GREGORY F. WELCH PH.D. 2/26/2016
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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 ENTERTAINMENT
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`AMERICA, LLC,
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` Petitioner,
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`v. Case No. IPR2015-00729
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` Patent No. 7,280,097
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`APLIX IP HOLDINGS CORPORATION,
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` Patent Owner.
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` DEPOSITION OF GREGORY F. WELCH, Ph.D.
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` Friday, February 26, 2016
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` 11:00 a.m. - 1:45 p.m.
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` Orlando Airport Hyatt
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` 9300 Jeff Fuqua Boulevard
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` Orlando, Florida 32827
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`BEFORE: LAURA J. LANDERMAN, RMR, CRR
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` Notary Public, State of
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` Florida at Large.
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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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 ENTERTAINMENT
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`AMERICA, LLC,
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` Petitioner,
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`v. Case No. IPR2015-00729
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` Patent No. 7,280,097
`
`APLIX IP HOLDINGS CORPORATION,
`
` Patent Owner.
`
`
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` DEPOSITION OF GREGORY F. WELCH, Ph.D.
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` Friday, February 26, 2016
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` 11:00 a.m. - 1:45 p.m.
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` Orlando Airport Hyatt
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` 9300 Jeff Fuqua Boulevard
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` Orlando, Florida 32827
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`BEFORE: LAURA J. LANDERMAN, RMR, CRR
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` Notary Public, State of
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` Florida at Large.
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 2
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`A P P E A R A N C E S:
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` ABRAN J. KEAN, ESQUIRE
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` ERISE IP, P.A.
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` 5600 Greenwood Plaza Boulevard
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` Suite 200
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` Greenwood Village, Colorado 80111
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` 913-777-5600
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` abran.kean@erisip.com
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` Appearing on behalf of the Petitioner,
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` Sony Computer Entertainment America,
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` LLC,
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` JASON R. BARTLETT, ESQUIRE (via telephone)
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` Mauriel Kapouytian Woods, LLP
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` 15 West 26th Street -- Floor 7
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` New York, New York 10010
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` 212-529-5131
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` jbartlett@mkwllp.com
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` Appearing on behalf of the Patent Owner,
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` Aplix IP Holdings Corporation.
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`ALSO PRESENT: Callie Pendergrass, Senior Technical
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` Advisor - ERISE IP
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 3
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` I N D E X
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`TESTIMONY OF GREGORY F. WELCH, Ph.D.
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` Direct Examination by Mr. Bartlett 4
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` Cross-Examination by Mr. Kean 77
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` Redirect Examination by Mr. Bartlett 79
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`CERTIFICATE OF REPORTER 82
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`CERTIFICATE OF OATH 83
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` E X H I B I T S
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` (None marked.)
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`GREGORY F. WELCH PH.D. 2/26/2016
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` THE REPORTER: Do you swear the testimony
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` you're about to give will be the truth, the
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` whole truth and nothing but the truth so help
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` you God?
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` THE WITNESS: I do.
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` DIRECT EXAMINATION
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`BY MR. BARTLETT:
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` Q Good morning, Dr. Welch.
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` A Good morning, Jason.
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` Q So I'm in California and you're there with
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`the court reporter and your counsel in Florida, and
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`I'm appearing by telephone pursuant to the agreement
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`of the parties. As far as I'm aware, the sound
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`quality sounds as if it's been checked and it's
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`adequate. It could deteriorate. It happens these
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`days. And if that happens, please don't struggle.
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`Just let me know, and I'll be happy to hang up and
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`call right back.
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` A Okay. Sure. I understand.
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` Q Now, because we're on the phone, it's very
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`important for the four speaking parties here, that's
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`you, it's me, your counsel and the court reporter,
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`not to speak over each other. I'll do my best
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`always to pause at the end of each of your answers
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`in case the court reporter needs to ask for
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 5
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`clarification, and I'll ask you always to pause
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`before answering my questions in case your counsel
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`wants to interpose an objection. Okay?
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` A Understood.
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` Q And of course, as always, if you can't
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`understand my question, I'll be happy to repeat it.
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`And I have complete confidence in my colleague,
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`Mr. Kean, so that this doesn't really need to be
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`said, but I'll just say it for the record. You
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`understand that even though that I'm not there, the
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`same restrictions apply regarding your
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`communications with counsel during the deposition
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`and coaching and that sort of thing. You're aware
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`of that, yes?
