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` IN THE 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 ENTERTAINMENT
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` AMERICA LLC,
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` Petitioner,
`
` -vs- Case No. IPR2015-00230
`
` Patent No. 7,463,245
`
` APLIX IP HOLDINGS CORPORATION,
`
` Patent Owner.
`
`
`
` DEPOSITION OF PENG LIM
`
` PALO ALTO, CALIFORNIA
`
` WEDNESDAY, OCTOBER 28, 2015
`
`
`
` Reported by: LOUISE MARIE SOUSOURES, CSR NO. 3575
`
` Certified LiveNote Reporter
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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. 1041 Page 1
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`
`
`PENG LIM 10/28/2015
`
`Page 2
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` Deposition of PENG LIM, taken on behalf of the
`
` Petitioner, before Louise Marie Sousoures, a Certified
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` Shorthand Reporter and a Certified LiveNote Reporter
`
` commencing on WEDNESDAY, OCTOBER 28, 2015 at 9:01 a.m.
`
` at 625 El Camino Real, Palo Alto, California.
`
` A P P E A R A N C E S
`
` FOR THE PETITIONER:
`
` ERISE IP
`
` 5600 GREENWOOD PLAZA BOULEVARD, SUITE 200
`
` GREENWOOD VILLAGE, COLORADO 80111
`
` BY: ABRAN KEAN,
`
` ATTORNEY AT LAW
`
` 720.689.5440
`
` FOR THE PATENT OWNER:
`
` GREENE ESPEL PLLP
`
` 222 SOUTH NINTH STREET, SUITE 2200
`
` MINNEAPOLIS, MINNESOTA 55402
`
` BY: ROBERT J. GILBERTSON,
`
` ATTORNEY AT LAW
`
` 612.373.0830
`
` ALSO PRESENT:
`
` CALLIE PENDERGRASS, SENIOR TECHNICAL ADVISOR
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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. 1041 Page 2
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`
`
`PENG LIM 10/28/2015
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`Page 3
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` IT IS HEREBY STIPULATED AND AGREED
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` by and between the attorneys for the
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` respective parties herein, that filing and
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` sealing be and the same are hereby waived.
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` IT IS FURTHER STIPULATED AND AGREED
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` that all objections, except as to the form
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` of the question, shall be reserved to the
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` time of the trial.
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` IT IS FURTHER STIPULATED AND AGREED
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` that the within deposition may be sworn to
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` and signed before any officer authorized
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` to administer an oath, with the same
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` force and effect as if signed and sworn
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` to before the Court.
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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. 1041 Page 3
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`
`
`PENG LIM 10/28/2015
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`Page 4
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` INDEX OF EXAMINATIONS
`
` PAGE
`
` BY
`
` MR. KEAN 7
`
` MR. GILBERTSON 183
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` INDEX OF EXHIBITS
`
` NUMBER DESCRIPTION PAGE NOTED
`
` Exhibit 1023 Document entitled "Powerful 12
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` calculators throw teachers
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` a new curve"
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` Exhibit 1024 Document entitled "Stylistic 18
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` 1200 pen tablet user's guide"
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` Exhibit 1025 Document entitled "Happy 20th 19
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` birthday, Windows 95"
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` Exhibit 1026 Document entitled "Pen computer 27
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` technology"
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` Exhibit 1027 Document entitled "Fujitsu and 32
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` the tablet PC"
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` Exhibit 1028 Document entitled "Stylistic 35
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` ST4000 series tablet PC"
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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. 1041 Page 4
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`
`
`PENG LIM 10/28/2015
`
` INDEX OF EXHIBITS (CONTINUED)
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`Page 5
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` NUMBER DESCRIPTION PAGE NOTED
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` Exhibit 1029 Document entitled "Stylistic 37
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` ST4000 series tablet PC
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` technical reference guide"
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` Exhibit 1030 Document entitled "Windows XP 39
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` Tablet PC Edition review"
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` Exhibit 1031 Document, screen shot Tapwave 68
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` web site
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` Exhibit 1032 (Not marked)
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` Exhibit 1033 Document entitled "User's guide" 169
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` Exhibit 1034 Document entitled "The 12 cell 171
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` phones that changed our world
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` forever"
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` Exhibit 1035 Document entitled "The 25 best 172
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` selling cell phones of all time"
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` Exhibit 1036 Document entitled "Why my 173
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` favorite phone of all time is
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` an old Nokia"
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
`
`SCEA Ex. 1041 Page 5
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`
`
`PENG LIM 10/28/2015
`
` INDEX OF PREVIOUSLY MARKED EXHIBITS
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`Page 6
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` NUMBER PAGE REFERENCED
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` Exhibit 1001 154
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` Exhibit 1003 108
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` Exhibit 1004 105
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` Exhibit 1016 51
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` Exhibit 2005 9
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` Exhibit 2026 167
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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. 1041 Page 6
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`
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`PENG LIM 10/28/2015
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`Page 7
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` PENG LIM,
`
` having been first duly sworn by the
`
` Certified Shorthand Reporter to tell
`
` the truth, the whole truth, and nothing
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` but the truth, testified as follows:
`
` EXAMINATION
`
` BY MR. KEAN:
`
` Q. Good morning, sir.
