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` IN THE UNITED STATES PATENT AND
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` TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Case No: IPR2014-01102
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`U.S. Patent No: 5,228,077
`
`_________________________________
`
`Case No: IPR2014-01103
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`U.S. Patent No: 5,552,917
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`_________________________________
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`Case No: IPR2014-01104
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`U.S. Patent No: 5,414,761
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`__________________________________
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`Case No: IPR2014-01106
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`U.S. Patent No: 5,255,313
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`__________________________________
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`Case No: IPR2014-01109
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`U.S. Patent No: 7,831,930
`
`___________________________________
`
` Deposition of ALEX COOK, taken
`
`before LAURA MUKAHIRN, CSR, RPR, CRR, at
`
`One South Dearborn Street, in the City of
`
`Chicago, Cook County, Illinois, commencing
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`at 9:00 o'clock a.m. on the 17th day of
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`June, 2015.
`
` VOLUME III
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`877-479-2484
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`
`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
`
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000001
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`A P P E A R A N C E S:
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` OSTROLENK FABER LLP
`
` 1180 Avenue of the Americas
`
` New York, New York 10036
`
` (212)382-0700
`
` BY: MR. KEITH BARKAUS
`
` -AND-
`
` SIDLEY AUSTIN
`
` 1001 Page Mill Road
`
` Building 1
`
` Palo Alto, California 94304
`
` (650)565-7006
`
` BY: MR. PETER H. KANG
`
` MR. FERENC PAZMANDI
`
` Appeared on behalf of Universal
`
` Remote Control, Inc.;
`
` GREENBERG TRAURIG, LLP
`
` 77 West Wacker Drive
`
`12
`
` Suite 2500
`
` Chicago, Illinois 60601
`
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` (312) 456-8451
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` BY: MR. ERIC J. MAIERS
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` Appeared on behalf of Universal
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` Electronics, Inc.
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000002
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`[Page 511]
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` I N D E X
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` Examinations Page
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`Cross-Examination 512
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`By Mr. Barkaus
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` 727
`
`Direct Examination
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`By Mr. Maiers
`
` E X H I B I T S
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` No. Page
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` Exhibit 1046 513
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` (Universal Remote Control Exhibit
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` 1046 Trial No. IPR 2014-1146)
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` Exhibit 2029 521
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` (Universal Electronics Exhibit 2029
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` Trial No. IPR 2014-1146)
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` Exhibit 1003
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`12
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` (Universal Remote Control Exhibit 526
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` No. 1003 Trial No. IPR 2014-1146)
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` Exhibit 1001 532
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`14
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` (Universal Remote Control Exhibit
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` No. 1001 Trial No. IPR 2014-1146)
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` Exhibit 1047 542
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`16
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` (Universal Remote Control Exhibit
`
` 1047 Trial No. IPR 2014-1146)
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`17
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` Exhibit 1005 592
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`18
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` (Universal Remote Control Exhibit
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` 1005 Trial No. IPR 2014-1146)
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` (Witness previously
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`877-479-2484
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000003
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` sworn.)
`
` ALEX COOK
`
` called as a witness herein, having been
`
` first duly sworn, was examined and
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` testified further as follows:
`
` Cross-Examination
`
` By Mr. Barkaus
`
` Q. Good morning, Mr. Cook.
`
` A. Good morning, Mr. Barkaus.
`
` Q. You recall that you're still
`
` under oath, sir?
`
` A. Yes.
`
` (Document marked as
`
` Exhibit No. 1046 for
`
` identification.)
`
` BY MR. BARKAUS:
`
` Q. Okay. I'm going to hand to you
`
` an exhibit which we've marked Universal
`
` Remote Control Exhibit 1046. And,
`
` actually, I just noticed -- Will you hand
`
` that back to me. This is currently marked
`
` Universal Remote Control Exhibit 1046,
`
` Trial No. IPR 2014-1109. And we're going
`
` to change that to be Universal Remote
`
` Control Exhibit 1046 Trial No. IPR
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`877-479-2484
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`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000004
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` 2014-1146.
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` (Document remarked as
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` Exhibit No. 1046 for
`
` identification.)
`
` BY MR. BARKAUS:
`
` Q. So do you have that document in
`
` front of you now, Mr. Cook?
`
` A. I do.
