Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
`
`1
`
` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` HULU, LLC,
` NETFLIX, INC., and
` SPOTIFY USA INC.
` Petitioners
` v.
` CRFD RESEARCH, INC.
` Patent Owner
`
` Case IPR2015-00259
` U.S. Patent No. 7,191,233
`
` DEPOSITION OF PRASANT MOHAPATRA, Ph.D.
` San Jose, California
` Wednesday, October 14, 2015
`
`Reported by:
`JANIS JENNINGS, CSR, CLR, CCRR
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`IPR2015-00259
`
`October 14, 2015
`
`1
`
` IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` HULU, LLC,
` NETFLIX, INC., and
` SPOTIFY USA INC.
` Petitioners
` v.
` CRFD RESEARCH, INC.
` Patent Owner
`
` Case IPR2015-00259
` U.S. Patent No. 7,191,233
`
` DEPOSITION OF PRASANT MOHAPATRA, Ph.D.
` San Jose, California
` Wednesday, October 14, 2015
`
`Reported by:
`JANIS JENNINGS, CSR, CLR, CCRR
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
`
`2
`
` DEPOSITION OF PRASANT MOHAPATRA, Ph.D.,
`taken on behalf of the Petitioner, at Ascenda Law Group,
`333 W. San Carlos Street, Suite 200, San Jose,
`California, beginning at 9:02 a.m. on Wednesday, October
`14, 2015, before Janis Jennings, Certified Shorthand
`Reporter No. 3942, CLR, CCRR.
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
`
`3
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`APPEARANCES:
`
` For Petitioners:
` WARD & ZINNA, LLC
` BY: DAVID G. LINDENBAUM, ESQ.
` 382 Springfield Avenue
` Summit, New Jersey 07901
` 908.277.3333
` dlindenbaum@wardzinna.com
`
` For Patent Owner:
` ASCENDA LAW GROUP
` BY: TAREK N. FAHMI, ESQ.
` 333 W. San Carlos Street
` Suite 200
` San Jose, California 95110-2730
` 408.389.3537
` tarek@ascendalaw.com
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
`
`4
`
` I N D E X
`
`WITNESS EXAMINATION
`PRASANT MOHAPATRA, Ph.D.
`
` BY MR. LINDENBAUM 6
` BY MR. FAHMI 148
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
`
`5
`
` E X H I B I T S
`
`NUMBER DESCRIPTION PAGE
`Exhibit 1001 United States Patent No. 7,191,233 30
`
`Exhibit 1004 United States Patent No. 6,963,901 34
`
`Exhibit 1006 Mobile ID Protocol: A Badge- 121
` Activated Application Level Handoff
` of a Multimedia Streaming to Support
` User Mobility by Bo Zou
`
`Exhibit 1018 Transmission Control Protocol DARPA 68
` Internet Program Protocol
` Specification September 1981
`
`Exhibit 1019 Schematic 146
`
`Exhibit 2001 Declaration of Prasant Mohapatra, 10
` Ph.D.
`
`Exhibit 2002 Curriculum Vitae of Prasant 11
` Mohapatra, Ph.D.
`
`PAPER 8 Decision Entered: June 3, 2015 33
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
`
`6
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` SAN JOSE, CALIFORNIA; WEDNESDAY, OCTOBER 14, 2015;
` 9:02 A.M.
`
` PRASANT MOHAPATRA, Ph.D.,
` The witness herein, was sworn and testified
` as follows:
`
` EXAMINATION
`BY MR. LINDENBAUM:
` Q. Could you state your full name for the
`record.
` A. Prasant Mohapatra.
` Q. Okay. Okay. Dr. Mohapatra, my name is
`David Lindenbaum. I represent Hulu LLC, Netflix
`Inc., and Spotify USA Inc. and I will be taking your
`deposition today.
` You have been administered an oath and
`pursuant to that oath, you're obligated to tell the
`truth during the deposition.
