CONFIDENTIAL
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`WAVEMARKET, INC. d/b/a
`LOCATION LABS,
`Petitioner,
`
`)
`)
`)
`)
`vs.
`)
`LOCATIONET SYSTEMS, LTD.,
`)
`Patent owner.
`______________________________)
`
`No. IPR2014-00920
`
`CONFIDENTIAL TESTIMONY
`VIDEOTAPED DEPOSITION OF SCOTT HOTES, PH.D.
`WEDNESDAY, FEBRUARY 18, 2015
`
`PAGES 1 - 249
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`WAVEMARKET, INC. d/b/a
`LOCATION LABS,
`Petitioner,
`
`)
`)
`)
`)
`vs.
`)
`LOCATIONET SYSTEMS, LTD.,
`)
`Patent owner.
`______________________________)
`
`No. IPR2014-00920
`
`CONFIDENTIAL TESTIMONY
`VIDEOTAPED DEPOSITION OF SCOTT HOTES, PH.D.
`WEDNESDAY, FEBRUARY 18, 2015
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`PAGES 1 - 249
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`CONFIDENTIAL
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`Videotaped Deposition of SCOTT HOTES, PH.D. taken
`on behalf of Patent Owner, at DENTONS US, LLP, 525
`Market Street, 26th Floor, San Francisco, California,
`commencing at 9:32 a.m., Wednesday, February 18, 2015,
`before Kelli Combs, CSR 7705.
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`CONFIDENTIAL
`APPEARANCE OF COUNSEL:
`
`FOR PETITIONER:
`PEPPER HAMILTON
`BY:
`ANDY H. CHAN, ESQ.
`333 Twin Dolphin Drive, Suite 400
`Redwood Shores, California 94065
`(650) 802-3600
`chana@pepperlaw.com
`
`FOR PATENT:
`DENTONS US, LLP
`BY:
`SCOTT W. CUMMINGS, ESQ
`1301 K Street NW
`Washington, DC 20005
`(202) 408-9217
`scott.cummings@dentons.com
`
`Also present: Frank Claire, Videographer
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`CONFIDENTIAL
`I N D E X
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`February 18, 2015
`
`SCOTT HOTES, PH.D.
`EXAMINATION
`
`(BY MR. CHAN)
`
`PAGE
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`7
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`QUESTIONS NOT ANSWERED:
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`CONFIDENTIAL
`EXHIBIT INDEX
`
`PREVIOUSLY MARKED EXHIBITS
`US Patent No. 6,321,092
`Exhibit 1105 -
`US Patent No. 6,002,936
`Exhibit 1107 -
`Declaration of Scott Hotes, Ph.D.
`Exhibit 1116 -
`No Exhibit No. - Petition for Inter Partes Review of
`US Patent Number 6,771,970
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`
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`Wednesday, February 18, 2015, San Francisco, California
`
`CONFIDENTIAL
`
`--o0o--
`
`THE VIDEOGRAPHER:
`
`Good morning.
`
`We're on
`
`the record at 9:32 a.m. on February 18th, 2015.
`
`9:32:49AM
`
`This is the video recorded deposition of Dr. Scott
`
`Hotes.
`
`My name Frank Claire, here with our court
`
`reporter, Kelli Combs.
`
`We're here from Veritext
`
`Legal Solutions at the request of counsel for the
`
`patent owner.
`
`9:33:12AM
`
`This deposition is being held at Dentons
`
`in San Francisco.
`
`The caption of this case is
`
`WaveMarket, Inc., doing business as Location Labs
`
`versus LocatioNet Systems, Ltd., Case number
`
`IPR2014-00920.
`
`9:33:31AM
`
`Please note that audio and video recording
`
`will take place unless all parties agree to go off
`
`the record.
`
`Microphones are sensitive and may pick up
`
`whispers, private conversations and cellular
`
`9:33:45AM
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`interference.
`
`I'm not related to any party in this
`
`action, nor am I financially interested in the
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`outcome in any way.
`
`Would counsel please identify yourselves
`
`and state whom you represent.
`
`9:33:58AM
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`MR. CHAN:
`
`I'm Andy Chan of Pepper
`
`9:34:00AM
`
`Hamilton representing patent owner, LocatioNet
`
`Systems.
`
`MR. CUMMINGS:
`
`Scott Cummings with Dentons
`
`representing the Petetioner, WaveMarket, doing
`
`9:34:08AM
`
`business as Location Labs.
`
`THE VIDEOGRAPHER:
`
`Thank you.