`
` Q. All right. And as you can see,
`
` it's -- on the top right-hand it says
`
` Amended Notice of Deposition of Alex Cook;
`
` is that correct?
`
` A. Yes.
`
` Q. On the left-hand side it
`
` says -- Well, let's look at the case
`
` number. IPR 2014-1146 and U.S. Patent No.
`
` 8,243,207. Do you see that?
`
` A. Yes.
`
` Q. And if you turn to Page 2,
`
` there's a listing of the trial numbers or
`
` the case numbers that you're giving
`
` testimony in: Case Nos. IPR 2014-1102, IPR
`
` 2014-1103, IPR 2014-1104, IPR 2014-1106.
`
` And you gave testimony in those matters
`
` yesterday. Do you recall doing that?
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`877-479-2484
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`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000005
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` A. Yes.
`
` Q. Okay. And, finally, IPR
`
` 2014-1109, and you gave testimony in that
`
` matter on Monday. Do you recall doing
`
` that?
`
` A. I do.
`
` Q. Okay. And you understand that
`
` today we're going to ask you to give some
`
` testimony on IPR 2014-1146. Do you
`
` understand that?
`
` A. Yes.
`
` Q. Okay. Great. And for -- To
`
` make things easier on both of us, when I
`
` refer to U.S. Patent No. 8,243,207, I'm
`
` going to use the term the '207 patent.
`
` Does that work for you?
`
` A. Yes.
`
` Q. You'll understand what that
`
` means. And then when I refer to the IPR as
`
` a whole, can I refer to that as the 1146
`
` IPR? Do you understand that?
`
` A. Yes.
`
` Q. Okay. Good. I'd like to start
`
` off by talking a little bit about your time
`
` at Scientific Atlanta which was between
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`877-479-2484
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`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000006
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` 1983 and 1996; is that correct?
`
` A. Yes.
`
` Q. And you previously mentioned
`
` that while you were working there, you
`
` worked on set-top boxes as well as remote
`
` controls, both single device remote
`
` controls and universal remote controls; is
`
` that correct?
`
` A. That's correct.
`
` Q. Okay. While you were at
`
` Scientific Atlanta, did you do any work on
`
` VCRs?
`
` MR. MAIERS: Objection. Form.
`
` THE WITNESS: When you say did I
`
` do any work on VCRs, are you saying did I
`
` design or develop VCRs? What's your
`
` question?
`
` BY MR. BARKAUS:
`
` Q. Let's go with that one. Did
`
` you design or develop VCRs at Scientific
`
` Atlanta?
`
` A. No, I did not.
`
` Q. Did you do any work related to
`
` VCRs at Scientific Atlanta?
`
` A. During that period of time VCRs
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`877-479-2484
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`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000007
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` in home environment were common, and so I
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` became very familiar with VCRs. And so
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` from that sense in understanding the
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` environment of a typical cable subscriber
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` and the various pieces of equipment that
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` they had, yes, I became very familiar with
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` VCRs.
`
` Q. But Scientific Atlanta did not
`
` make any VCRs; is that correct?
`
` A. No. But definitely impacted
`
` the other products we did make.
`
` Q. Did -- Have you ever had any
`
` design and/or development experience in DVD
`
` players?
`
` A. Design or development
`
` experience in DVD players, no, not
`
` directly.
`
` Q. Did you have design or
`
` development experience in DVD players
`
` indirectly?
`
` A. In the effect, again, on the
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` set-top box products and remote controls
`
` that Scientific Atlanta made we had to
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` consider the entire entertainment
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` environment in the home. And that included
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`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000008
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` DVD players.
`
` Q. Scientific Atlanta didn't make
`
` any DVD players, did they?
`
` A. No.
`
` Q. After leaving Scientific
`
` Atlanta, did you have any experience in the
`
` design or development of VCRs?
`
` A. I don't recall ever having any
`
` design or development experience with VCRs.
`
` Q. So that would be -- So you say
`
` you don't recall ever having any design or
`
` development experience with VCRs. That's
`
` in your entire career?
`
` A. That's correct.
`
` Q. Okay. And do you recall ever
`
` having design or development experience
`
` with DVD players over the course of your
`
` career?
`
` A. I don't recall ever having any
`
` design or development experience with DVD
`
` players over the entire career.
`
` Q. Have you ever had any
`
` experience in design or development of
`
` digital video recording devices such as,
`
` for example, the TiVo device?