`
` Would you please state your name for the
`
` record?
`
` A. Sure. My name is Peng Lim.
`
` Q. And Mr. Lim, have you been deposed before?
`
` A. No.
`
` Q. Do you know Beth Marcus?
`
` A. Beth Marcus, the inventor?
`
` Q. Yes.
`
` A. No, I don't.
`
` Q. Do you know David Lee, the other inventor?
`
` A. No, I don't.
`
` Q. How are you compensated for your work in
`
` connection with this case?
`
` A. Paid.
`
` Q. Is that hourly pay?
`
` A. Yes.
`
` Q. What's your hourly rate?
`
`www.midwestlitigation.com
`
`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`SCEA Ex. 1041 Page 7
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`
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`PENG LIM 10/28/2015
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`Page 8
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` A. 385.
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` Q. How many hours would you say you spent on
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` this proceeding -- I'll call it the '245 proceeding
`
` today. If I call it the '245 proceeding, will you be
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` familiar with what I'm talking about?
`
` A. Yes.
`
` Q. Okay. How many hours would you estimate that
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` you've spent working on the '245 proceeding?
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` A. All inclusive, right? Licensed patents?
`
` Q. Yes.
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` A. 50 to 100, maybe 70 to 100, somewhere around
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` there, hours I mean.
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` Q. Since you never have been deposed before, it
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` might helpful if I go over a couple of ground rules.
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` I'll do my best today not to speak over you
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` if you'll extend me the same courtesy and that will
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` make the court reporter's job easier.
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` A. Yes, I will. I'll try my best.
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` Q. It's also important to provide the court
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` reporter with verbal answers, so verbal yes or no
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` because, obviously, head shakes and nods don't make it
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` onto the record.
`
` A. Okay.
`
` Q. It's not a marathon today. If you'd like to
`
` take a break at any time, let me know and we can take
`
`www.midwestlitigation.com
`
`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`SCEA Ex. 1041 Page 8
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`PENG LIM 10/28/2015
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`Page 9
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` a break whenever you like.
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` A. Thank you. I appreciate that.
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` Q. Mr. Lim, I've handed you what's been marked
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` previously as Exhibit 2005 in the '245 proceeding.
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` Do you recognize this document?
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` A. Yes, I do.
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` Q. What is it?
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` A. It's my declaration.
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` Q. And if you turn to the final page, page 61 of
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` that document --
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` A. 61, yes.
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` Q. -- this is your signature?
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` A. Yes, that's mine.
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` Q. Do you have any additions or changes to this
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` declaration before we get started today?
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` A. Yes. While I was flipping through it, I
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` realized that is formatting error, a small format,
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` indent format, when I flip through it earlier.
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` If you flip to page 46, okay.
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` The number 2 on the bottom, opinion of
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` nonobviousness, you see that page 46?
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` Q. Yes, sir.
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` A. That I believe it should be opinions of
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` bullet 1, so the 2 should not be there, the number 2
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` should not be there.
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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. 1041 Page 9
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`
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`PENG LIM 10/28/2015
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`Page 10
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` Then, if you flip -- I'm sorry, do you follow
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` me, if you flip to page 47, it say A, incorporating
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` Andrews, that A should be a 2, you follow me?
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` Q. Yes, sir. What might be easiest, would you
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` mark the document how you would like to fix it.
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` A. I would just say that and then that should
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` be -- let me double-check it. That should be A.
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` Q. Very good, thank you.
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` Do you have any other changes or additions to
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` that document?
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` A. I don't believe so at this point.
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` Q. Okay. Mr. Lim, I'd like to discuss your
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` background and so in your declaration, I'm going to be
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` starting about at paragraph 10 of your declaration.