`
`The court reporter will administer the
`
`oath and examination may begin.
`
`SCOTT HOTES, PH.D.
`
`9:34:16AM
`
`after having been duly sworn, testified as follows:
`
`---o0o---
`
`EXAMINATION
`
`BY MR. CHAN:
`
`9:34:26AM
`
`Q
`
`A
`
`Q
`
`Good morning, Dr. Hotes.
`
`Good morning.
`
`Can you please state your name and address
`
`for the record.
`
`A
`
`Yes.
`
`Scott Hotes, 505 Cragmont Avenue,
`
`9:34:31AM
`
`Berkeley, California 94709.
`
`Q
`
`And do you understand that you'll be
`
`testifying today as if you were in a court of law?
`
`A
`
`Q
`
`Yes.
`
`And have you been deposed before?
`
`9:34:46AM
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`9:34:48AM
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`Yes.
`
`How many times?
`
`Just once.
`
`And can you describe to me what the
`
`A
`
`Q
`
`A
`
`Q
`
`circumstances of that deposition was?
`
`9:34:53AM
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`Labs.
`
`case?
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`exactly.
`
`Q
`
`A
`
`Q
`
`A
`
`It was a patent case relating to Location
`
`And who was the opposing party in that
`
`I don't recall.
`
`And when did that occur?
`
`It was early part of 2014.
`
`I don't recall
`
`9:35:08AM
`
`And was that a district court case?
`
`I don't know.
`
`I don't recall.
`
`9:35:27AM
`
`Was that a case at the patent office?
`
`You know, I don't remember exactly the --
`
`as far as -- I don't know.
`
`I don't know the answer
`
`to that.
`
`Q
`
`Do you recall what technology was involved
`
`9:35:44AM
`
`in that case?
`
`A
`
`Q
`
`A
`
`Yes.
`
`Yes, I do.
`
`And can you tell me what that was?
`
`It was relating to location-based
`
`services.
`
`9:35:58AM
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`Q
`
`And is there anything in particular about
`
`9:36:00AM
`
`location-based services that you remember that
`
`deposition to be involving?
`
`A
`
`Yes.
`
`There were a variety of things that
`
`I recall that it involved, yes.
`
`9:36:13AM
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`Q
`
`A
`
`And can you describe those to me?
`
`It involved geographic information
`
`systems, visualizing content on a map, on a digital
`
`map.
`
`That kind of thing.
`
`Q
`
`A
`
`Q
`
`that case?
`
`A
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`Q
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`A
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`Q
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`place?
`
`A
`
`Q
`
`Is that all?
`
`Yes.
`
`And you don't recall the opposing party in
`
`9:36:29AM
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`I don't, no.
`
`You don't recall what court it was in?
`
`9:36:39AM
`
`No, I don't.
`
`Do you recall where the deposition took
`
`In San Francisco.
`
`Do you recall the attorney who took that
`
`9:36:50AM
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`deposition?
`
`A
`
`Q
`
`I don't, no.
`
`Do you recall the law firm that took that
`
`deposition?
`
`A
`
`No.
`
`9:36:57AM
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`CONFIDENTIAL
`
`Q
`
`Have you ever been deposed at all in an
`
`9:37:00AM
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`IPR proceeding?
`
`A
`
`I was deposed once.
`
`I don't know if it
`
`was an IPR or not.
`
`I don't believe it was, but ....
`
`It involved -- yeah, so I don't know the
`
`9:37:18AM
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`answer to that.
`
`Q
`
`Do you know what --
`
`Are you familiar with an IPR proceeding?
`
`MR. CUMMINGS:
`
`Objection; form.
`
`THE WITNESS:
`
`Yeah.
`
`No, I'm not actually.
`
`9:37:29AM
`
`BY MR. CHAN:
`
`Q
`
`Do you understand that this deposition is
`
`being taken with respect to an IPR proceeding?
`
`A
`
`If it -- the only thing I'm not familiar
`
`with is the tech- -- I mean, I know what IPR is.
`
`To
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`9:37:45AM
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`say what an IPR proceeding as a -- as a phrase, I
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`don't know technically exactly what that means, so
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`it's hard for me to answer that question.
`
`Q
`
`Do you understand that IPR stands for
`
`inter partes review?
`
`9:38:00AM
`
`A
`
`Actually, so no, I don't.
`
`I mean, I don't
`
`know.
`
`I don't.
`
`I'm not a lawyer.
`
`I don't know.
`
`I
`
`don't know what that means.
`
`Q
`
`You understand that you submitted a
`
`declaration in this proceeding, which is an IPR
`
`9:38:21AM
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`proceeding?
