements. And I think the
`
` 3 6,000 samples are adequate to show what happens
`
` 4 when a device is communicating with Bluetooth
`
` 5 EDR compared to when it's communicating with
`
` 6 Basic Rate.
`
` 7 Q Let's stick with the S3 test.
`
` 8 This ten-minute sample size showed that
`
` 9 EDR uses more power than Basic Rate, correct?
`
` 10 A I don't think it shows that. I think it
`
` 11 shows that when the device was communicating
`
` 12 with EDR, the average power was higher averaged
`
` 13 over ten minutes was higher than the average --
`Page 12
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
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` 14 than the device consumed -- than the power
`
` 15 consumed by the device when it was
`
` 16 communicating with Basic Rate.
`
` 17 And I suggested that we learn that because
`
` 18 I think that's really what's of interest to a
`
` 19 judge and jury trying to understand the issues
`
` 20 in this case.
`
` 21 Q If you had run another ten-minute test for
`
` 22 the S3, do you think that EDR would have
`
` 23 consumed more power than Basic Rate?
`
` 24 A Yes.
`
` 25 Q But you don't know?
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`

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` 1 ROUGH DRAFT - Goodman
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` 2 A Right.
`
` 3 You know, if I flip a coin 20 times, I
`
` 4 don't know if it's going to come up heads 19
`
` 5 times, but I've had enough experience flipping
`
` 6 coins that it's going to come up heads 19 times
`
` 7 or totals 19 times.
`
` 8 I think it would be somewhere closer to
`
` 9 five. Maybe not exactly, or somewhere closer
`
` 10 to ten times.
`
` 11 So, of course, I don't know what would
`
` 12 have happened if I run it for 16 hours which is
`
` 13 what Dr. Morrow did.
`
` 14 Q Did you review the raw data that NTS
`
` 15 gathered?
`
` 16 A Yes.
`
` 17 Q Would you agree that an 20-minute test is
`
` 18 more reliable than a ten-minute test?
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`Page 13
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
` 19 A Yes.
`
` 20 Q Would you agree that a 4-hour test is more
`
` 21 reliable than a ten-minute test?
`
` 22 A A four hour test?
`
` 23 I don't think someone would be interested
`
` 24 in a four hour phone call. I think maybe a
`
` 25 20-minute phone call that a lot of us have
`
`

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` 17
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` 1 ROUGH DRAFT - Goodman
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` 2 experienced or engage, I can't remember a
`
` 3 four-hour phone calls with my cell phone.
`
` 4 Q Do you think a four hour test is more
`
` 5 reliable than a ten minute test?
`
` 6 A I don't think it's a reliable indication
`
` 7 of the information that would be relevant to
`
` 8 this case.
`
` 9 Q And you don't think a 16 hour test would
`
` 10 be more reliable than a ten-minute test either?
`
` 11 MR. MILLER: Objection; form.
`
` 12 A I don't think -- I don't think I could
`
` 13 have had a 16 hour conversation without the
`
` 14 battery running down. But I don't think a 16
`
` 15 minute test would be an indication of something
`
` 16 that would interest or that would help a judge
`
` 17 and jury understand of the phenomena that are
`
` 18 relevant to this case.
`
` 19 Q Yesterday we were looking at these plots,
`
` 20 and I think you told me the power spikes were
`
` 21 not attributable to Bluetooth; is that right?
`
` 22 A You suggested that. I think your
`
` 23 suggestion was plausible, yes.
`
` 24 Q Well, let's be clear on this.
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
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` 25 Are the power spikes due to Bluetooth?
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`

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` 18
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` 1 ROUGH DRAFT - Goodman
`
` 2 A I doubt it.
`
` 3 Q They couldn't be due to Bluetooth?
`
` 4 A I couldn't imagine they could.
`
` 5 Q They were due to something other than
`
` 6 Bluetooth?
`
` 7 A As far as I know, yes.
`
` 8 Q And in a different ten minute test, you
`
` 9 might have different power spikes?
`
` 10 A I would expect that.
`
` 11 Q And in a different ten minute test the
`
` 12 power spikes might have occurred during the
`
` 13 Basic Rate and not during the EDR testing?
`
` 14 A Could be.
`
` 15 Can I see your color chart again, because
`
` 16 I can't separate out the power spikes on mine.
`
` 17 Yeah, that's fine. I won't read your notes. I
`
` 18 can't read your notes. I can't read your
`
` 19 notes, in fact.
`
` 20 Yeah, so there were smaller spikes during
`
` 21 the Basic Rate then those big larger ones.
`
` 22 I guess red is EDR; is that right?
`
` 23 Q Yes.
`
` 24 And in a different ten-minute sample, that
`
` 25 could have been large spikes for Basic Rate and
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`

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` 1 ROUGH DRAFT - Goodman
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` 2 small spikes for EDR?
`
` 3 A Could be, or no spikes at all.
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
` 4 Q And these spikes wil greatly affect the
`
` 5 average power that was consumed during the
`
` 6 test?
`
` 7 A The spikes would affect the average power.
`
` 8 They are fairly brief. If I had a spreadsheet
`
` 9 I would do a calculation.
`
` 10 Q Although they are fairly brief, they are
`
` 11 also very pronounced?
`
` 12 A They're about four and a half times
`
` 13 bigger. So the power, when it didn't happen.
`
` 14 So, yeah, the averages that I report certainly
`
` 15 are influenced by those spikes.
`
` 16 Q In Paragraph 53, you state that the S3
`
` 17 consumed more power with the EDR enabled
`
` 18 headset than what the Basic Rate headset the
`
` 19 majority of the time.
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` 20 Is that the summary of your first test
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` 21 results?
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` 22 A Yes, I think you're referring to Paragraph
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` 23 52, I believe.
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` 24 A Yes.
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` 25 Q Yes.
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` 20
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` 1 ROUGH DRAFT - Goodman
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` 2 A I think that's a summary essentially
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` 3 describes the charts that you and I were
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` 4 discussion a minute ago.
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` 5 Q But it's not your opinion that EDR by
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` 6 itself uses more power than Basic Rate by
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` 7 itself?
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` 8 A The only information that I can recall was
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` 9 in those Intel charts that we look at
`Page 16
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`REMBRANDT EXHIBIT 2310
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`Goodman, David 11-19-14 ROUGH Transcript (CONF).txt
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` 10 yesterday. I don't know if I'm allowed to
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` 11 discuss it with Mr. Goodwin here.
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` 12 Q Don't get into the specifics. I think
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` 13 we'll be okay.
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` 14 A Because I know that's a sensitive
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` 15 information.
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` 16 MR. MILLER: Can you answer his question
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` 17 without getting into the details?
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` 18 THE WITNESS: No. No, I think I have to.
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` 19 MR. MILLER: So I think we're going to
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` 20 have to go back on the confidential record.
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` 21 MR. ENGER: Okay.
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` 22 (Wherein Mr. Goodwin leaves the conference
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` 23 room.)
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` 24
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