` Do you understand?
` A. Yes.
` Q. All right. Are you taking any medications
`today that will prevent you from understanding my
`questions or answering my questions fully and
`truthfully?
`
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`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
`
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` A. No.
` Q. Have you ever been deposed before?
` A. Yes.
` Q. When was the last time?
` A. About a month back. Yeah, about a month.
` Q. A month ago from today?
` A. Yeah.
` Q. Okay. Was that for a patent case?
` A. No.
` Q. What type of case was that for?
` A. It's for a trade secret.
` Q. Okay. So some of the procedures here might
`be similar -- familiar to you. But I'd like to just
`go over some preliminary instruction --
` A. Yes.
` Q. -- before we begin.
` I will be asking questions and my questions
`and your answers will be recorded by the court
`reporter. The court reporter is recording
`everything that we say or trying to record
`everything that we say so we need to talk one person
`at a time. Okay?
` A. Yes.
` Q. I will try to wait until you finish your
`answer before asking my next question and that I ask
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
`
`8
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`you to wait until I finish my question before
`answering the questions. Okay?
` A. Yes.
` Q. Okay. That brings up another point which is
`the court reporter has -- sometimes has difficulty
`recording nods of the head or shakes of the head so
`I need you to give verbal answers to the questions.
` Do you understand?
` A. Yes.
` Q. Okay. Thank you.
` All right. If I ask you a question that you
`do not hear, please let me know and I will either
`repeat the question or have the court reporter read
`it to you again. Okay?
` A. Yes.
` Q. Okay. If I ask a question that you do not
`understand, please let me know and I will try to
`clarify the question. Okay?
` A. Okay.
` Q. All right. And if you need a break at any
`time, please let me know. I just ask that if there
`is a pending question or series of questions, I may
`ask you to answer those questions before we take the
`break. Do you understand?
` A. Yes.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
`
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` Q. All right. Did you do anything to prepare
`for the deposition today?
` A. Yes.
` Q. What did you do?
` A. I read through the declaration and all the
`documents referenced in there.
` Q. Okay. Did you meet with anyone to prepare
`for the deposition?
` A. Yes.
` Q. Who did you meet with?
` A. Tarek.
` Q. Is that Mr. Fahmi sitting next to you today?
` A. Yes.
` Q. All right. Anyone else?
` A. No.
` Q. Okay. Did you discuss the deposition with
`anyone else before today?
` A. No.
` Q. Did you discuss the deposition with anyone
`else today?
` A. No.
` Q. All right. And when did you meet with
`Mr. Fahmi?
` A. Yesterday.
` Q. For how long?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
`
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` A. About three hours.
` Q. Okay. And was anyone else there?
` A. No.
` MR. LINDENBAUM: All right. Okay. I am
`going to hand you a document that has already been
`marked as Exhibit 2001.
` (Exhibit 2001 was previously marked for
` identification and attached hereto.)
`BY MR. LINDENBAUM:
` Q. I'm going to ask you to take a look at it
`and let me know if you're familiar with this
`document.
` A. Yes.
` Q. What is this document?
` A. This is a declaration.
` Q. Okay. And did you draft this declaration?
` A. The initial draft was done by Mr. Fahmi.
` Q. Okay. And if you'd turn to page 27 of this
`declaration.
` A. Yes.
` Q. You should see, is that your signature
`there?
` A. Yes.
` Q. Okay. And did you review the declaration
`before signing this?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
`
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` A. Yes.
` Q. Okay. I will refer to this during the
`deposition as your declaration. Do you understand?
` A. Yes.
` Q. All right. And on page 27, also there is a
`date, August 15th, 2015. Is that when you signed
`the declaration?
` A. Yes.
` MR. LINDENBAUM: All right. Good. All
`right.
` I'm going to hand you another document.
`This document has already been marked as
`Exhibit 2002.