`
`9:38:24AM
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`CONFIDENTIAL
`
`A
`
`Q
`
`I did submit a declaration, yes.
`
`And do you understand you submitted it
`
`with respect to an IPR proceeding?
`
`A
`
`No, I don't know what that means, so no, I
`
`9:38:37AM
`
`guess not.
`
`Q
`
`Have you submitted expert reports in the
`
`other case?
`
`MR. CUMMINGS:
`
`Objection; form.
`
`THE WITNESS:
`
`I don't recall what was
`
`9:39:15AM
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`submitted by me directly.
`
`BY MR. CHAN:
`
`Q
`
`Do you ever recall preparing an expert
`
`report for another proceeding?
`
`A
`
`I don't understand -- I don't know the
`
`9:39:33AM
`
`definition of "expert report" is.
`
`Q
`
`Have you served as an expert before in any
`
`other proceeding?
`
`A
`
`Q
`
`Yes.
`
`And can you tell me how many times you've
`
`9:39:43AM
`
`done that before?
`
`A
`
`Once.
`
`It's in reference to the same thing
`
`we discussed earlier.
`
`Q
`
`And in that proceeding, you submitted an
`
`expert report; is that correct?
`
`9:39:51AM
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`MR. CUMMINGS:
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`Objection; form.
`
`9:39:54AM
`
`THE WITNESS:
`
`I don't recall doing that,
`
`no.
`
`I don't know.
`
`BY MR. CHAN:
`
`Q
`
`So I'm sure your counsel has been, you
`
`9:40:02AM
`
`know -- he's advised you of the rules for a
`
`deposition.
`
`I just want to remind you of a few
`
`things.
`
`It's a question-and-answer process.
`
`I'll
`
`ask you some questions and you get the opportunity
`
`to provide answers.
`
`9:40:13AM
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`You're testifying under oath, and it has
`
`the same effect as if you were at trial.
`
`If you
`
`need a break, please let me know and we can take a
`
`break.
`
`And it's important that we take turns
`
`speaking because it's important to be clear as we
`
`9:40:24AM
`
`have a court reporter here who's transcribing the
`
`proceeding.
`
`Does that make sense?
`
`Yep.
`
`Is there any reason you cannot give
`
`9:40:32AM
`
`A
`
`Q
`
`truthful and accurate testimony today?
`
`A
`
`Q
`
`No.
`
`And did you do anything to prepare for
`
`your deposition today?
`
`A
`
`Yes.
`
`9:40:39AM
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`CONFIDENTIAL
`
`Q
`
`A
`
`And can you describe to me what you did?
`
`9:40:41AM
`
`I reviewed my declaration, I reviewed some
`
`of the documents that are referenced in the
`
`declaration, and I met with my attorney,
`
`Mr. Cummings.
`
`9:40:57AM
`
`Q
`
`A
`
`Excuse me?
`
`Mr. Cummings.
`
`Sorry, I met with my
`
`attorney, Mr. Cummings.
`
`Q
`
`And do you recall which documents you
`
`reviewed?
`
`9:41:10AM
`
`MR. CUMMINGS:
`
`Objection; privileged.
`
`I instruct the witness not to answer.
`
`BY MR. CHAN:
`
`Q
`
`Did you review those documents to refresh
`
`your recollection of what you had cited in your
`
`9:41:19AM
`
`declaration?
`
`A
`
`Q
`
`Yes.
`
`And can you tell me what -- what documents
`
`you reviewed to refresh your recollection?
`
`MR. CUMMINGS:
`
`Objection; privileged.
`
`9:41:31AM
`
`Instruct the witness not to answer.
`
`BY MR. CHAN:
`
`Q
`
`Are you going to follow your counsel's
`
`instruction?
`
`A
`
`Yes.
`
`9:41:38AM
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`CONFIDENTIAL
`
`Q
`
`How long did you meet with your counsel in
`
`9:41:49AM
`
`preparation for this deposition?
`
`A
`
`It was a matter of a few hours.
`
`We met in
`
`person for a few hours, and there were two phone
`
`conversations that were -- probably totaled an hour
`
`9:42:04AM
`
`and a half.
`
`Q
`
`And can you tell me when those meetings
`
`took place?
`
`A
`
`Well, the meeting in person took place
`
`yesterday.
`
`The phone conversation -- one of the
`
`9:42:20AM
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`phone conversations occurred on Monday, so two days
`
`ago; that was about an hour.