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`877-479-2484
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000009
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` A. I've had experience with
`
` digital video recording devices similar to
`
` a TiVo device.
`
` Q. And designing and developing
`
` those devices?
`
` A. Yes.
`
` Q. And where was that at?
`
` A. That -- I've had that
`
` experience in designing and developing
`
` those products in my current role at
`
` Comcast.
`
` Q. So presently working in the
`
` design and development -- slow down a
`
` little bit here.
`
` Are you presently working on
`
` the design and development of digital video
`
` recording devices at Comcast?
`
` A. Not today. The products I'm
`
` working on today do not have that feature.
`
` Q. Okay. So this was in the past?
`
` A. Yes.
`
` Q. Can you tell me approximately
`
` when you worked on those types of products?
`
` A. 2011 and '12, I think.
`
` Q. And prior to that work that you
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`877-479-2484
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`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
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` did at Comcast, did you have any experience
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` in the design and development of digital
`
` video recording devices?
`
` A. I don't think I had any design
`
` or development role prior to the work at
`
` Comcast.
`
` Q. And did any of your prior
`
` employers make a product -- make a digital
`
` video recording device?
`
` A. I did contract work for --
`
` consulting work for a company called Nagra
`
` Livewire from 2006. Let me get the dates
`
` right. Sorry. Through -- yeah, 20 -- let
`
` me say 2007 through -- through late 2010.
`
` Nagra made a software product that went
`
` with digital video recorders, and I was
`
` involved in the team that sourced the
`
` hardware that used that software product.
`
` So I had some role in that whole process
`
` from 2007 through late 2010.
`
` Q. And you said the name of the
`
` company was Nagra? Can you spell that,
`
` please?
`
` A. N-A-G-R-A. And I'm sorry. And
`
` the specific division at the time was a
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`877-479-2484
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`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
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` company called Livewire, L-I-V-E-W-I-R-E,
`
` all one word, located in Atlanta.
`
` Q. And you said that this company
`
` developed a software application?
`
` A. Yeah. The application was
`
` actually called Livewire.
`
` Q. Okay. But this company,
`
` Livewire, did not make the hardware. They
`
` just wrote the software; is that correct?
`
` A. That's correct. We sourced the
`
` hardware, specified the hardware, and that
`
` was part of my work was to specify that.
`
` Q. So when you say you specified
`
` the hardware, you developed the
`
` specification requirements that you
`
` needed --
`
` A. Yes.
`
` Q. -- and then someone else made
`
` the device?
`
` A. That's right.
`
` Q. Okay. I'm a little embarrassed
`
` I didn't ask this on the first day, and I
`
` don't think Peter asked it yesterday. What
`
` is your current residence?
`
` A. Current residence is in the
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`877-479-2484
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`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
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` Atlanta area. It's 2290 Soaring, that's
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` S-O-A-R-I-N-G, Soaring Lane, and the city
`
` is Lawrenceville,
`
` L-A-W-R-E-N-C-E-V-I-L-L-E, Georgia, 30044.
`
` Q. I'm going to give you now a
`
` copy of document Universal Electronics
`
` Exhibit 2029 in the 1146 IPR. Do you
`
` recognize this document?
`
` A. Yes. It's my declaration in
`
` this case.
`
` Q. Okay. And can you turn to
`
` Page -- okay. I'm going to stick with the
`
` rule today, otherwise Eric is going to
`
` throw stuff at me. We'll use the page
`
` numbers on this document after Universal
`
` Electronic Exhibit 2029. There's a page
`
` number. We're going to use that page
`
` number on the bottom right side of the
`
` page. Do you understand that?
`
` A. Yes.
`
` Q. So please turn to Page 26 of
`
` Exhibit 2029.
`
` A. Yes.
`
` Q. And do you see your signature
`
` on that page?
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` A. I do.
`
` Q. And is that your signature?
`
` A. It is.
`
` Q. Okay. Do you recall signing
`
` this document?
`
` A. I do.
`
` Q. Okay. There's a date next to
`
` it says March 25, 2015. Is that the day
`
` that you signed this document?
`
` A. It is.
`
` Q. And is that the date that this
`
` document was finalized as far as you're
`
` concerned?
`
` A. Yes, it is. Yes.
`
` Q. And do you recall when you
`
` began working on this document?