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` A. Paragraph 10. Yes, sir.
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` Q. You worked at Texas Instruments from 1996
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` until 1997; is that right?
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` A. That is correct.
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` Q. Were you familiar with the Texas Instruments
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` graphing calculators that were available at that time?
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` A. I was aware of it. It wasn't in my
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` department.
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` Q. What was your department?
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` A. Notebook department. I forgot exact name of
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` the department, but the end product is notebook. I
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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. 1041 Page 10
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`PENG LIM 10/28/2015
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`Page 11
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` managed engineering there, computer.
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` Q. For instance, you were at least familiar with
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` the TI 85 graphing calculator?
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` A. I wouldn't say familiar. I mean it's a
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` product on the market, not part of my department and I
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` wasn't using it at the time, so I wouldn't say --
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` depends on your definition of familiar. I heard of
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` it.
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` Q. Sure. Were you aware that that calculator
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` was programmable in BASIC or Assembly language at the
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` time?
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` A. I couldn't say one way or the other, to be
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` honest with you.
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` I wasn't using it and, of course, when I was
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` in college, you know, it was Casio brand, a different
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` calculator brand. I'm sorry, I will try to be --
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` MR. GILBERTSON: I think the words might have
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` been casual use.
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` THE WITNESS: Casio, C-A-S-I-O.
`
` BY MR. KEAN:
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` Q. Mr. Lim, I'm going to hand you a document
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` that's been marked -- this is a new exhibit and we are
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` going to continue the numbering from the '245
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` proceedings.
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` So this exhibit is now numbered 1023.
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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. 1041 Page 11
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`PENG LIM 10/28/2015
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`Page 12
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` If you would, Mr. Lim, please turn to the
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` second page of the document and please take a look at
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` the second to last paragraph at the bottom of the
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` document as well as the last paragraph that carries
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` over into page 3.
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` Yes, sir. And then please take a look at
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` that and read that. You don't need to read it out
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` loud, but once you've taken a look at it, just let me
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` know.
`
` A. Okay.
`
` Q. Now, this document is an article from the New
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` York Times from September 2nd, 1999 and in the portion
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` that I just asked you to read, it's describing Texas
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` Instruments graphing calculators.
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` And it's describing the hundreds of games
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` that were available on those devices.
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` Did you see that?
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` A. Yes. That's what it say on this document.
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` Q. Were you aware in your time at TI that the
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` graphing calculators could be used to -- that users of
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` the graphing calculators could install games on them?
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` A. I was there in 1996 to 1997, so it's about
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` three years before this article.
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` To answer your question directly, I did not
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` aware of that.
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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. 1041 Page 12
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`
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`PENG LIM 10/28/2015
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` Q. Were you aware that students could program
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`Page 13
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` these devices to include games?
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` A. I don't because if I do I would be
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` speculating here.
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` So do I have knowledge of that people were
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` doing that, I don't -- I did not at that time.
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` Q. Were you aware that there were hundreds of
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` games that were available that could be installed on
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` the graphing calculators?
`
` A. It wasn't my focus at all. It was totally
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` different department and I wasn't using it. I'm not
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` sure how to answer I did not know that. Actually
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` surprised me I see this article.
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` Q. Is it fair to say that you did not consider
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` the games on the graphing calculators as part of
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` forming your opinion in your declaration?
`
` A. I did not see the article that you hand it to
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` me, nor have I taken this into consideration.
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` Q. Apart from the article, did you take into
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` consideration the games that were available for the TI
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` 85 and other TI calculators at the time when you were
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` forming your opinion?
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` A. Anything that I thought the most relevant to
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` this case here I submitted it as a reference.
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` So that's what I selected.
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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. 1041 Page 13
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`PENG LIM 10/28/2015
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`Page 14
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` As far as whether I knew TI calculator, did I
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` take TI calculator into consideration, gaming, no.
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` Q. Thank you.
`
` I'd like to turn to the next paragraph in
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` your declaration, paragraph 11.
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` A. Okay.
`
` Q. And paragraph 11 is describing your time at
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` Fujitsu?
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` A. Yes.
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` Q. You were with Fujitsu as the vice-president
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` of engineering from 1997 until 1999; is that right?
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` A. That is correct.
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` Q. And in your role as a vice-president of
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` engineering, you worked on the Stylistic tablet
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` computers; is that correct?
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` A. Yes, my team.
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` Q. What operating systems did those tablet
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` computers run?