` (Exhibit 2002 was previously marked for
` identification and attached hereto.)
`BY MR. LINDENBAUM:
` Q. Are you familiar with this document?
` A. Yes.
` Q. What is this document?
` A. This is my CV.
` Q. And if I refer to this as your CV during the
`deposition, will you understand that?
` A. Yes.
` Q. All right. And I see on the first page
`under the first line under "Professional Experience"
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
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`it says, "Interim Vice-Provost" -- excuse me,
`"Interim Vice-Provost and CIO, University of
`California, Davis, California."
` Do you see that?
` A. Yes.
` Q. All right. And to the left of that it says
`2003 and then there's a dash; correct?
` A. 2013.
` Q. Excuse me. 2013, there's a dash; correct?
` A. Yes.
` Q. Okay. Did you hold that position since
`2013?
` A. No. I'm done with that.
` Q. Okay.
` A. This was a one year.
` Q. Oh, so when did that position terminate?
` A. 2014.
` Q. Do you know when in 2014?
` A. August.
` Q. August. Okay. All right.
` And then the next item under Professional
`Experience it says, "Professor, Computer Science
`Department, University of California, Davis,
`California."
` Do you see that?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
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` A. Yes.
` Q. All right. And it says that you began that
`position in 2003; correct?
` A. Yes.
` Q. Do you still hold that position?
` A. Yes.
` Q. All right. In addition to the professional
`experiences listed here, is there any other
`professional experience that you have had?
` A. Yes. This is a little bit dated. So from
`2014, after this interim role, I have been also
`serving as the Associate Chancellor of the
`university --
` DEPOSITION REPORTER: I'm sorry?
` THE WITNESS: Associate Chancellor of UC
`Davis.
`BY MR. LINDENBAUM:
` Q. Is that for the computer science department
`or for the entire university?
` A. No. It's for the entire university.
` Q. Okay. And you still hold that position?
` A. Yes.
` Q. And what is your role in that position?
` A. To assist the chancellor in special projects
`in UC Davis.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
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` Q. And what is the chancellor responsible for?
` A. The chancellor's responsibilities is
`anything and everything related to the operations of
`the university.
` Q. Okay. So it's not limited to the computer
`science department?
` A. No.
` Q. And do you still hold that position today?
` A. Yes.
` Q. And as a professor of the computer science
`department, what are your duties in that role?
` A. Three essential duties; teaching, research,
`and service.
` Q. Okay. And when you say "teaching," do you
`mean teaching courses?
` A. Teaching courses to both undergraduate and
`graduate students.
` Q. Okay. And those are computer science
`courses; correct?
` A. Yes.
` Q. And any -- do you specialize in any
`particular field of computer science?
` A. In computer networks.
` Q. So do you teach courses in computer
`networks?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
`
`
`
`Mohapatra, Prasant
`
`IPR2015-00259
`
`October 14, 2015
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` A. Mostly.
` Q. What else do you teach courses?
` A. Sometimes I've taught courses in computer
`architecture and systems and organization, computer
`systems and organization. I have also taught
`courses related to computer preferments.
` Q. Okay. And the courses related to computer
`networks, is that -- do you teach entire courses
`devoted to that subject?
` A. Can you explain what you mean by that?
` Q. So the course -- do you teach a course which
`the main focus is computer networks?
` A. Yes. Usually at the undergraduate level,
`it's a broad coverage of computer networks.
` DEPOSITION REPORTER: I'm sorry. I'm having
`trouble hearing you. Can you please move a little
`closer? I'm sorry.
` THE WITNESS: Yeah. I have been speaking
`softly.
` At the undergraduate level, the courses are
`very broad. At the graduate level, it becomes a
`little more specific.
`BY MR. LINDENBAUM:
` Q. Okay. What I'm trying to understand is when
`you say you teach courses, let's say at the
`
`202-220-4158
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`Henderson Legal Services, Inc.
