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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Page 1
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`SONY COMPUTER )
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`ENTERTAINMENT AMERICA )
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`LLC, )
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` Petitioner, )
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` v. ) CASE NO.: IPR2015-00396
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`APLIX IP HOLDINGS ) IPR2015-00476
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`CORPORATION, ) IPR2015-00533
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` Patent Owner. )
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` )
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` ) DEPOSITION OF KARON
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` ) MACLEAN, VANCOUVER BRITISH
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` ) COLUMBIA NOVEMBER 20 & 21,
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` ) 2015
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`
`
` The discovery deposition of KARON MACLEAN, taken in
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`the above-entitled cause, before Spencer J. Charest, BCSRA
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`No.429, Official reporter, on the 20th and 21st of
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`November, 2015, at 1253 Johnston Street, Vancouver, B.C.
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`SCEA Ex. 1037 Page 1
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`
`
`KARON MACLEAN 11/20/2015
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`Page 2
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`APPEARANCES:
`
` ERISE IP
`
` 5600 Greenwood Plaza Blvd.
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` Suite 200
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` Greenwood Village, CO 80111
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` (720) 689-5440
`
` BY: MR. ABRAN KEAN.
`
` On behalf of the Petitioner;
`
` GREEN ESPEL PLLP
`
` 222 SOUTH NINTH STREET
`
` SUITE 2200
`
` MINNEAPOLIS, MINNESOTA 55402
`
` BY: ROBERT J. GILBERTSON,
`
` On behalf of the Patent Owner.
`
` ALSO PRESENT: CALLIE PENDERGRASS,
`
` SENIOR TECHNICAL ADVISOR
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`MIDWEST LITIGATION SERVICES
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`Fax: 314.644.1334
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`SCEA Ex. 1037 Page 2
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`
`
`KARON MACLEAN 11/20/2015
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` I N D E X
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` INDEX OF EXAMINATIONS
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`EXAMINATION PAGE.
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`Page 3
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`Examination of Karen MacLean by Mr. Kean 4
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`Examination of Karon Maclean by Mr. Gilbertson 267
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` E X H I B I T S
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`NUMBER DESCRIPTION PAGE
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`Exhibit 1027 Photocopy of hand-drawn
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` illustration by Ms. Maclean 188
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`Exhibit 1028 Itaya et al., patent of input
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` system including resistance film
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` touch panel and pushed position
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` detecting device 222
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`Exhibit 1029 Press release for the FingerWorks
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` iGesture Pad 236
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`Exhibit 1030 Article from the New York Times
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` dated January 24th, 2002 246
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`Exhibit 1031 Document entitled "A Multi-Touch
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` Three-Dimensional Touch Sensitive
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` Tablet" 261
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`Fax: 314.644.1334
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`SCEA Ex. 1037 Page 3
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`
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`KARON MACLEAN 11/20/2015
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` EXAMINATION BY
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`MR. KEAN:
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` Q. Will you state your name for the record, please.
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` A. Karen MacLean.
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` Q. And, Dr. MacLean, the same ground rules from the
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`other day are going to apply on today's deposition. So
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`verbal answers, please. I will try not to speak over you.
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`If you want to break at any time just let me know and we
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`can take a break.
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` A. Okay. Thanks.
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` Q. One thing that came up the other day is you
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`mentioned at some point you were feeling kind of tired?
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` A. M'mm-hmm.
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` Q. If that happens today we can certainly take a
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`break whenever you would like.
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` A. Yes.
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` Q. If you answer my questions I'm going to assume
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`that you're able to answer them fully and honestly. Is
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`that fair?
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` A. Yes, and I will be clear when I want a break.
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` Q. Okay. Very good. Today's deposition is going to
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`cover opinions you offered in declarations in three
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`proceedings. The first is IPR2015-00396, and I'm going to
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`refer to that today as the 00396 proceeding. Would you
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`understand what I'm talking about?
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`SCEA Ex. 1037 Page 4
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`KARON MACLEAN 11/20/2015
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`Page 5
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` A. Yes.
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` MR. GILBERTSON: Can I interject on that.
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` MR. KEAN: Sure thing.
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` MR. GILBERTSON: Here on the record. One thing
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`we did in an earlier deposition that I think was helpful
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`is to ask that in the reporting of the deposition when 396
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`is used as a shorthand that it be typed as 00396, and when
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`533 is used, 00533, and when 476 is used, 00476. So that
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`even if the words that come out of our mouth are 476 it
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`will be helpful for the judges to have it say 00476. This
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`is because we refer to patent numbers with just three
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`digits very often but what we're referring to with 00396,
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`00533 and 00476 is not patent numbers, but action numbers.