`
` A. Same answer as on Monday. It
`
` was in that February time frame, but I do
`
` not recall the exact start of it.
`
` Q. And the process that you used
`
` to prepare this document is the same
`
` process that you used to prepare your
`
` declaration in the 1109 IPR; is that
`
` correct?
`
` A. Yes.
`
`877-479-2484
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`
`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000014
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` Q. Okay. And just to quickly
`
` summarize, you prepared a first draft of
`
` the document; is that correct?
`
` A. That's correct.
`
` Q. And then you forwarded that on
`
` to some folks at Greenberg Traurig and they
`
` revised the formatting; is that correct?
`
` A. That's correct.
`
` Q. And do you recall if they made
`
` any changes to the substance of the
`
` document?
`
` A. I don't recall any changes to
`
` the substance of the document, no.
`
` Q. When I say "the document," I
`
` mean this specific document we're referring
`
` to right now.
`
` A. I don't recall any changes for
`
` this.
`
` Q. Do you recall if -- do you
`
` recall how many drafts, if any additional
`
` drafts, were exchanged between you and
`
` Greenberg Traurig?
`
` A. I don't recall any additional
`
` drafts on this document.
`
` Q. Okay. So just to summarize
`
`877-479-2484
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`
`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000015
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`
`
`
`
` then, you do recall preparing a first draft
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`[Page 524]
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` of this document?
`
` A. I do.
`
` Q. Okay. And then you sent it to
`
` Greenberg Traurig and they made whatever
`
` formatting changes they believed were
`
` necessary; is that correct?
`
` A. That's correct.
`
` MR. MAIERS: Objection. Form.
`
` BY MR. BARKAUS:
`
` Q. And then they sent you back a
`
` revised draft; is that correct?
`
` A. That's correct.
`
` Q. And you don't recall making any
`
` additional changes to that revised draft?
`
` A. I don't recall making any
`
` additional changes on this one to that
`
` revised draft, no.
`
` Q. Okay. So do you believe that
`
` the revised draft you got back from
`
` Greenberg Traurig is the same as this
`
` document in final form?
`
` A. I believe that it is, yes.
`
` Q. Okay. Could you please turn to
`
` Page 6 of Exhibit 2029?
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`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000016
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`[Page 525]
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` A. Okay.
`
` Q. And I'd like to direct your
`
` attention to Paragraph 20 which is at the
`
` bottom of that page. Do you see that
`
` paragraph?
`
` A. I do.
`
` Q. And you see it says here, I
`
` agree with Mr. Geier that a person of
`
` ordinary skill in the art in the relevant
`
` time frame was aware of associating keys on
`
` a remote control with command values.
`
` Do you see that?
`
` A. I do.
`
` Q. And then it says, I would also
`
` agree that it was well known to use a
`
` remote control to select inputs and outputs
`
` of devices. Do you see that?
`
` A. I do.
`
` Q. Okay. And then, finally, it
`
` says, I do not agree that such a person was
`
` aware of sending a command value to a
`
` device to actively switch inputs and
`
` outputs according to a user's activity.
`
` In that last sentence there,
`
` you use the term actively switch. Do you
`
`877-479-2484
`
`
`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
`
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000017
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`
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`[Page 526]
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` see that?
`
` A. I do.
`
` Q. Did Mr. Geier use the term
`
` actively switch?
`
` A. No. That's a term --
`
` MR. MAIERS: Objection. Form.
`
` Foundation.
`
` THE WITNESS: No.
`
` BY MR. BARKAUS:
`
` Q. No?
`
` A. Actually, I don't have
`
` Mr. Geier's declaration in front of me.
`
` Can we take a look at that?
`
` Q. We certainly can. I'm going to
`
` go ahead and hand you what's been
`
` previously marked as Universal Remote
`
` Control Exhibit 1003, and this is in the
`
` 1146 IPR.
`
` So going back to my question,
`
` the term actively switch, which is on Page
`
` 6 of your declaration which is
`
` Exhibit 2029. Is the term actively switch
`
` a term that Mr. Geier used?
`
` A. No. It's not a term that he
`
` actively used -- or he used in his
`
`877-479-2484
`
`
`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
`
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
`
`Universal Remote Control Exhibit: 1054 Page 000018
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`[Page 527]
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` description of what a person of ordinary
`
` skill in the art would be.