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` A Yes, I am. Absolutely.
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` Q And is there any reason to think of that
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`you're not at your best this morning in terms of
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`your ability to testify?
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` A No.
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` MR. BARTLETT: Counsel, any comments
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` before we begin?
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` MR. KEAN: Two very minor ones. I want to
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` note for the record that Dr. Welch is going to
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` be referring to exhibits on his computer as you
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` lead him through those exhibits with your
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 6
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` questioning.
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` Secondly, for the record, I just want to
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` note that we received the deposition notices
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` about 15 minutes before the start of the depo,
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` so I just want to lodge an objection for the
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` record for the timing of those deposition
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` notices.
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` MR. BARTLETT: Well, with respect to the
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` second issue, as you know, this was a situation
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` within the deadline to notice depositions, and
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` we immediately began to meet and confer about
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` the timing of the deposition and were given
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` just one date, which was today, which we
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` accepted. So I think we were all on the
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` same -- I think we were all cooperating about
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` getting this deposition scheduled.
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` Do you disagree, Counsel?
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` MR. KEAN: No, I don't disagree with that.
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` I just was making the objection for the record.
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` MR. BARTLETT: Okay. And I'll say that
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` part of the reason why the deposition notice
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` was not able to be sent earlier is that it took
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` us some time to find a location for the
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` deposition which would be acceptable to all
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 7
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` parties and which also had acceptable sound
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` quality telephone available, and, in fact, we
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` changed the location just yesterday in order to
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` achieve that. So I'll note that for the
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` record.
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` Anything else?
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` MR. KEAN: Nothing else for me. Thank
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` you.
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`BY MR. BARTLETT:
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` Q So, Dr. Welch, referring to your
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`supplemental declaration, Exhibit No. 1039, do you
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`have that with you?
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` A I have my two supplemental declarations
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`for the '97 and '892 patent. I don't have the
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`exhibit numbers on them, so I don't know which is
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`which.
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` Q Okay. No problem. I'm going to refer
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`today, when I speak about your declaration, unless I
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`say otherwise, I'll just be referring to your
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`supplemental declaration for the '097 patent. Is
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`that acceptable?
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` A That's fine.
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` Q And do you have that in front of you?
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` A I do.
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` Q Please refer to the list of exhibits that
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 8
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`appears starting at page 1 of your supplemental
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`declaration.
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` A Jason, if I could, I want to make sure
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`that -- I lowered the volume here, and I wanted to
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`make sure that was okay with Laura. It was a little
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`loud for me.
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` You said page 1, the list of exhibits. I
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`see it.
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` Q Okay. So you've submitted several new
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`exhibits with this supplemental declaration,
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`correct?
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` A That is correct, yes.
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` Q Now, Exhibit No. 1038 "Buxton's Directory
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`of Sources for Input Technology," what is that
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`document?
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` A I'm going to go from memory here because I
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`don't have it in front of me. I probably have it
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`somewhere. But my recollection is that is a
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`document that was listed on the face of the '097
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`patent, along with there were maybe three pages of
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`other -- all sorts of references that the inventors
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`included with the patent.
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` Q What was your purpose for citing 1038 in
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`your declaration?
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` A I guess I just thought it was relevant
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 9
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`since the inventors seemed to think everything they
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`included was relevant. I can't think of any other
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`reason why they would have included that long list
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`of things, and it is a nice, comprehensive list of
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`input devices, sources and resources.
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` And Bill Buxton is a very famous person in
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`user interfaces and other things, but he's a really
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`famous researcher, and so it's a nice article. He
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`does a lot of things like keeping historical records
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`of all sorts of technology and research-related
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`things that are not necessarily documented in
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`published papers, and so it's a nice service that he
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`does for the community to assemble and make
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`accessible all of this information.
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` Q So you said it was relevant. Relevant to
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`what, specifically, in terms of the issues in this
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`proceeding?
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` A Just relevant to the patent.
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` Q In what way?
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` A In that it was included by the inventors.
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` Q How is it relevant to your supplemental
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`testimony and your declaration?
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` A Do you remember or do you know, Jason,
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`whether I cited that somewhere in my declaration?
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`I'm not finding it here at the moment. One moment.