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`So if the court reporter is amenable to that and if all
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`the parties are I would like to make that request.
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` MR. KEAN: I think that's a good idea and a
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`helpful way to structure this.
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` (DISCUSSION OFF THE RECORD)
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` MR. KEAN:
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` Q. Okay. Dr. MacLean, I'm going to hand you what
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`has previously been marked 2007 in the 00396 proceeding.
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` A. Okay.
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` Q. Please turn with me to the last page of that
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`document and confirm that that's your signature?
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` A. Yes, that's my signature.
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`SCEA Ex. 1037 Page 5
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`KARON MACLEAN 11/20/2015
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`Page 6
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` Q. Before we get started today on your declarations,
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`is there any changes or corrections that you need to make
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`this to declaration?
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` A. Not to this declaration. There will be a small
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`change -- or clarification to a later one.
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` Q. Okay. If you turn to pages 8 through 10 in this
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`document, it's a list of exhibits analyzed.
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` A. M'mm-hmm. Yes.
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` Q. Will you confirm that you analyzed fully each of
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`the documents listed here?
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` MR. GILBERTSON: Objection to the form as to the
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`word "fully."
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` THE WITNESS: I have read all of the exhibits
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`listed here.
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` MR. KEAN:
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` Q. Are there any documents that you reviewed in
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`preparing your opinion that are not listed here?
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` A. I would say not extensively. I certainly did
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`broader research than this, but these were the ones that I
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`thought were worth putting in as exhibits.
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` Q. The second proceeding we're going to be
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`discussing today is IPR2015-00476 and I will be referring
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`to that today as the 00476 proceeding. Will you
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`understand what I'm referring to?
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` A. Yes.
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
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`SCEA Ex. 1037 Page 6
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`
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`KARON MACLEAN 11/20/2015
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`Page 7
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` Q. And I'm going to hand you what has been marked as
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`Exhibit 2007 in that proceeding, that proceeding being the
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`00476 proceeding. And I'm going to ask you the same set
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`of questions. First, would you confirm that that's your
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`signature on the last page of the document.
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` A. Yes, this is my signature.
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` Q. Do you need to make any corrections or changes to
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`your opinions offered in this document?
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` A. I am going to take a moment to make sure of which
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`of these three I had a small clarification on, because I'm
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`not seeing my notes where I thought they were. Just give
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`me just a moment.
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` I would like to correct what I said about the
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`00396 declaration because that is the one that I had a
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`problem with and I thought it was a later one. Sorry
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`about that. Should I go ahead and say what that problem
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`is?
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` Q. Yes.
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` A. So it's on the exhibits listed. Sorry for not
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`catching this. So on page 8 of the 00396 declaration
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`Exhibit 1009 is erroneously listed as patent number
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`7336260 to Martin et al, and it should say Martin 6563487,
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`which is the one that is the correct exhibit to be using
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`here.
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` Q. Okay. And so you're just correcting --
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`SCEA Ex. 1037 Page 7
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`KARON MACLEAN 11/20/2015
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` A. The only error is in the exhibit listing. I
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`am -- in the declaration itself I am referring to the
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`Page 8
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`487 -- Martin 487.
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` Q. Okay.
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` A. So it's simply a typographical error in the list
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`of exhibits.
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` Q. Sure thing. Thank you. Is that a typographical
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`error that also appears in the 00476 declaration?
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` A. No, because Martin does not show up. So what it
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`was is there is two Martin references that come up in
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`these larger proceedings and they got switched in the
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`exhibit list, but neither Martin is listed in the other
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`ones.
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` Q. Okay.
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` A. So it was limited to this location.
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` Q. Thank you. Are there any other changes or
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`corrections you would like to make to either the 00396 or
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`the 00476 declaration?
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` A. No. I did discover a few typos here and there
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`but I don't think anything that's of significance to the
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`proceedings.
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` Q. Thank you. And would you confirm in the 00476
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`declaration, would you look at the exhibits analyzed there
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`and confirm that you reviewed those documents. It's on
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`pages 8 through 10.
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`MIDWEST LITIGATION SERVICES
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`Fax: 314.644.1334
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`SCEA Ex. 1037 Page 8
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`KARON MACLEAN 11/20/2015
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`Page 9
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` A. Yes, I have read all these exhibits.