`
`And there was another
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`conversation late in January that was maybe about a
`
`half an hour.
`
`Q
`
`Do you recall how long the meeting took
`
`9:42:41AM
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`place yesterday?
`
`A
`
`Q
`
`A
`
`Q
`
`It was just over two hours.
`
`And who was present at that meeting?
`
`Just Mr. Cummings and myself.
`
`I believe you testified earlier that you
`
`9:43:21AM
`
`served as an expert in a prior proceeding; is that
`
`right?
`
`A
`
`I was asked to -- to -- yes.
`
`I -- yes,
`
`I'm not exactly sure what the technical definition
`
`of serving as an expert is.
`
`Again, I'm not a
`
`9:43:36AM
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`CONFIDENTIAL
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`lawyer, but I was asked to answer questions, and it
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`9:43:39AM
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`was a case, there was opposing counsel, and I was
`
`asked questions, and I answered them.
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`Q
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`A
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`Were you compensated for that expert work?
`
`No.
`
`Well, I'm an employee -- as an
`
`9:43:50AM
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`employee of Location Labs, I was asked to do it and
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`I did.
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`So in a sense, as an employee, I did my -- I
`
`acted as someone who had expertise in that area, and
`
`I was -- and I answered questions.
`
`So was I compensated?
`
`Not directly, only
`
`9:44:11AM
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`as an employee of the company that I was working
`
`for.
`
`Q
`
`Can you briefly describe your educational
`
`background?
`
`A
`
`Yes.
`
`I have a undergraduate degree in
`
`9:44:21AM
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`mathematical physics from Case Western Reserve
`
`University.
`
`I finished in 1987, and then I have a
`
`Ph.D. in particle physics from University of
`
`California, Berkeley, graduating in December of
`
`1992.
`
`9:44:40AM
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`Q
`
`A
`
`Q
`
`What is your current job title?
`
`I'm the Chief Technology Officer.
`
`And the Chief Technology Officer of
`
`Location Labs?
`
`A
`
`No.
`
`I'm the Chief Technology Officer of
`
`9:44:59AM
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`Voleon Capital Management.
`
`It's a hedge fund in
`
`9:45:01AM
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`CONFIDENTIAL
`
`downtown Berkeley.
`
`Q
`
`A
`
`What was that again?
`
`It's -- the name of the company is Voleon,
`
`V-O-L-E-O-N, Capital Management.
`
`9:45:13AM
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`That's in Berkeley?
`
`Uh-huh.
`
`And can you briefly describe your work
`
`Q
`
`A
`
`Q
`
`history?
`
`A
`
`Sure.
`
`After finishing my Ph.D., I
`
`9:45:46AM
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`taught -- I taught -- I taught physics at Case
`
`Western for a semester.
`
`After that in 1995, I was
`
`at Silicon Graphics for almost four years working in
`
`their networking technologies division.
`
`After that,
`
`I worked for the Defense Department for a short
`
`9:46:11AM
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`period, about a year.
`
`That was out of Fort Meade in
`
`Maryland, and after that I joined Location Labs,
`
`which was known as WaveMarket at the time, and was
`
`at Location Labs for just under 14 years.
`
`Q
`
`A
`
`Q
`
`A
`
`When did you join Location Labs, again?
`
`9:46:37AM
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`In January 1 of 2001.
`
`When did you leave Location Labs?
`
`I left on -- November 4th was my last day.
`
`Wait.
`
`Take that back.
`
`My last day was
`
`October 31st.
`
`Apologize for that.
`
`October 31st of
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`9:46:57AM
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`CONFIDENTIAL
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`2014.
`
`9:47:07AM
`
`Q
`
`What was your title at Location Labs when
`
`you left the company?
`
`A
`
`It was Chief Technology Officer and Senior
`
`Vice President of Engineering.
`
`9:47:23AM
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`Q
`
`And what were your primary
`
`responsibilities?
`
`A
`
`I oversaw the software development.
`
`I was
`
`a -- there were a number of them.
`
`I oversaw
`
`software development, IT, so operations, project
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`9:47:48AM
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`management.
`
`I worked with marketing and sales to
`
`sell products, and I worked on the strategic vision
`
`of the company with the management team.
`
`Q
`
`So you were with Location Labs for 14
`
`years?
`
`A
`
`Q
`
`Yes.
`
`And when you left, your title was CTO and
`
`9:48:27AM
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`Senior Vice President of Engineering?
`
`A
`
`Q
`
`Uh-huh.
`
`Did you hold any other titles during that
`
`9:48:36AM
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`14-year period?