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`www.midwestlitigation.com
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 10
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` Q You cite it starting at paragraph 5.
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` A I might have an erroneous copy or
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`something. My paragraph 5 lists Exhibit 1039, I
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`think, as Buxton. Does your copy say 1038? I'm
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`just curious.
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` Q My copy says 1039, and maybe that's a
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`typo, but it refers to Buxton.
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` A That's right, right. So that is a list
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`of -- a directory of sources for input technology,
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`as the title says. So I think that given that the
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`patent is largely about handheld and other input
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`devices for interfacing with different electronics,
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`that list from Bill Buxton provides a comprehensive
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`list of all sorts of input technologies, including
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`those sorts of input devices.
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` Q Anything else that comes to mind at the
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`moment?
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` A Not really. Again, just that it was
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`focused on input technologies -- and I'm going from
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`memory here -- and that it was cited by or included
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`by the inventors of the patent.
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` Q Okay. If you could then turn to paragraph
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`6 of your declaration, the next paragraph.
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` A Okay.
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` Q This portion of your declaration refers to
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 11
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`work that you did in your senior year of
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`undergraduate studies at Purdue, correct?
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` A That's correct.
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` Q There were four exhibits that you included
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`in your declaration relating to the work discussed
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`here in paragraph 6, right?
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` A That appears to be the case, that's right.
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` Q So Exhibits 1033, 1034, 1035 and 1036 all
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`relate to the EZ Chair work that you did -- for the
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`court reporter, that was E-Z Chair -- work that you
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`did as an undergraduate?
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` A That is correct.
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` Q Exhibit 1037 is a 10-page Survey of Power
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`Management Techniques that you wrote, correct?
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` A That is correct.
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` Q And you wrote that when?
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` A I believe it -- well, it's dated here as
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`1995 is the publication date. I don't remember
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`exactly when I would have written it. It would have
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`been prior to that. But from memory, it was when I
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`was a freshman at -- I'm sorry -- a first-year
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`graduate student at the University of North Carolina
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`at Chapel Hill. Again, that's going from memory,
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`but it would have been around that time.
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` Q Okay. So Exhibit 1037, the Survey of
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 12
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`Power Management Techniques, was one that you wrote
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`when you were a first-year graduate student?
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` A It was first or second year. I had
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`originally written it for an operating systems
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`class. I had decided to focus on that for a project
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`paper we had to write, and my professor liked it so
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`much he told me I should submit it to this Operating
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`Systems Review Journal. So I cleaned it up, added a
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`few more things and submitted it. And it got
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`accepted and was published as indicated in the
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`citation.
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` Q Now, Exhibit 1032 is a dissertation or a
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`thesis written by Mark Meenay, correct?
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` A Correct, except it's pronounced Meenay,
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`like M-E-E-N-A-Y, but that's correct.
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` Q So Exhibit 1032 is a dissertation by Mark
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`Meenay, and this dates also to the time you were a
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`graduate student, correct?
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` A That's correct. Mark Mark Meenay and I
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`are the closest of friends. In fact, he was the
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`reason I came or went to UNC-Chapel Hill for
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`graduate school, and he and I worked closely
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`together on all sorts of things as graduate
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`students.
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` Q And do you have a copy of Exhibit 1032,
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 13
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`Mr. Meenay's thesis, available to you there?
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` A Possibly. I would have to look for it.
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` Q Let's see if we need it. I'll represent
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`to you that you are thanked in the acknowledgments
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`section of this thesis, and there's a reference to
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`meetings of the IHBI at the TOTH. Is that familiar
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`to you?
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` A Yes, indeed. That's a humorous
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`acknowledgment.
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` Q What does that refer to?
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` A I think that refers to what we used to
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`call the Institute for Half-Baked Ideas, lovingly,
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`between myself and Mark and a couple of other
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`students. And we would meet at a restaurant called
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`the Top of the Hill on certain afternoons and have a
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`beer and discuss various research ideas. So it was
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`a very casual setting where we could explore
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`different ideas together, flush out different
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`research ideas at a very casual level.
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` Q And why did you submit, in support of your
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`supplemental declaration, Mr. Meenay's writing on
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`this project instead of your own writing?
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` MR. KEAN: Object to form.