`
` Q. Did Mr. Geier use the term
`
` actively switch anywhere in his
`
` declaration? Actually, withdraw that.
`
` Let's go ahead and take a look
`
` at -- The statements that you make in
`
` Paragraph 20 here, are they with reference
`
` to your citation to Paragraph 22 of
`
` Mr. Geier's declaration in Paragraph 19
`
` above?
`
` A. They would be in reference to
`
` that and anywhere in Mr. Geier's
`
` declaration where he referred to someone of
`
` ordinary skill in the art.
`
` Q. Okay. So then based on your
`
` statements in Paragraph 20, you would agree
`
` that one of skill -- of ordinary skill in
`
` the art was aware of associating keys on a
`
` remote control with command values; is that
`
` correct?
`
` A. I would agree that associating
`
` keys on a remote control with a value that
`
` was transmitted, being the command value,
`
` people would be aware of that.
`
`877-479-2484
`
`
`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
`
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
`
`Universal Remote Control Exhibit: 1054 Page 000019
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`[Page 528]
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` Q. Okay. So do you agree with the
`
` first sentence of Paragraph 20 in your
`
` declaration, Exhibit 2029? Is that an
`
` accurate statement of your belief?
`
` A. Yes, it is.
`
` Q. Okay. And would you also agree
`
` that one of ordinary skill in the art would
`
` have known to use a remote control to
`
` select inputs and outputs?
`
` A. Yes.
`
` Q. But it is your position based
`
` again on your statements in Paragraph 20
`
` that a person of skill in the art would not
`
` be aware of sending a command value to a
`
` device to actively switch inputs and
`
` outputs; is that correct?
`
` MR. MAIERS: Objection. Form.
`
` BY MR. BARKAUS:
`
` Q. Actually, let me just change
`
` the question.
`
` Would a person of ordinary
`
` skill in the art in the relevant time
`
` period that you refer to here in
`
` Paragraph 20 be aware of sending a command
`
` value to a device to actively switch inputs
`
`877-479-2484
`
`
`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
`
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
`
`Universal Remote Control Exhibit: 1054 Page 000020
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`[Page 529]
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` and outputs?
`
` A. Yeah. I believe that a person
`
` of ordinary skill in the art at that time
`
` would not have been aware of sending a
`
` single command value to actively switch
`
` inputs and outputs.
`
` Q. When you use the term actively
`
` switch, what is your understanding of what
`
` that term means?
`
` A. My understanding, I think I
`
` call out later in the document.
`
` Q. Okay.
`
` A. And I give examples from the --
`
` from the '207 patent, and my understanding
`
` comports with those examples given.
`
` Q. So is it your testimony that
`
` actively switch means what occurs in the
`
` examples you cite in your declaration?
`
` A. It means I stated to switch or
`
` route inputs to outputs in a device.
`
` Q. And is it your position --
`
` actually let me -- Withdrawn.
`
` Turning back to Paragraph 20 on
`
` Page 6 of Exhibit 2029. You refer to in
`
` the first sentence that the relevant time
`
`877-479-2484
`
`
`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
`
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000021
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`[Page 530]
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` frame. What is -- what relevant time frame
`
` were you referring to, Paragraph 20?
`
` A. To the time of the filing of
`
` the '207 patent which would have been
`
` September in 2009.
`
` Q. And, again, Mr. Geier did not
`
` use the term actively switch in his
`
` declaration, did he?
`
` A. I haven't looked again at the
`
` entire declaration, and I don't recall if
`
` that phrase is in, though, the declaration.
`
` I can review it now if you'd like.
`
` Q. Sure. Why don't you go ahead
`
` and review it, please.
`
` A. I believe you're right. I
`
` believe he does not discuss act switching
`
` in this document.
`
` Q. Okay. So he does not use the
`
` term actively switch in his declaration; is
`
` that correct?
`
` A. No. I don't see where he used
`
` actively switched or discussed that concept
`
` in any way that I could be referring to.
`
` Q. Okay. So then the statement
`
` that you made in the last sentence of
`
`877-479-2484
`
`
`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000022
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` Paragraph 20, Exhibit 2029, is an error?
`
` MR. MAIERS: Objection. Form.
`
` BY MR. BARKAUS:
`
` Q. Is that correct?