`
`A
`
`When I started, my title was Principal
`
`Scientist.
`
`I was promoted to Vice President of
`
`Engineering, I believe -- I don't recall exactly,
`
`but I believe it was the late summer of 2001, and
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`9:49:00AM
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`those are the only other two titles I ever held.
`
`9:49:08AM
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`CONFIDENTIAL
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`Q
`
`And as the V.P. of Engineering, what were
`
`your primary responsibilities?
`
`A
`
`Well, so I -- I would view it as the two
`
`titles; the Vice President of Engineering is more
`
`9:49:30AM
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`internal facing.
`
`Again, that's managing product
`
`development, software development, software
`
`engineering, also the operational role of running
`
`production systems and things like that.
`
`And then the CTO role -- you didn't ask
`
`9:49:45AM
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`that -- is more external, so that's the distinction
`
`I would draw.
`
`I've given you a list of primary
`
`responsibilities; if you want me to put some under
`
`Vice President of Engineering, I would say it's the
`
`internal facing ones.
`
`9:49:58AM
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`Q
`
`A
`
`When did you become the CTO?
`
`I don't recall exactly.
`
`It was very --
`
`you know, it was early on.
`
`It was probably 2003,
`
`something like that.
`
`I don't recall exactly.
`
`Q
`
`A
`
`Why did you leave Location Labs?
`
`9:50:15AM
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`Well, I had been at the company a long
`
`time, and I was looking for new opportunities, new
`
`challenges for my -- professionally.
`
`Q
`
`And so when you submitted your declaration
`
`in this matter, you were an employee of Location
`
`9:50:47AM
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`Labs; is that right?
`
`9:50:49AM
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`CONFIDENTIAL
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`A
`
`Q
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`That's correct.
`
`So on June 9, 2014, you were an employee
`
`of Location Labs?
`
`A
`
`Q
`
`Yes.
`
`9:50:56AM
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`And were you compensated for the
`
`declaration you submitted in this matter?
`
`A
`
`Q
`
`No.
`
`There was no compensation.
`
`There's no separate compensation, other
`
`than the salary that you were provided as an
`
`9:51:15AM
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`employee of Location Labs; is that right?
`
`A
`
`For my declaration?
`
`No, there was no
`
`other compensation.
`
`Q
`
`Was submitting your declaration a part of
`
`your responsibilities as CTO and Senior Vice
`
`9:51:24AM
`
`President?
`
`A
`
`Q
`
`Yes.
`
`And your employer was Location Labs, and
`
`you received compensation as an employee of Location
`
`Labs; is that right?
`
`9:51:39AM
`
`A
`
`Q
`
`I did, during those 14 years, yes.
`
`Are you being compensated for this
`
`deposition?
`
`A
`
`I'm being compensated for my time to
`
`appear here, yes.
`
`9:51:56AM
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`CONFIDENTIAL
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`Q
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`And can you tell me how you're being
`
`9:51:58AM
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`compensated?
`
`A
`
`I have a consultant contract with Location
`
`Labs.
`
`It's paying at an hourly rate.
`
`Do you want
`
`to know the hourly rate?
`
`9:52:10AM
`
`Q
`
`A
`
`Q
`
`Sure.
`
`$150 an hour.
`
`Do you have any financial interest in the
`
`outcome of the proceeding?
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`I do not.
`
`9:52:24AM
`
`Do you hold any stock in Location Labs?
`
`No.
`
`How did you become involved in the matter?
`
`Which matter?
`
`In this proceeding, this IPR2014-000920.
`
`9:52:44AM
`
`So I think -- okay, so as we discussed, as
`
`the CTO of Location Labs, one of my responsibilities
`
`was to -- to be involved with and help manage
`
`matters like this that would come up, so -- as my
`
`role as CTO.
`
`9:53:06AM
`
`Q
`
`Can you tell me who -- who you spoke to
`
`with respect to this matter to become involved in
`
`it?
`
`A
`
`I believe it was introduced to me at
`
`Location Labs through Edward Abbati, who is our Vice
`
`9:53:41AM
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`President of Finance.
`
`9:53:47AM
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`CONFIDENTIAL
`
`Q
`
`A
`
`And can you tell me what he said?
`
`At the time -- you know, this goes back a
`
`ways.
`
`I don't -- don't recall exactly what he said,
`
`no.
`
`Q
`
`A
`
`Can you tell me when this happened?
`
`I don't recall when.
`
`It's a -- it's a
`
`9:54:06AM
`
`fairly long time ago.
`
`I don't recall.