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` A I don't know. And I wouldn't say I did
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`that instead of something else. I simply chose to
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`GREGORY F. WELCH PH.D. 2/26/2016
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`provide that. It had nice pictures in it, and it
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`represents work -- the work that he did and the
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`input devices that he created or that he's shown
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`using in the picture, I should say, or the two
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`pictures that I included were developed by him. And
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`I think I helped him with one in -- on the left in
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`Figure 6.2 because I remember that's -- I think
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`that's a toothbrush holder that we modified to add
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`the different components to it.
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` But, again, it's an example of something
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`that I worked on as a part of a team, and it had
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`nice pictures, so I thought I would include it.
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` Q I want to refer you now to the claims of
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`the '097 patent. So can you please call up your
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`copy of that patent?
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` A Okay. I have a copy of the '097 patent.
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` Q All right. Would you please look at
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`Claim 1?
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` A Okay.
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` Q In your opinion, would a conventional
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`laptop with a conventional mouse attached to it
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`anticipate this claim?
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` MR. KEAN: Object to form.
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` A I couldn't tell you. I don't think I've
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`offered an opinion on that, and I couldn't form an
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 15
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`opinion on that sitting here right now. If there's
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`something in my declaration that's relevant or
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`related to that, I'd be happy to look at that with
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`you.
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` Q Well, let me ask you this: Is there
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`anything that you can think of sitting here today --
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`any claim element of this claim that you can
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`identify, sitting here today, that is not present in
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`a conventional laptop with a conventional mouse
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`attached to it?
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` MR. KEAN: Object to form.
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` A I can't answer that. I don't want to say
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`that I can't think of anything because that implies
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`that I considered it and am unable to think of
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`something. I just don't think I can consider that,
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`sitting here right now, on the fly, or it would not
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`be wise of me to do so.
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` Q Well, understanding that this is not
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`something that you address directly in your
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`declaration, I'm just asking you right now is there
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`anything that you can think of and identify for me
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`that would -- that is required by these claims that
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`would be missing from a conventional laptop and
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`mouse configuration?
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` MR. KEAN: Object to form.
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
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`Fax: 314.644.1334
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 16
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` A I don't know about indirect or direct, but
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`that doesn't seem related in any way to the
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`substance of anything I've testified about in my
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`declaration. And what you're asking has
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`ramifications that would require me to spend
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`considerable time thinking about this, and I don't
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`think it's even time I could do just sitting here,
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`you know, in an hour or so.
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` So I have not offered an opinion anything
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`like that that I can recall anywhere, and I don't
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`feel comfortable trying to come up with an opinion
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`on something like that, sitting here right now.
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` Q Well, let me ask you this since your view
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`is that it's irrelevant and unrelated to your
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`testimony. For purposes of Claim 1, what's the
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`difference between the Shima reference, on which you
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`have testified, and a conventional laptop connected
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`to a conventional mouse?
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` MR. KEAN: Object to form.
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` A To begin with, I don't think I said
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`irrelevant. I think I said it was not directly
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`related to anything that I had testified about. And
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`you're right. I have testified at various places in
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`ways that relate to Shima, but I have not, that I
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`recall, analyzed anything related to the question
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 17
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`you just asked.
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` And so my answer would be the same. I
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`would have to, on the fly, develop an opinion that I
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`think is going to require much more consideration
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`than just an off-the-cuff answer, so I don't feel
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`comfortable answering -- trying to answer that right
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`now.
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` Q So you are not going to identify for me
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`today any difference between Shima -- the
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`disclosures of Shima and a conventional laptop with
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`a conventional mouse that are relevant to the claims
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`as you construe them?
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` MR. KEAN: Object to form.
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` A Well, I think it's unreasonable to be
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`asked to conjure up a new opinion on the fly here
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`and it would be very unwise of me to do that because
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`I think this is something I would really have to
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`study and think about carefully, and I'm just not
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`prepared to do that right now. So I'm not saying
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`one way or the other yes or no or it does or it
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`doesn't. I simply can't answer that.
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` Q And your answer would be the same if I
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`asked you about Claim 2 and Claim 5?
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` MR. KEAN: Same objection.
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` A Given what I could imagine you would be
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 18
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`asking, I would say yes. I mean, you would have to
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`ask the specific questions, but the same -- the
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`spirit of my answer to the same spirit of question
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`would be the same.