`
` A. I don't think I would call that
`
` an error. I would say that it's a matter
`
` of -- that I'm relating the person that he
`
` described to a person I think would need to
`
` be of ordinary skill in the art.
`
` Q. Okay. But the statement that
`
` you make in the last sentence of Paragraph
`
` 20, you're not actually disagreeing with
`
` anything that Mr. Geier expressed in his
`
` declaration?
`
` A. Correct.
`
` MR. MAIERS: Objection. Form.
`
` BY MR. BARKAUS:
`
` Q. Let's go down to Paragraph 22.
`
` And we're on Page 7 of Exhibit 2029 in the
`
` 1146 IPR. And you see there you say, I
`
` also disagree with Mr. Geier's opinion that
`
` the '207 patent also describes that
`
` technology was known in the art regarding
`
` controlling various components of a home
`
` entertainment center.
`
`877-479-2484
`
`
`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
`
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
`
`Universal Remote Control Exhibit: 1054 Page 000023
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`
`
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`[Page 532]
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` Do you see that section?
`
` A. I do.
`
` Q. Okay. Are you familiar with
`
` what a macro is?
`
` A. Yes.
`
` Q. Can you explain to me your
`
` understanding of what a macro is?
`
` A. A macro is when I take a number
`
` of individual commands on a remote control
`
` and assign those to a single key so that
`
` pressing that single key transmits those
`
` commands instead of a single command.
`
` Q. And can a macro include
`
` commands that relate to different
`
` components of a home entertainment system?
`
` A. Yes.
`
` Q. Let's take a look at -- I'm
`
` going to give you a copy of the '207 patent
`
` so we can talk about that. And this has
`
` been marked as Exhibit 1001 in the 1146
`
` IPR.
`
` Do you see the document that's
`
` marked as Universal Remote Control
`
` Exhibit 1001 -- I'm sorry. Universal
`
` Remote Control Exhibit 1001?
`
`877-479-2484
`
`
`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
`
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000024
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`
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`[Page 533]
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` A. I do.
`
` Q. Do you recognize this document?
`
` A. I do.
`
` Q. Can you tell me what it is,
`
` please?
`
` A. I'm sorry?
`
` Q. Can you tell me what it is,
`
` please.
`
` A. It's a copy of U.S. Patent
`
` 8,243,207, the '207 patent.
`
` Q. Okay. And you have read this
`
` '207 patent; is that correct?
`
` A. That's correct. I have.
`
` Q. From cover to cover?
`
` A. Cover to cover.
`
` Q. Okay. Great. Can you please
`
` turn to Page 9 of that Exhibit 1001. I'll
`
` ask you to look at Column 1 starting around
`
` Line 20 where it says, various methods have
`
` been proposed for automating all or part of
`
` these configuration operations, for
`
` example, through use of controlling device
`
` based macro sequences such as described in
`
` U.S. Patent No. 5,959,751.
`
` A. Correct.
`
`877-479-2484
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`
`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
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`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000025
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`[Page 534]
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`
` Q. Do you see that section?
`
` A. Mm-hmm.
`
` Q. So we just discussed what a
`
` macro is, correct?
`
` A. Yes.
`
` Q. And we discussed that macros
`
` can be used to send commands to multiple
`
` components in an entertainment device?
`
` A. Yes.
`
` Q. And right here in Column 1 of
`
` the '207 patent, the idea of a macro
`
` sequence is described?
`
` A. Yes.
`
` Q. Is that correct?
`
` A. Yes.
`
` Q. So wouldn't it be fair to say
`
` that the '207 patent does describe at least
`
` one way to control multiple components of
`
` the home entertainment system?
`
` A. No. I think the '207 patent
`
` references that to differentiate its
`
` content from macros.
`
` Q. Would one of skill in the art
`
` understand what a macro is?
`
` A. Yes.
`
`877-479-2484
`
`
`U.S. LEGAL SUPPORT, INC. www.uslegalsupport.com
`
`Universal Remote Control v. Universal Electronics, Trial No. IPR2014-01146
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`Universal Remote Control Exhibit: 1054 Page 000026
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`[Page 535]
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` Q. Would one of skill in the art
`
` understand that a macro allows a user to
`
` control multiple components of a home
`
` entertainment system?
`
` A. Yes.
`
` Q. So one of skill in the art,
`
` when they see the description of a patent
`
` that relates to macro sequences, would
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