`
`Q
`
`Did you speak to anybody else at Location
`
`Labs about the IPR matter?
`
`9:54:21AM
`
`MR. CUMMINGS:
`
`Objection; form.
`
`THE WITNESS:
`
`I'm not sure I understand
`
`the question.
`
`BY MR. CHAN:
`
`Q
`
`You testified that you'd spoke to Edward
`
`9:54:30AM
`
`Abbati who introduced you to this matter.
`
`My
`
`question is whether or not you spoke to anybody else
`
`at Location Labs about this matter?
`
`A
`
`Let me think.
`
`The only reason I'm having a hard time
`
`9:55:15AM
`
`answering the question is that to understand what it
`
`means to talk about that.
`
`I mean, the fact that the
`
`case was ongoing and that the company was involved
`
`with the case, the fact that that was happening,
`
`yes, there were people that, you know, were -- there
`
`9:55:27AM
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`CONFIDENTIAL
`
`were meetings where that -- that fact was discussed,
`
`9:55:30AM
`
`and there were other people there present at the
`
`meeting.
`
`To say that I discussed it with them -- I
`
`don't know -- is a little bit -- there is -- you
`
`9:55:39AM
`
`know, I can think of one employee who helped prepare
`
`materials and things along with me in preparing
`
`for -- you know, during the course of this.
`
`That's -- that's -- that would probably be the one
`
`that I would constitute as talked with.
`
`So, yes,
`
`9:55:55AM
`
`there's at least one.
`
`Q
`
`A
`
`Can you tell me who that person is?
`
`His name is Ryo Kawaoka.
`
`First name is
`
`R-Y-O, his last name, K-A-W-A-O-K-A.
`
`And he's the
`
`Vice President of Project Management at Location
`
`9:56:12AM
`
`Labs.
`
`Q
`
`You referenced meetings regarding this
`
`matter at Location Labs.
`
`Can you tell me who was
`
`present at those meetings?
`
`A
`
`So I want to say that the meeting -- I --
`
`9:56:32AM
`
`what I was saying was there were meetings that
`
`occurred where the subject of this case came up.
`
`Whether -- I'm not -- I wouldn't -- I wouldn't
`
`testify that the meeting was about this, but there
`
`were meetings where this fact -- the fact that this
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`9:56:47AM
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`case came up -- existed, came up.
`
`9:56:49AM
`
`CONFIDENTIAL
`
`Present were, you know, parts of the
`
`management team, so our CEO and our Chief Operating
`
`Officer were present.
`
`Q
`
`A
`
`Q
`
`A
`
`And who is the CEO?
`
`Tasso Roumeliotis.
`
`Can you spell his last name?
`
`R-O-U-M-E-L-I-O-T-I-S.
`
`Sorry, talk
`
`louder?
`
`And, yes, that's how you spell his last
`
`name.
`
`Q
`
`A
`
`Q
`
`And who is the COO?
`
`Joel Grossman, J-O-E-L, G-R-O-S-S-M-A-N.
`
`Were you involved in the preparation of
`
`9:57:01AM
`
`9:57:22AM
`
`the IPR petition in this case?
`
`A
`
`I'm sorry, I don't know exact- -- that
`
`9:57:53AM
`
`language, IPR petition.
`
`I was involved in many
`
`things.
`
`That particular language, I'm not familiar
`
`with.
`
`Can you --
`
`Q
`
`Do you understand that Location Labs
`
`instituted this proceeding?
`
`9:58:04AM
`
`MR. CUMMINGS:
`
`Objection; form.
`
`THE WITNESS:
`
`I'm not -- no, I'm not privy
`
`to -- no, I'm not aware of that, of how the
`
`mechanics were...
`
`MR. CHAN:
`
`I'm handing the court reporter
`
`9:59:06AM
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`CONFIDENTIAL
`
`a document that's been previously marked as
`
`9:59:07AM
`
`Exhibit 1116, a declaration of Scott Hotes, Ph.D.,
`
`for inter partes review of US Patent Number
`
`6,771,970.
`
`BY MR. CHAN:
`
`9:59:33AM
`
`Q
`
`Dr. Hotes, if you would take a moment to
`
`review the document and let me know when you're
`
`ready.
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`Yeah, I'm ready.
`
`Do you recognize this document?
`
`9:59:49AM
`
`I do.
`
`Can you tell me what it is?
`
`It is my declaration involved in this case
`
`as to the efficacy or viability of patent '970.
`
`Q
`
`And this is the declaration that you
`
`10:00:07AM
`
`submitted in this IPR proceeding, correct?