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` A. Windows.
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` Q. Any particular version of Windows?
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` A. I believe it's Windows 95. I think that's
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` pre-XP.
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` '97, again, this is long time ago, 95
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` probably would be the most appropriate. If not 95, it
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` would be XP, but Microsoft Windows for sure.
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`www.midwestlitigation.com
`
`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`SCEA Ex. 1041 Page 14
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`PENG LIM 10/28/2015
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` Q. There was not a specialized version of
`
` Windows 95 for tablets at the time, was there?
`
` A. Operating system itself I believe is mostly
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` generic.
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` Application itself, drivers of the device and
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` hardware, a lot of them are specialized meaning that
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` every manufacturer would produce their own hardware,
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` would write their own drivers and Fujitsu, actually we
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` have our own driver that's specific for something that
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` we would like to do and we would submit it to
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` Microsoft and Microsoft would pass it, make sure it
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` work and then include it into the quote, unquote, the
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` bundle of our property.
`
` Q. So again, there was not a specialized version
`
` of Windows 95 for tablet computers, right?
`
` A. As I say earlier, I would say that majority
`
` of the Windows generic -- generic in the sense as you
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` know, but when it come to tablet or notebook the power
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` management I could not say they are generic.
`
` There are few area -- couldn't say few, quite
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` a bit of the area that are very specific to certain
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` device to certain application. I'll give you example,
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` power management, power management will be very
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` important for devices like tablet, like notebook while
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` it's not important at all for desktop computer.
`
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`MIDWEST LITIGATION SERVICES
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`SCEA Ex. 1041 Page 15
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` LCD support, LCD support is very important
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` for a tablet and a notebook, not so important back in
`
` those days for, again, for your desktop.
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` I can give you many, many, many area that are
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` differences that you have a bundle into the product
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` and that's not to mention that manufacturer specific.
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` When I say "manufacturer," that means
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` Fujitsu, you know, Toshiba, Compaq, manufacturer
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` specific.
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` So when I say generically, I was referring to
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` kind of very high level, but when you're coming down,
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` it become more and more specific.
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` By the time you get into the Fujitsu
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` computer, right, I would say that it could be true
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` even today. I think by the time that it get into your
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` device, that operating system, that bundled operating
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` system are not transferable to another computer and
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` just say that you're running.
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` For example, you cannot take a Fujitsu bundle
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` of the operating system and the drivers and everything
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` else and say I'm going to take the hardware away, I'm
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` going to buy a, just for example, buy a Toshiba and
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` put the -- load this software into the Toshiba,
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` totally replace everything that Toshiba has inside and
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` expect it to run reliably. I would say it would not,
`
`www.midwestlitigation.com
`
`MIDWEST LITIGATION SERVICES
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`SCEA Ex. 1041 Page 16
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` reliably.
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` So in that sense, at the very high level you
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` say that yeah, it look similar, but by the time you
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` get to the hardware -- by the time you get to the
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` product itself, it would not be the same.
`
` Does that answer your question?
`
` Q. Maybe. When you say it looks similar, do you
`
` mean that the user interface and the applications that
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` would be available on Windows 95 on a tablet would be
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` the same as on a PC?
`
` A. Can you repeat that again?
`
` MR. KEAN: Would you repeat that for me,
`
` please?
`
` (The record was read by the Reporter.)
`
` THE WITNESS: You mention about the
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` application and the user interface, right.
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` In that sense, depends on what application
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` and what user interface.
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` Give you an example. If you buy a tablet
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` computer for the purpose that for when Fujitsu was
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` selling them, usually there are some dedicated
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` application that would be -- would be loaded on top of
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` the operating system itself that will have a very
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` specific purpose for that application.
`
` In that case, there will be different kind of
`
`www.midwestlitigation.com
`
`MIDWEST LITIGATION SERVICES
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`SCEA Ex. 1041 Page 17
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` user interface on it that will be suitable for
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` whatever corporation it needed to.
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` However, if there are application that are,
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` how do I say, commonly used that would come with
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` operating system, then it's possible, I got to
`
` think -- it's possible, but in the application on the
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` tablet many times are quite specific, but they are
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` generic out there, too, I don't want to rule
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` everything out.
`
` I'll give you -- the example I want to give
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` you, I almost wanted to say like a pop-up keyboard,
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` but pop-up keyboard is very specific for handheld that
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` is not on the desktop, that's not a thing to show you
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` the difference, but -- I don't know, maybe Lotus or
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` maybe Excel would work, I would guess.