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` Q. Are there any other documents that you reviewed
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`in preparing your opinions here that are not listed?
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` A. Yes, I did look at a larger group of documents,
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`but these are the ones I thought were important to bring
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`forward.
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` Q. What other type of documents did you look at?
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` A. Well, for example, when I -- there's a few cases
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`where I have listed academic papers, and in choosing the
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`academic papers that I wanted to represent here I looked
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`at a larger set and I choose representative ones.
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` Q. Anything else?
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` A. I looked on the web for different mentions and
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`articles and things like that. So I did research, and as
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`usual when you do research, you look at a large set of
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`information and narrow it down to the most relevant items.
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` Q. So is it fair to say that the exhibits listed
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`here are what you viewed as the most relevant documents to
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`your opinion?
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` A. Yes.
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` Q. Okay. I'm going to hand you your third
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`declaration that's relevant today. It's also
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`Exhibit 2007, and this one is for the 00533 proceeding.
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` A. Okay.
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` Q. And the same set of questions. Will you please
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`SCEA Ex. 1037 Page 9
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`KARON MACLEAN 11/20/2015
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`Page 10
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`confirm your signature is on the last page of this
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`declaration.
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` A. Yes, my signature is on the last page.
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` Q. All right. And have any of your opinions in this
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`declaration changed or do you require any corrections?
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` A. No, no corrections on this one.
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` Q. And if you turn with me to pages 8 through 10 of
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`this document, will you confirm that you reviewed the
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`exhibits listed here.
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` A. Yes, I have read all of these exhibits.
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` Q. And once again, are there any other exhibits that
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`you reviewed in preparing your opinions that are included
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`in this document that are not listed here?
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` A. Same answer as before, which I did my broader
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`research and then choose these as the most representative
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`and relevant.
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` Q. Okay. Before we get started on specific opinions
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`today I want to try to understand your analysis in forming
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`your opinions a little bit. Is it fair to say that you
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`performed the same analysis for each of the references and
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`each of the opinions you offered?
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` A. By references you mean the other patents brought
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`to play, for example, Pallakoff would be an example of
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`what you mean by a reference?
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` Q. That's right?
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`www.midwestlitigation.com
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`SCEA Ex. 1037 Page 10
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`KARON MACLEAN 11/20/2015
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`Page 11
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` A. Yes. Yes, I did comparable methods to my
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`research in all cases.
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` Q. And that would also be true for the 245 and 692
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`proceedings that we discussed earlier this week?
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` A. That's correct.
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` Q. What is your understanding of a person having
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`ordinary skill in the art?
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` A. A general definition or the specific
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`interpretation with respect to this case?
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` Q. You know, I would like to do both, but first I
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`would like to understand your understanding of what a
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`person of ordinary skill in the art is and why that
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`matters to an obviousness analysis.
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` A. Well, I will refer to the definition that I was
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`given for it to work with in this case, and that's in my
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`declaration. Level of skill in the art, for example, in
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`the 00476 declaration, which is the one I had open here,
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`it's the same in all three of them. On page 13,
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`paragraph 30 it says "I am" -- whoops, that's level of
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`skill in the art. Yes. "Obviousness is to be judged from
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`the perspective of a person of ordinary skill, not the
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`perspective of an expert. Even if the invention would
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`have been obvious to the brightest minds in the field that
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`does not render it unpatentable. I understand that highly
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`educated and trained individuals know more and thus more
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`www.midwestlitigation.com
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`SCEA Ex. 1037 Page 11
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`KARON MACLEAN 11/20/2015
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`Page 12
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`inventions are obvious to them. On the other hand,
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`individuals with little education or training would have
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`more difficulty in making connections and therefore fewer
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`inventions would be obvious to them."
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` So this is how I was instructed to interpret this
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`concept and that's what I did.
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` Q. Are you aware that a person having ordinary skill
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`in the art is an objective concept?
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` A. By objective concept you mean it could be
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`precisely defined or what -- I'm not quite sure what you
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`mean by objective in this context.
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` Q. Sure. Are you aware that a person having
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`ordinary skill in the art is not -- it's not a subjective
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`perspective, it's an objective perspective from --
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` A. M'mm-hmm.
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` Q. -- someone that would have a certain level of
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`education and experience?