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`Mohapatra, Prasant
`
`IPR2015-00259
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`October 14, 2015
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`undergraduate level concerning computer networks, do
`you teach courses that cover broad topics including
`computer networks or do you teach a course that is
`devoted exclusively to computer networks?
` A. A course that is devoted exclusively to
`computer networks.
` Q. Okay. And does that course cover
`distributed services?
` A. Yes. And just to clarify, I also taught a
`course and that's listed in there, it's introduction
`to computer science which covers a broad range,
`including computer networks.
` Q. Okay. Can you identify that for me in your
`CV?
` A. On the -- on the first page right under
`"Teaching Experience," you have the list of all the
`courses.
` Q. Yeah. Got it. Okay.
` So are those the titles of the courses?
` A. Yes.
` Q. So the first one says, "Computer Networks."
`Correct?
` A. Yes.
` Q. So you teach a course that is titled
`Computer Networks; correct?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
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`
`Mohapatra, Prasant
`
`IPR2015-00259
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`October 14, 2015
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` A. Yes.
` Q. All right. And similarly, for the graduate
`courses, you teach a course titled "Advanced
`Computer Networks." Correct?
` A. Yes.
` Q. Okay. Does the course under that Computer
`Networks also cover distributed systems?
` A. Yes.
` Q. And does the course on Wireless and Mobile
`Networks also cover distributed systems?
` A. Yes.
` Q. For the Computer Networks course, for the
`undergraduate level, have you been teaching that
`course since 2003?
` A. No. I have been teaching a similar course,
`very similar from 1992.
` Q. Okay. Were you at the University of
`California, Davis at that time?
` A. No.
` Q. Where were you teaching then?
` A. Iowa State University and then Michigan
`State University.
` Q. So have you been teaching a course
`concerning computer networks at various universities
`since 1992; is that correct?
`
`202-220-4158
`
`Henderson Legal Services, Inc.
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`Mohapatra, Prasant
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`IPR2015-00259
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`October 14, 2015
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` A. It could be prior to that. Also as a
`graduate student, sometimes we are a teaching
`assistant.
` Q. Okay. But at least since 1992?
` A. Yeah. At least since 1992.
` Q. Okay. And have you also been teaching a
`graduate course in advanced computer networks since
`1992?
` A. Since -- since 1993.
` Q. Since 1993. Okay. So -- okay.
` So if I look on the next page, I see that
`from 1999 to 2001 you were an associate professor in
`computer science in the engineering department at
`Michigan State University; correct?
` A. Yes.
` Q. So were you teaching a course in computer
`networks during that time?
` A. Yes.
` Q. At the undergraduate level?
` A. During that time, I taught both at the
`undergraduate level and the graduate level.
` Q. You taught courses in computer networks at
`the undergraduate level and at the graduate level;
`correct?
` A. Yes.
`
`202-220-4158
`
`Henderson Legal Services, Inc.
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`
`
`Mohapatra, Prasant
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`IPR2015-00259
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`October 14, 2015
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` Q. And did both of those courses cover
`distributed systems?
` A. Yes.
` Q. Okay. If you turn to page 4 of your CV --
`excuse me, page 3. There is a section titled
`"Litigation Related Consulting."
` Do you see that?
` A. Yes.
` Q. I see that goes until -- it indicates dates
`from 2012 to 2013; is that correct?
` A. Yes.
` Q. Have you had additional litigated-related
`consulting engagements since the most recent matter
`on this page?
` A. Yes.
` Q. How many, would you say?
` A. My guess would be at least around five or
`so.
` Q. Okay. And would all of those be related to
`patents?
` A. Excluding one.
` Q. So you've had approximately four
`additional -- you have been retained --
` A. Somewhere between four to six --
` Q. Four to six.
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`Mohapatra, Prasant
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`IPR2015-00259
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`October 14, 2015
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` A. -- that is patent and one trade secret.