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` Q Well, I can go and I can ask you the
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`questions, if you feel that's necessary, regarding
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`Claim 2 and Claim 5, but it seems to me that your
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`position is somewhat categorical so I didn't think
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`we needed to burn the time. Should I ask those
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`questions?
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` MR. KEAN: Same objection.
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` A It's up to you, but I don't recall having
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`done any sort of full claim analysis anywhere,
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`offhand, and certainly not in this declaration. And
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`so I would not be prepared to make comparisons or
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`assessments about full claims and elements of
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`claims, broadly, as you asked in Claim 1, anywhere
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`in the patent, unless it's something that I actually
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`did offer an opinion about in my declaration, then
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`I'd be happy to try to answer that.
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` Q In your opinion, does the ordinary meaning
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`of "handheld" include laptops?
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` MR. KEAN: Object to form.
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` A With respect to this case, I honestly
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`don't think that what I would think matters. What
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 19
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`matters is what the inventors said. There are many
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`words, most words, in fact, that I can think of in
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`technology that have no well-defined, absolute
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`accepted meaning, and so you have to -- when reading
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`a technical paper or a patent, you have to take the
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`authors at their word, for what it is, for how they
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`define certain terms.
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` And my understanding of patent laws is
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`this is different, that we have to look to what the
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`inventors said explicitly, and that anybody, any
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`person of ordinary skill, any expert, would go by
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`that when trying to interpret the patent.
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` Q Is the definition of -- is the usage of
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`"handheld" in the -- cited at -- actually, let me
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`back up.
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` Can you refer to paragraph 17 of your
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`declaration?
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` A Okay. I'm there.
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` Q You quote a portion of the specification
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`of the '097 patent here that relates to a variety of
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`handheld devices, correct?
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` A That's correct.
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` Q Is the word -- is the inclusion of
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`"laptop" in that list consistent with the ordinary
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`meaning of handheld devices, as that term would have
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 20
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`been used by persons of skill in the art at the
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`relevant time?
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` MR. KEAN: Object to form.
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` A Two things I'd say. One is I'd repeat
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`what I said a moment ago, which is that, in my mind,
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`it really doesn't matter what a person of ordinary
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`skill might or might not think. What matters is
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`what's written here in the patent and the inventors
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`explicitly say that. And what they say is very
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`open-ended. It says "a variety of handheld devices
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`such as" and "other similar devices" it says at the
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`end of the sentence.
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` And I'd also note that in prior testimony
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`in matters related to these two patents, they were
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`other Aplix patents, I don't remember offhand what
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`the numbers were, but I also provided testimony
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`illustrating how ill-defined, how vague, and how
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`widely used many of these terms are and that you
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`won't find unanimity in definitions or in
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`classifications of devices in any way. So the fact
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`that the inventors provide a nice list here is,
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`actually, quite liberating because it helps define
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`some sort of bounds on what they're thinking of as
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`handheld devices.
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` Q Do you have an opinion about what the
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 21
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`ordinary meaning of the term "handheld" was at the
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`relevant time to a person of ordinary skill in the
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`art?
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` A I don't think I have offered that opinion,
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`and I would not feel comfortable trying to offer
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`that opinion. As I said earlier, the
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`classifications of devices in that way is all over
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`the map, so I don't think one could come up with a
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`plausible and reliable definition, if you will, of a
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`term like that that would be universally applicable
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`or useful in a wide variety of cases.
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` Q Did you form an opinion about the ordinary
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`meaning of the term "handheld" to a person of
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`ordinary skill in the art at the relevant time when
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`you were opining about the construction of the term
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`"handheld host device" in Claim 1 of the '097
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`patent?
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`18
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` MR. KEAN: Object to form.
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`19
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` A I don't recall, but any opinion that would
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`be in any way related to what you just said would be
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`in my declaration, and if you want to point me to
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`that, we could look at that and discuss that.
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` Q I did not see in your declaration anywhere
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`that you opined on the ordinary meaning of the term
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`"handheld" in your declaration, but feel free to
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 22
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`look through it, if that would be helpful. I think
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`that the testimony relating to this issue begins at
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`paragraph 15 under the heading "Handheld Host
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`Device."
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` A I don't see, nor do I recall ever offering
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`a opinion about, the plain and ordinary meaning of
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`that term. And as I mentioned a moment ago, I find
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`it hard to believe that I would have even attempted
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`to do that, for one, because it would be very
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`difficult to do in a way that is meaningful or
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`reliable, but also because the inventors already
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`defined it. They actually gave a list of example
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`devices or exemplary devices in that class that
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`they're referring to as handheld devices.