`
`A
`
`Q
`
`Yes, it is.
`
`And this is -- this Exhibit 1116 contains
`
`your opinions in this matter regarding the '970
`
`patent, correct?
`
`10:00:24AM
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`It does.
`
`Did you personally draft this declaration?
`
`I worked with my attorneys to draft this.
`
`Can you explain how it was created?
`
`It was a long process; it involved --
`
`10:00:51AM
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`MR. CUMMINGS:
`
`Caution the witness not to
`
`10:00:53AM
`
`reveal the substance of any attorney/client
`
`communications in the process.
`
`THE WITNESS:
`
`Okay.
`
`There was -- as far
`
`as the actual mechanics of the process, there was
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`10:00:59AM
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`reviewing of documents.
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`As you can see in the
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`document itself, it references a number of things,
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`so those were reviewed.
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`There were conversations and communication
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`with -- with legal representation.
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`There was a lot
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`of analysis that went on on my side, you know, and
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`there were drafts, some of the drafts, some of the
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`language, you know, some of the legal sides of
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`language was definitely, you know, helped draft by
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`the -- by legal counsel, so it was a group effort.
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`10:01:43AM
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`BY MR. CHAN:
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`Q
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`So I'd like to direct your attention to
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`page 2 of your declaration, Exhibit 1116.
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`In paragraph 2, you state:
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`"In the preparation of this
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`10:01:56AM
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`declaration, I have studied:
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`A..."
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`Number of different items.
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`Now, I want to
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`direct your attention to Item N on page 3.
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`""Petition for inter partes
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`review of U.S. Patent No. 6,771,970
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`10:02:07AM
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`CONFIDENTIAL
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`Pursuant to 35 U.S.C. Sections 311-
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`10:02:07AM
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`312 and 37 C.F.R. Sections
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`42.100-106, 108 (to be filed with
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`this declaration)."
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`Do you see that?
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`Yes.
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`Does it refresh your recollection as to
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`A
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`Q
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`whether or not you considered the petition that
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`Location Labs filed for IPR in this case?
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`10:02:27AM
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`A
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`If I could see a copy of it, that would
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`10:02:39AM
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`help refresh my memory of it.
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`MR. CHAN:
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`Hand the court reporter a
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`document titled "Petition for Inter Partes Review of
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`US Patent Number 6,771,970."
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`I believe it's paper number 3 in this
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`10:03:08AM
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`proceeding.
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`THE WITNESS:
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`Yes, I'm familiar with this.
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`I just -- personally I've never used the phrase,
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`"Petition for Inter Partes Review."
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`That's not
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`language I typically would use.
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`I didn't recall the
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`10:03:26AM
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`exact title of the document but, yes, I'm familiar
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`with it.
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`MR. CHAN:
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`So the record would be clear,
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`the witness testified that he is familiar with the
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`inter partes review petition filed by Location Labs,
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`Item Number N in Exhibit 1116.
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`10:03:42AM
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`CONFIDENTIAL
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`MR. CUMMINGS:
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`Objection; form.
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`BY MR. CHAN:
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`Q
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`Is that correct, Dr. Hotes?
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`MR. CUMMINGS:
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`Objection; form.
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`10:03:51AM
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`THE WITNESS:
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`What's the question?
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`BY MR. CHAN:
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`it.
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`Q
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`A
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`That you testified you were familiar with
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`I'm familiar with the --
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`10:03:58AM
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`MR. CUMMINGS:
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`Objection to form.
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`BY MR. CHAN:
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`Q
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`Is that correct?
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`MR. CUMMINGS:
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`Objection; form.
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`BY MR. CHAN:
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`10:04:04AM
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`Q
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`A
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`Q
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`You may answer.
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`I am familiar with this document, yes.
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`Thank you.
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`And earlier I asked the question whether
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`or not you had been involved in the preparation of
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`10:04:14AM
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`the Petition for Inter Partes Review in this
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`proceeding.
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`Do you recall that?
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`A
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`Yes, I recall you asking the question,
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`yes.
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`10:04:24AM
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`Q
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`And can you answer that question now?
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`10:04:24AM
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`MR. CUMMINGS:
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`Objection; form.
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`THE WITNESS:
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`I do recall -- yes, I was
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`involved -- so let me answer the question.
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`Yes, I
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`was involved in the preparation of this document.
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`10:04:36AM
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`BY MR. CHAN:
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`Q
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`A
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`And the document you're referring to --
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`Oh, sorry.
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`The document I'm referring to
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`is the Petition for Inter Partes Review, yes.