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` A. I understand that there's a lot of guidance in
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`this description to assess that, but I would also infer
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`that there needs to be some interpretation of a particular
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`concept about what skill in the art is referring to in
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`this particular case. I mean, depending on the -- a
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`discipline has to be stated, for example, before you can
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`nail it down more precisely.
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` I'm not sure I'm completely understanding your
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`www.midwestlitigation.com
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`SCEA Ex. 1037 Page 12
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`KARON MACLEAN 11/20/2015
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`Page 13
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`question. As an objective con -- I understand that there
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`is a way that it can be interpreted. There's lots of
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`instruction here. But it will have to be interpreted in
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`the context of the discipline and the case and the
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`situation. That seems obvious to me.
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` So if some subjectivity would come into it, I
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`hope not. For example, I believe that my colleagues and I
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`would probably come to the same definition of it -- the
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`same interpretation of it in a given case, if that's what
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`you mean.
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` Q. And when you say the same interpretation of it,
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`what are you referring to there?
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` A. Well, later in my declaration I was asked to
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`define what level of skill in the art meant in this
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`particular context, so that would be what I'm referring
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`to.
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` Q. Are you aware that a person having ordinary skill
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`in the art is supposed to approach problems with some
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`level of creativity and commonsense?
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` A. Some level, yes.
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` Q. What's your understanding of "some level"?
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` A. Well, the level that would come based on the
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`training and knowledge you had, but also the kinds of
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`problems that have been put before you. And I have taught
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`quite a few students in my career and worked with
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`MIDWEST LITIGATION SERVICES
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`SCEA Ex. 1037 Page 13
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`
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`KARON MACLEAN 11/20/2015
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`Page 14
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`graduates and I think I understand the range of creativity
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`that a typical person in this area would have at a certain
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`level of training and experience.
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` So there will be some, and it varies from
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`individual to individual, and I think we're talking about
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`an average level of creativity and skill.
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` Q. In performing your analysis did you assume a
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`person having ordinary skill in the art would have some
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`creativity and commonsense in evaluating whether or not it
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`was obvious to combine references?
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` A. Absolutely, yes.
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` Q. Who would qualify as a person having ordinary
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`skill in the art for these three proceedings in your
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`opinion?
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` A. So this was section C in all three petitions. So
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`again I'm looking at the 00476, somewhat arbitrary
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`selection of the three, and in this one it's paragraph 52,
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`page 23.
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` And in this definition I largely agree with the
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`definition provided by Dr. Welch. So there's some
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`objectivity for you. We both came to large agreement.
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` My one difference from Dr. Welch's opinion was to
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`actually broaden the level of background training that an
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`opinion of skill in the area of user interface design in
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`particular handheld design would have. He mentioned
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`SCEA Ex. 1037 Page 14
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`
`
`KARON MACLEAN 11/20/2015
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`Page 15
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`computer science and I said as well mechanical,
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`biomechanical, industrial engineering, not just electrical
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`engineering, computer science or computer engineering
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`which is what he mentioned. So I actually broadened the
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`definition of where a person might get their expertise
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`from.
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` Q. Why did you broaden it in that way?
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` A. Well, for one thing, that's what my background is
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`in so I do include myself in this definition. And at the
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`time -- at the phase of my career where I would have met
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`this definition, my background was in mechanical
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`engineering and I feel that I met the definition. And I
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`have taught many people who come from diverse backgrounds.
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`You do not need a computer science background to be
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`practising in human/computer interaction.
`
` Q. Let's discuss your background for a moment.
`
`Would you describe, after high school, your educational
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`background.
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` A. Certainly. I went to Stanford University for my
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`undergrad and I majored in both biological sciences and
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`mechanical engineering in the state for a second degree.
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`My first intent had been to go to medical school and so I
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`took a lot of biology and premedical sources which got me
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`very interested in biomechanics and biology and
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`physiology. But I wanted to build things, so I turned to
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
`
`SCEA Ex. 1037 Page 15
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`
`
`KARON MACLEAN 11/20/2015
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`Page 16
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`mechanical engineering.
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` Then I went to MIT for my master's and ended up
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`because of my joint interest in biomechanics and biology
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`and physiology and engineering, I landed in a biomechanics
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`lab at Massachusetts Institute of Technology in the
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`mechanical engineering department.
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` And there I was exposed to people working on many
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`biomechanics problems and I -- that is where I started
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`working on haptics actually in my PhD degree.