` Q. Okay. All right. And I see on this page
`the second item says, "Patent infringement case
`between Ruckus Wireless and Netgear, Topic:
`Wireless Mesh Network, 2013 (Gave deposition)."
` Do you see that?
` A. Yes.
` Q. Okay. Did you give a deposition in that
`matter?
` A. Yes.
` Q. Okay. Was the deposition given in 2013?
` A. Yes.
` Q. I notice that none of the other matters on
`here state "gave deposition." Is that correct?
` A. None listed in here. But beyond that, I
`have given at least three to five more depositions.
` Q. Okay. But in terms of the matters that are
`listed here, did you give depositions in any of the
`other matters other than the one that indicates
`"gave deposition"?
` A. No.
` Q. Okay. So the three to five additional
`depositions that you gave were given in matters
`since 2013; is that correct?
` A. Yes.
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` Q. Okay. And how many of those were -- were
`all of those in the patent cases -- oh, and you said
`one was given during the trade secret; correct?
` A. One, yeah. Yes.
` Q. All right. So you gave three to five
`depositions in addition to the one listed here, one
`of which was in the trade secret case; correct?
` A. Right.
` Q. All right. Okay. If you turn to page 4,
`you will see a section entitled "Grants and
`Contracts."
` Do you see that?
` A. Yes.
` Q. Okay. And it goes up to number 63. Do you
`see that?
` A. Yes.
` Q. Have there been a number of additional
`grants and contracts since is this CV was prepared?
` A. At least one more.
` Q. Okay.
` A. Yeah.
` Q. And then if we turn to -- let's see, page 8.
`Do you see there is a section titled "Patents."
` Do you see that?
` A. Yes.
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` Q. And I note there are four items there;
`correct?
` A. Yes.
` Q. Okay. And the first three are patents
`pending; correct?
` A. The one listed as No. 2, that has been
`granted.
` Q. Okay. And for No. 3, is that still pending?
` A. Yes.
` Q. And for No. 4, is that still pending?
` A. Yes.
` Q. Okay. Do you have any other U.S. patents,
`applications currently pending?
` A. One more.
` Q. Okay. Is it related to any of the patents
`that are listed here?
` A. No.
` Q. Was it filed after this CV was prepared?
` A. Yes.
` Q. Okay. And what is the subject of that
`application?
` A. It is securities within mobile devices.
` Q. And for the U.S. patent -- so the number 2
`that you noted you said was granted; correct?
` A. Yes.
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` Q. Do you know when that was granted?
` A. I think sometime beginning of 2015.
` Q. Okay. Do you know if it's been licensed to
`anyone?
` A. I don't know.
` Q. You don't know?
` A. No.
` Q. Do you own the patent?
` A. The patent is owned by the university, all
`of the patent.
` Q. All of the patents and patent applications
`are owned by the university?
` A. Yes.
` Q. Okay. For the patent No. 6,466,978 which is
`indicated as item 1 in this section. Do you see
`that?
` A. Yes.
` Q. Has that patent been licensed to anyone?
` A. That patent is owned by Panasonic
`Technologies. And I wouldn't know if it has been
`licensed.
` Q. Okay. And if you look under the section,
`the next section which is "Technical Publications."
` Do you see that?
` A. Yes.
`
`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`Mohapatra, Prasant
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` Q. It says -- the first subsection says, "Books
`and Book Chapters."
` Do you see that?
` A. Yes.
` Q. And there are six items listed there;
`correct?
` A. Yes.
` Q. Have you authored any additional books or
`book chapters since this CV was prepared?
` A. No.
` Q. All right. And the next subsection says
`"Journal Papers."
` Do you see that?
` A. Yes.
` Q. And I see that there are 84 items listed;
`correct?
` A. Yes.
` Q. Have you prepared any additional journal
`papers since this CV was prepared?
` A. Yes.
` Q. How many, would you say?
` A. At least ten more.