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` So I don't -- I don't think I would have
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`had any reason to go running off and try and
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`characterize that, unless somebody had asked me to,
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`and I don't recall being asked, and I don't recall
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`doing it.
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` Q Are you aware that there are other
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`portions of the specification of the '097 patent
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`that contained lists of handheld devices that do not
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`include laptops?
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`24
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` A From memory, that seems plausible, but
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`25
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`also from memory, I don't recall any such list being
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`GREGORY F. WELCH PH.D. 2/26/2016
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`exhaustive. Every list I recall was open-ended and
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`provided, simply, examples.
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` And also, I don't remember there being
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`complete consistency among the devices listed.
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`There were lots of varieties, which, to me, I think
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`a person of ordinary skill would consider everything
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`collectively that was mentioned anywhere in the
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`patent as a candidate for that class of devices they
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`were referring to. So it wouldn't surprise me and
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`it wouldn't matter to me if that was not listed
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`comprehensively everywhere in the patent. Listed in
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`one place would be good enough for me.
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` Q Please refer to paragraph 20 of your
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`declaration.
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`15
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` MR. KEAN: You're talking the '097
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`16
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` declaration, right, Jason?
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`17
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` MR. BARTLETT: Correct, yeah. For
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` purposes of today, unless I specify otherwise,
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` I will always refer to his supplement to --
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`20
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` Dr. Welch's supplemental declaration relating
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` to the '097 patent as "his declaration."
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` MR. KEAN: Okay. Very good. Thanks.
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`23
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` THE WITNESS: Good. I understand, and I
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` am also at paragraph 20.
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`BY MR. BARTLETT:
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 24
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` Q Paragraph 20 you offer an opinion
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`regarding Claim 38 of the '097 patent, correct?
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` A Correct.
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` Q And Claim 38 states in the portion that
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`you have quoted here in your declaration, "Wherein
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`the plurality of host devices comprises at least one
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`of a cellular phone, a personal digital assistant, a
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`smartphone, a laptop, a garage door opener, an
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`automobile keyless entry unit, a smartcard, a
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`programmable RFID key fob -- that's R-F-I-D key
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`fob -- a universal remote control unit, a digital
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`wristwatch, a compact disc player or a MP3 player."
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` Have I read that correctly?
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`14
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` A I believe so. And for the court reporter,
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`15
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`it's radio frequency identification. It's RF, as in
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`France, just to make sure she got that.
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` Yes, I think you read that correctly,
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`Jason.
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` Q I want to focus for a moment on the
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`automobile keyless entry unit for a moment. Do you
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`have that in mind?
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` A I have the words in mind, sure.
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` Q As you construe this claim, can you
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`describe for me what that would look like if the
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`plurality of host devices comprised an automobile
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 25
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`keyless entry unit?
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` MR. KEAN: Object to form.
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` A Well, I have not offered an opinion on
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`that anywhere. I haven't thought about that before
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`now, just sitting here right now, so I don't know
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`exactly what it would look like.
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` What -- can you tell me a little more
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`about what you're looking for?
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` Q Well, suppose that the input accelerator
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`of the claims were configured in accordance with
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`Claim 38 to also connect to an automobile keyless
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`entry unit. Do you have that in mind?
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` A I have something in mind. I'm not sure if
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`it's enough to answer your question, but let's keep
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`going.
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` Q So what's an automobile keyless entry
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`unit, as you understand this claim?
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`18
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` MR. KEAN: Object to form.
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`19
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` A Well, I don't know if it's defined
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`somewhere in the patent, and if it was, I would go
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`by that definition. But offhand, sitting here
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`without having given it any more thought than the
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`few seconds of having read this, I can imagine it
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`24
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`could be a unit, say, inside my car which allows me
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`25
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`to enter the car by touching the doorhandle or
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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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`
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`GREGORY F. WELCH PH.D. 2/26/2016
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`Page 26
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`touching the back of the latch on the tailgate of
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`the car, something like that, possibly. Again, I
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`don't know if it's explained somewhere in the
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`patent. And if it is, it would be great if you
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`would point me to that. But just sitting here just
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`looking at th
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