`
` BY MR. KEAN:
`
` Q. I'm going to hand you a document marked
`
` Exhibit 1024. This document is a users's guide for
`
` the Fujitsu Stylistic 1200.
`
` A. Yes.
`
` Q. Would you please turn with me to pages 2-6?
`
` A. 2-6.
`
` Q. Toward the top of the page under the number
`
` 3 --
`
` A. Number 3.
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`MIDWEST LITIGATION SERVICES
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`SCEA Ex. 1041 Page 18
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`PENG LIM 10/28/2015
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` Q. -- it identifies various operating systems
`
` that work on this device.
`
` It notes that the device runs Windows 95 and
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`Page 19
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` Windows NT?
`
` A. Uh-huh.
`
` Q. Would you agree with that?
`
` A. That's what it say here and I did tell you it
`
` was 95 or XP, I couldn't remember.
`
` Q. I'm going to hand you a document that has
`
` been previously marked -- new exhibit, but it's marked
`
` 1025.
`
` A. 1025, yes.
`
` Q. This document is a review of Windows 95.
`
` Will you please take a quick minute just to
`
` read the document?
`
` A. The whole page?
`
` Q. Yes, sir.
`
` You know what might be more efficient, I can
`
` direct you to the most relevant portion of this, it's
`
` going to be right in the middle of the page, it's the
`
` sixth paragraph.
`
` A. Windows 95?
`
` Q. Yes, sir.
`
` A. Okay.
`
` Q. This document is a review of Windows 95 and
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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. 1041 Page 19
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` it's describing some, quote, "much-loved games" that
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` came with the operating system including favorites
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` such as Minesweeper, Hearts, Freecell and Solitaire?
`
` A. Uh-huh.
`
` Q. Do you agree that Windows 95 included these
`
` games?
`
` A. I'm not sure it included, but I think it
`
` could run these games.
`
` Windows 95, when I say a little bit earlier
`
` on the higher level, right, it looks similar.
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` Windows 95 also run on desktops, so that I'm
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` not sure you're aware of it, run on desktop, run on
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` notebook, run on tablets and it tends to specialize or
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` customize as you go down to different category of the
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` product.
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` So at the very high level, they are, and I
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` would say that yes, it could run, I'm not sure whether
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` it bundle with it, that's what I mean.
`
` Q. Sure. Would you agree with me, sir, the
`
` Stylistic 1200 could run Windows 95?
`
` A. Yes, it could run Windows 95.
`
` Q. Would you agree with me the Stylistic 1200
`
` running Windows 95 could include games such as
`
` Minesweeper, Hearts, Freecell and Solitaire?
`
` A. As reported in my report, as I wrote in my
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` report that Stylistic 1200 was designed for the
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` corporate or what we call vertical market.
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` So that question you asked me is difficult
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` for me to answer simply because would people load
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` games into Stylistic 1200 for the purpose of Fujitsu
`
` was selling them and they were buying them for
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` vertical market, in my report, the answer is very,
`
` very unlikely.
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` And I give the reason in there that why it's
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` unlikely because in the corporate world, gamings is
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` not something that any corporate would endorse except,
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` you know, in the gaming company.
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` Other than that, not something that would
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` endorse.
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` So on the surface, on the very high level,
`
` yes, it could run. I think your question is would
`
` people load that into the 1200, Fujitsu Stylistic
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` 1200, I would say very unlikely for the application.
`
` Q. Sure. We will discuss the vertical markets
`
` and all that here in a bit.
`
` My question for you is: Would the Stylistic
`
` 1200, if a user had that device, could they load
`
` Windows 95 and if so, could they also load these games
`
` mentioned in this Windows review such as Minesweeper,
`
` Hearts, Freecell and Solitaire?
`
`www.midwestlitigation.com
`
`MIDWEST LITIGATION SERVICES
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` A. The first part is yes, they can load Windows
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` 95, come with the Fujitsu. At that time there were
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` CDs that come with computer they can load into it.
`
` The question is yes, if you follow the
`
` procedure you can load Windows 95 into the 1200, the
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` version Fujitsu give it to you, right.
`
` Can you run that software, I guess you -- I
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` mean it's -- it's a computer, right.
`
` I want to say it's not likely people do that,
`
` but people that want to do that on purpose, I guess
`
` they could, yeah.
`
` Q. Thank you.
`
` Did you do any work at Fujitsu after 1999?