` Q. Okay. All right. And if you turn to page
`15.
` A. Yes.
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`Henderson Legal Services, Inc.
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` Q. You see there's a subsection titled
`"Conference Papers." Correct?
` A. Yes.
` Q. All right. And it looks like there are 183
`items listed in this subsection; correct?
` A. Yes.
` Q. Have there been any additional conference
`papers since this CV was prepared?
` A. Yes.
` Q. How many, would you say?
` A. At least 25 more.
` Q. 25 more. All right. And then if you turn
`to page 27.
` A. Yes.
` Q. You'll see that there is a subsection titled
`"Tutorials"?
` A. Yes.
` Q. And there are 22 items listed in that
`subsection; correct?
` A. Yes.
` Q. Have there been any additional tutorials
`since this CV was prepared?
` A. No.
` Q. Okay. And the next subsection is on the
`next page, it says, "Keynote Addresses and
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`Mohapatra, Prasant
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`Distinguished Lectures." Correct?
` A. Yes.
` Q. And there are 13 items listed in that
`subsection; correct?
` A. Yes.
` Q. Have there been any additional keynote
`addresses or distinguished lectures since this CV
`was prepared?
` A. At least five more.
` Q. Okay. All right. And then if you turn
`to page 29, there is a subsection titled "Invited
`Talks/Panels."
` Do you see that?
` A. Yes.
` Q. And there are 96 items listed there. Do you
`see that?
` A. Yes. Yes.
` Q. Okay. Have there been any additional
`invited talks or panels since this CV was prepared?
` A. At least five more.
` Q. Okay. And if you turn to page 35. There is
`a subsection titled "Graduate Students."
` Do you see that?
` A. Yes.
` Q. And then the section under that it says,
`
`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`Mohapatra, Prasant
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`"Doctoral Dissertations." Correct?
` A. Yes.
` Q. What is included in that section?
` A. The number of students that have received a
`Ph.D. under my guidance.
` Q. Okay. And have there been any additional
`such students since this CV was prepared?
` A. Five more.
` Q. Okay. And the same question with respect to
`"Master Degree Theses" on the next page.
` A. Yes.
` Q. How many additional students have received
`master degree theses under your guidance since this
`CV was prepared?
` A. One more.
` Q. Okay. And then if I turn to page 37,
`there's a section that says, "Currently Under
`Supervision."
` Do you see that?
` A. Yes.
` Q. Is that list current?
` A. No.
` Q. Okay. Are any of those students currently
`under your supervision?
` A. Most of them.
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` Q. Most of them are.
` A. Yeah.
` Q. Okay. All right. Okay.
` And if we turn to the next page, page 38,
`you see it says, "Professional Activities"?
` A. Yes.
` Q. And the first line says, "Editor-in-Chief
`IEEE Transactions on Mobile Computing, 2014," and
`then there's a dash.
` Do you see that?
` A. Yes.
` Q. Do you still hold that position?
` A. Yes.
` Q. All right. Are there any other professional
`activities that you have been engaged in since this
`CV was prepared other than the ones that are listed?
` A. No.
` Q. All right. If you turn back to page 3
`again. I just have a general question.
` A. Yes.
` Q. You said there were four to six additional
`litigations; correct?
` A. Yes.
` Q. Okay. Were those -- how many of those were
`pending in 2014?
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`Mohapatra, Prasant
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` A. I don't know.
` Q. Was there at least one pending in 2014?
` A. What exactly do you mean by "pending"?
` Q. When were you engaged to work on it? About
`what time period?
` A. 2014 and 2015.
` Q. Okay. And on page 8, on the section titled
`"Journal Papers," you said there are approximately
`ten more since this CV was prepared; correct?
` A. Yes.
` Q. Okay. And were those published in 2014 and
`2015?
` A. Either published or accepted for
`publication.
` Q. In 2014 and 2015; correct?