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` So I finished my master's. I worked as a robotics
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`engineer in Utah for two years, and then I returned to MIT
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`for my PhD. And at that time, that was in 1990, the field
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`of haptics did not really exist, but the lab that I was in
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`at MIT was very strong in teleoperation, as had been the
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`robotics lab I worked in Utah. Probably the world leaders
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`in that area. And that we were starting to experiment
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`with virtual environments -- teleroboted environments that
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`people could interact with, which were the very first
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`haptic interfaces. So I was part of the first haptic
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`interfaces that were ever built. And interacted with
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`those people and I started working on that area too.
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` So that's what my PhD involved. And then I worked
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`in Silicon Valley from 1996 to 2000 and I was a member of
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`a research staff of a place called Interval Research. At
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`that point we were -- that's where I was really exposed to
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`SCEA Ex. 1037 Page 16
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`
`
`KARON MACLEAN 11/20/2015
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`Page 17
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`the human/computer interaction side of things where I was
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`hired to do human/computer interaction because it was felt
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`that that's what I was practising. And I worked with
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`other people who were seminal inventors in that area and
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`lived in Silicon Valley at that time. And then I was
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`hired by UBC, my present employer, to start their HCI
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`curriculum and program to be the primary HCI faculty in
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`their department. And I have continued to do that since.
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` Q. I believe you mentioned your work with haptic
`
`interfaces. Would you describe that in a little more
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`detail, please.
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` A. What haptic interfaces are, is that your
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`question?
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` Q. Yes.
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` A. Yes. Starting in the early 90s when I started
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`working on them we actually didn't call them haptic
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`interfaces. My first term for it was kinesthetic
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`interfaces. And they were simply robots that interacted
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`with people instead of pushing things or pushing things
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`around or moving in the air.
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` And so we had to learn a great deal about people
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`and people's responses to them and people's perception of
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`them in order to do that well, and this wasn't very
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`well-known at the time. And so it was an advantage in
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`this period, and it still is an advantage, to know a
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`www.midwestlitigation.com
`
`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`SCEA Ex. 1037 Page 17
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`
`
`KARON MACLEAN 11/20/2015
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`Page 18
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`certain amount of human physiology and human perception
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`and to know about doing experiments on people, because it
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`is hard to build the machines without the knowledge of the
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`people and the interaction.
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` So haptic interfaces started primarily as -- at
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`least at that time in that way, as force feedback devices.
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`So we were interacting with forces. And then it turned
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`more and more towards there was more and more study of
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`vibrotactile interfaces simply because they're much easier
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`to construct and easier to embed into devices, for
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`example, portable devices, because they don't need to be
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`grounded, they don't need to have reaction forces, and
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`they can actually be inserted into a device.
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` But understanding how people perceive the haptic
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`feedback, the vibrotactile feedback, was actually a very
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`different kind of problem than trying to understand how
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`people would perceive and interpret force feedback, which
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`is more similar to what they feel in the real world.
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` With vibrotactile feedback we are making synthetic
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`sensations that people are not used to perceiving and it
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`was a new concept that we had to teach to people and
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`understand their perception of it.
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` So a great deal of my research has focussed on this
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`understanding -- this creating and designing sensations
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`that people understand and also putting -- situating them
`
`www.midwestlitigation.com
`
`MIDWEST LITIGATION SERVICES
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`Fax: 314.644.1334
`
`SCEA Ex. 1037 Page 18
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`
`KARON MACLEAN 11/20/2015
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`Page 19
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`on devices and looking at the interaction techniques for
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`people to make use of them.
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` Q. Would you consider yourself an expert in
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`software?
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` A. I would not call myself an expert in software
`
`compared to my colleagues who are software engineers. I
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`have written a lot of code and writing code is part of
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`what I do. And my students are very expert in writing
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`software. Some of them are software engineers. We
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`produced very advanced code in my lab, for example. I
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`would not call myself at the forefront. It is not what my
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`research is.
`
` Q. In your experience and understanding would an
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`operating system include software?
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` A. An operating system is made of software.
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` Q. In your experience and understanding would
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`firmware include software?
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` A. Firmware does include software. It is also made
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`of software.
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` Q. And in your experience and understanding would
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`applications or programs be written with software?
`
` A. Yes.
`
` Q. If something was written in software -- let me
`
`rephrase that.
`
` If a functionality was written in software would
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`SCEA Ex. 1037 Page 19
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`KARON MACLEAN 11/20/2015
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`Page 20
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`that fact that it was in software give you any indication
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`as to whether or not it was an operating system-level
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`software program, a firmware software program or an
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`application-level software program?