`
` A. No, I left Fujitsu in 1999.
`
` Q. So after 1999, did you have any access to
`
` Fujitsu business plans?
`
` A. After 1999, I do not.
`
` Q. After 1999, did you have any access to
`
` Fujitsu marketing plans?
`
` A. I do not have internal marketing plan except
`
` I was in the industry, industry in the sense of
`
` tablet, PDA industry. Anything that was publicly
`
` announced, I would be aware of it, but not the
`
` proprietary information.
`
` Q. Were you involved in the development of any
`
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` Stylistic products after 1999?
`
` A. No, I do not -- I did not, I should say.
`
` Q. Were you involved in the development of any
`
` other Fujitsu products after 1999?
`
` A. After I left the company, I did not.
`
` Q. Were you aware that after you left Fujitsu,
`
` by around the 2002 time frame, tablets were moving in
`
` the direction of consumer markets?
`
` A. I heard about it, yes. I also heard about it
`
` that, of course, that round of product wasn't
`
` successful -- let me explain to you.
`
` In the computer world, in most of the
`
` industry, in the computer industry, there's always a
`
` way that people would like to go into consumer market
`
` and that wasn't -- I mean even if what you say is
`
` correct, and I believe it is, that at the time there
`
` was some discussion about going to consumer market,
`
` that wasn't the first time either.
`
` There were multiple times that in the
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` computer industry, that it always thought at the very
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` more focused corporate market and gradually over time
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` when the technology getting more mature, when the cost
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` getting lower, when the user more familiar with it,
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` you know, computer is special machine, so it start
`
` with, you know, professional, usually, and start
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` propagating down to consumer, but technology is
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` important, cost is important, battery life is
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` important.
`
` So yes, there's always a wave of companies or
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` industry that wanted to get into consumer, but my
`
` understanding, even certainly up to 1999 I was there,
`
` even post 2002, my recollection is that they will try,
`
` they were not successful.
`
` The one that was successful that commonly
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` known, as I point out in my report, was the iPad that
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` we know today, which really pushed the market to be
`
` kind of more consumer market for the tablet market.
`
` Yeah, and I guess it's not only my opinion
`
` here, I think it's industry knowledge that in that
`
` time, early 2000, tablet computer was for professional
`
` and I point out the cost was 4000 plus.
`
` And it's hard to see that a lot of consumer
`
` will buy that.
`
` Q. Sure. I'm just trying to understand your
`
` opinion here because it seems like you said some
`
` things that conflict.
`
` I believe you agree with me that by 2002,
`
` tablet computers were moving towards the consumer
`
` market; is that right?
`
` A. That's not what I meant.
`
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` Again, the moving is a word I try to
`
` understand.
`
` That's not what I meant.
`
` What I was saying was they were always an
`
` attempt of bringing computer product to the consumer
`
` market, start from desktop the same way, start with
`
` the notebook and I was in the notebook industry for a
`
` long time before I came into handheld market.
`
` That was always an attempt times after times
`
` try to do that.
`
` So that was my understanding that there was
`
` an attempt at the time.
`
` Moving, I don't know what you means.
`
` Q. Sure. So you would agree there were attempts
`
` by Fujitsu and other tablet designers by 2002 to
`
` design and develop tablets that were directed to the
`
` consumer market?
`
` A. I couldn't speak specifically for Fujitsu in
`
` 2000.
`
` In 1999, Fujitsu was actually on the tablet
`
` market not -- intentionally not focused on the
`
` consumer market because we knew that and we were
`
` focusing on the vertical market and we were successful
`
` in the vertical market, we did market study.
`
` The world of computer -- computer doesn't
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` produce -- just produce a computer.
`
` We did a lot of market study, include the
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` focus group, include a lot of surveys and include
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` talking to bunch of analysts, people that in the
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` industry that, you know, tends to survey the market.
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` From those we took that input coming in,
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` analyze it, then we produce a product, focus on
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` certain market that we believe that we could be
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` successful.
`
` At that time, in the late '90s, Fujitsu was
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` about vertical market and actually the whole
`
` department -- actually Fujitsu form a brand new
`
` Corporated, Inc., to address that market called
`
` Fujitsu Personal System, if I'm not mistaken, that's
`
` the name, Fujitsu Personal System.
`
` So I cannot speak for Fujitsu was attempting,
`
` I had no clue.
`
` Market, in general I heard about it that
`
` yeah, people tried to do that. It wasn't t