` DEPOSITION REPORTER: I'm sorry, "Either
`published or accepted"?
` THE WITNESS: Or accepted for publication.
`BY MR. LINDENBAUM:
` Q. I'm just trying to get a timeframe. Is that
`in 2014 and in 2015; is that correct?
` A. Right.
` Q. Okay. And on page 15, there was a section
`titled "Conference Papers."
` A. Yes.
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`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`Mohapatra, Prasant
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`IPR2015-00259
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` Q. And you said 25 since -- approximately since
`this CV was prepared; correct?
` A. Yes.
` Q. And those were presented in 2014 and 2015;
`correct?
` A. Yeah. Yes.
` Q. And the "Keynote Addresses and Distinguished
`Lectures" on page 28.
` A. Yes.
` Q. Those are in 2014 and 2015; correct?
` A. Yes.
` MR. LINDENBAUM: All right. I'm going to
`hand you a document that has been previously marked
`as Exhibit 1001.
` (Exhibit 1001 was previously marked for
` identification and attached hereto.)
`BY MR. LINDENBAUM:
` Q. Do you recognize this document?
` A. Yes.
` Q. And did you review this document before
`preparing your declaration?
` A. Yes.
` Q. And do you see in the top right corner on
`the first page is a patent number. Do you see that?
` A. Yes.
`
`202-220-4158
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`Henderson Legal Services, Inc.
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` Q. And it says U.S. 7,191,233 B2; correct?
` A. Yes.
` Q. Okay. And if I refer to this as the '233
`patent, will you understand what I'm referring to?
` A. Yes.
` Q. I'd like you to turn to your declaration,
`which was Exhibit 2001. Do you have that in front
`of you?
` A. Yes.
` Q. All right. And if you look on page 4,
`there's a paragraph numbered 11 that begins towards
`the bottom of the page.
` A. Yes.
` Q. Do you see that? Okay.
` And on the very last line it says, "Based on
`my experience." There is a sentence that begins,
`"Based on my experience."
` A. Yes.
` Q. Do you see that?
` A. Yes.
` Q. And that sentence describes what you
`understand to be a person of skill in the art;
`correct?
` A. Yes.
` Q. Is that still your understanding of a person
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`202-220-4158
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`Henderson Legal Services, Inc.
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`of skill in the art?
` A. Yes.
` Q. All right. And you note that the person
`would have a bachelor of science degree in computer
`science or computer engineering; correct?
` A. Yes.
` Q. With approximately two years of practical
`work experience or postgraduate research in a field
`such as computer networking and/or distributed
`systems; correct?
` A. Yes.
` Q. Okay. In terms of the postgraduate research
`in a field such as computer networking and/or
`distributed systems --
` A. Yes.
` Q. -- how much postgraduate research would you
`expect a person of skill in the art to have in those
`fields?
` A. Something equivalent to a master's degree.
` Q. A master's degree?
` A. Yeah.
` MR. LINDENBAUM: Okay. I'm going to hand
`you another document. This document has been
`designated as Paper 8.
` (Paper 8 was previously marked for
`
`202-220-4158
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`Henderson Legal Services, Inc.
`www.hendersonlegalservices.com
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`
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`Mohapatra, Prasant
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` identification and attached hereto.)
`BY MR. LINDENBAUM:
` Q. It says "Paper 8" in the top right corner;
`correct?
` A. Yes.
` Q. And did you review this document --
` A. Yes.
` Q. -- before preparing your declaration?
` A. Yes.
` Q. All right. Okay. And if you turn to
`page 7, you'll see that there is a table in the
`middle of the page.
` Do you see that?
` A. Yes.
` Q. And the left column says, "Claim Term."
`Correct?
` A. Yes.
` Q. And the right column says, "Interpretation."
`Correct?
` A. Yes.
` Q. And in the last row, you see the claim term
`is listed as "session." Do you see that?
` A. Yes.
` Q. And
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