`
` A. I'm going to try and rephrase your question to
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`make sure I understood it.
`
` Q. Sure.
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` A. I think you said that simply the fact that
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`something is represented in code in software, would that
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`give any clue -- just the fact of it being software, would
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`that give any clue whether it's firmware, operating system
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`or application level?
`
` Q. Yeah. That's generally what I'm trying to get
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`at, yes.
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` A. All of those things are written in software so
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`no, but the software might look very different for each of
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`them.
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` Q. How would it look different?
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` A. That depends. It will depend a great deal
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`depending on the kind of device, the kind of operating
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`system, the level of operating system and what its primary
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`purpose and function is. And not all systems have
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`firmware, for example, so some of these levels might
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`actually be absent.
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` A very primitive microprocessor doesn't have an
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`SCEA Ex. 1037 Page 20
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`KARON MACLEAN 11/20/2015
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`Page 21
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`operating system. You know, it might only have the
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`firmware. So what is even present will maybe be different
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`depending on the system and what it looks like and how
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`sophisticated it is.
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` For example, something that I have worked a lot
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`with is a real-time operating system where very low
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`latency is required and a very quick response time, and
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`that kind of operating system looks fairly different and
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`different specifications than, for example, a Windows
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`operating system which doesn't have those requirements.
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`It would be special purpose operating systems.
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` Q. So just the fact that something is written in
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`software would not signal to a person having ordinary
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`skill in the art that it needs to be done in the operating
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`system level; is that right?
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` A. Not just mentioning -- applying the word
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`"software" to it is not very specific. It's a broad term.
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` Q. Likewise, just the fact that something is written
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`in software would not signal to a person having ordinary
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`skill in the art that it needs to be done at the
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`application level; is that right?
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` A. Not generally. No. There could be a context in
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`a statement or statement that gave more insight into that,
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`but not standing alone.
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` Q. Looking back at paragraph 52 where you define the
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`SCEA Ex. 1037 Page 21
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`KARON MACLEAN 11/20/2015
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`Page 22
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`level of skill in the art for these three proceedings, in
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`addition to expanding the -- well, let me ask you this.
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`Is it your understanding if someone had a biomechanical or
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`an industrial engineering degree that they would also need
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`to have some type of ability or facility with software and
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`computers in order to be a person of skill in the art in
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`this case?
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` A. You said "also." Very frequently, but I will
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`agree not in every case that comes automatically with it.
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`It's rare even at this time, in the early 2000s, it would
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`be rare to not have a pretty good -- it's very difficult
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`to get through school, I think, as requirement of all of
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`these programs that I have ever seen to have a certain
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`amount of software ability.
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` I would expect there to be more software
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`experience in a computer science degree. I would
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`certainly hope so. But there's usually quite a lot and
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`sometimes an enormous amount in the other degree programs.
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` So I did not feel it needed to be stated
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`separately, but I -- I will acknowledge that you could
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`certainly find some graduates of such programs who perhaps
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`have less than I would want to see here. It would be
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`unusual.
`
` Q. In this paragraph you go on to discuss what you
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`quote as designed for human use in quotes in your
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`SCEA Ex. 1037 Page 22
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`KARON MACLEAN 11/20/2015
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`Page 23
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`definition. Do you see that?
`
` A. M'mm-hmm.
`
` Q. What do you mean by that?
`
` A. And this indeed is what I was focussing on more
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`strongly in my definition of skill in the art more than
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`the ability to write software or be familiar with
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`software.
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` Designed for human use is not easy, and in my
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`belief it's better done with training. It's not something
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`that you necessarily will do a good job in without
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`training, any more than you could design an electrical
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`circuit without some educational training in it.
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` So what I mean by designing for human use
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`principles of design, understanding basic tenets of human
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`perception and how people, for example, tend to solve
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`problems, how people tend to -- if you're designing for
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`physical objects, how people tend to grasp things and
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`basic biomechanical understanding of grasp. How people
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`interpret things that they see.
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` For example, an introductory human/computer
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`interaction class will include some basic perception like
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`basic principles of visual perception. Both techniques of
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`evaluation, simple user-centered evaluation, and design
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`principles of how you go about designing things, both
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`principles for designing things that are going to be
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`SCEA Ex. 1037 Page 23
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`KARON MACLEAN 11/20/2015
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`Pa