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`Q
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`And can you tell me what you did to be
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`10:04:48AM
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`involved in the preparation for the Petition for
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`Inter Partes Review?
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`A
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`I don't recall exactly, but I was
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`certainly involved with conversations having to do
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`with what's referred to as the claim chart, the
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`10:05:24AM
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`claims, you know -- how the -- and putting that
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`together and breaking down and trying to understand
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`exactly the content of the claims and, yes, that
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`part of the process I was involved with.
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`Q
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`You mentioned you were involved in
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`10:05:49AM
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`preparing the claim charts?
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`A
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`Q
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`Yes.
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`Anything else?
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`MR. CUMMINGS:
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`Objection; form.
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`THE WITNESS:
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`I'm not sure I understand
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`10:06:08AM
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`the question.
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`Can you repeat the question.
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`10:06:09AM
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`CONFIDENTIAL
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`BY MR. CHAN:
`
`Q
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`I'm just asking what other things did you
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`do to help prepare the petition?
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`A
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`Well, similar to the declaration, I mean,
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`10:06:20AM
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`to say "prepare" -- there's a -- there's a long
`
`process involved.
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`Again, questions of analysis,
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`references, related material, things like that.
`
`So
`
`there was -- it's hard to -- couldn't possibly
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`describe exactly of all -- all the entire process,
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`10:06:44AM
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`but, yes, there was a bunch -- there was a variety
`
`of research, reviewing documents and that kind of
`
`thing.
`
`Really, you know, and -- yes.
`
`So -- so
`
`reviewing documents, looking at primarily filed
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`patents, things like that.
`
`I reviewed those.
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`Product information, product materials, things like
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`that.
`
`Those are a lot of -- a review of a variety
`
`of documents.
`
`And discussion with -- with -- with
`
`the lawyers and that kind of thing.
`
`Q
`
`Did you select the prior art references
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`10:07:46AM
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`used in the petition?
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`MR. CUMMINGS:
`
`Objection; privileged.
`
`Instruct the witness not to answer.
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`BY MR. CHAN:
`
`Q
`
`I'm asking you, Dr. Hotes, did you select
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`
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`the prior art references?
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`10:08:03AM
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`CONFIDENTIAL
`
`MR. CUMMINGS:
`
`Objection; privileged --
`
`objection privileged.
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`Instruct the witness not to answer.
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`BY MR. CHAN:
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`10:08:12AM
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`Q
`
`I'm asking your own personal knowledge,
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`Dr. Hotes.
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`A
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`I'm following the instruction of counsel
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`to not answer the question.
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`Q
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`I'm asking your personal knowledge.
`
`I'm
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`10:08:20AM
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`not asking about any communications with your
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`attorneys.
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`I'm asking, did you select the prior art
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`references used in the petition?
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`MR. CUMMINGS:
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`Objection; privileged.
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`10:08:30AM
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`Instruct the witness not to answer.
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`BY MR. CHAN:
`
`Q
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`Are you going to follow your counsel's
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`instruction?
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`A
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`Q
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`Yes, I'm going to follow.
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`10:08:38AM
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`It's an improper instruction.
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`It's not
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`privileged.
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`I'm asking your personal knowledge.
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`Did
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`you select them?
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`Simple question.
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`MR. CUMMINGS:
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`Witness can answer the
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`
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`question.
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`BY MR. CHAN:
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`CONFIDENTIAL
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`10:08:50AM
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`Q
`
`A
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`Q
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`It's a "yes" or "no."
`
`I did not.
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`No.
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`Do you know who selected the prior art
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`10:09:02AM
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`references used in the petition?
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`A
`
`Q
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`I do not.
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`Do you recall the first time you saw any
`
`of the prior art references used in the petition?
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`A
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`Q
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`No, I don't recall.
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`10:09:23AM
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`Do you know how the prior art references
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`were selected?
`
`A
`
`Q
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`No.
`
`Was the first time you saw the prior art
`
`references used in the petition in preparation for
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`10:09:49AM
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`your declaration that you submitted in this matter?
`
`A
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`Q
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`I don't recall that either.
`
`You mentioned earlier that you are now the
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`CTO of Volean Capital Management; is that right?
`
`A
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`Q
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`Right.
`
`Yes.
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`10:10:20AM
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`Can you describe to me what your -- your
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`primary responsibilities are as CTO of Voleon?
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`A
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`Yes.
`
`I oversee software development, IT,
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`so information technologies that are used by the
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`company and the production process of managing --
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`10:10:48AM
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