Jay Bhatia
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` __________
`
`GOOGLE, INC., APPLE, INC.,
`
`SAMSUNG ELECTRONICS AMERICA, INC., and
`
`SAMSUNG ELECTRONICS CO., LTD.,
`
` Petitioners
`
` v.
`
`AMERICAN NAVIGATION SYSTEMS, INC.,,
`
` Patent Owner
`
` _________
`
` Case IPR2015-00851
`
` Patent 5,902,347
`
` __________
`
` DEPOSITION OF MR. JAY BHATIA
`
` APRIL 14TH, 2016
`
` TAMPA, FLORIDA
`
`PAGES 1 - 156
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 1
`
`1
`
`2
`
`3 4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`1
`
`Exhibit 1022
`Google et al. v. American Navigation
`IPR2015-00851
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` __________
`
`GOOGLE, INC., APPLE, INC.,
`
`SAMSUNG ELECTRONICS AMERICA, INC., and
`
`SAMSUNG ELECTRONICS CO., LTD.,
`
` Petitioners
`
` v.
`
`AMERICAN NAVIGATION SYSTEMS, INC.,,
`
` Patent Owner
`
` _________
`
` Case IPR2015-00851
`
` Patent 5,902,347
`
` __________
`
` DEPOSITION OF MR. JAY BHATIA
`
` APRIL 14TH, 2016
`
` TAMPA, FLORIDA
`
`PAGES 1 - 156
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 1
`
`1
`
`2
`
`3 4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`1
`
`Exhibit 1022
`Google et al. v. American Navigation
`IPR2015-00851
`
`
`
`Jay Bhatia
`
` DEPOSITION OF MR. JAY BHATIA
`
` taken on behalf of Petitioners
`
` DATE: April 14th, 2016
`
` TIME: 9:02 a.m. to 3:08 p.m.
`
` PLACE: Fee & Jeffries
`
` 1227 North Franklin Street
`
` Tampa, Florida 33602
`
` BEFORE: Dawn A. Hillier, RMR, CRR, CLR
`
` Notary Public - State of
`
` Florida, at Large
`
`1 2 3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 2
`
`2
`
`
`
`A P P E A R A N C E S :
`
`Jay Bhatia
`
`A T T O R N E Y S F O R P E T I T I O N E R S
` D A V I D S . A L M E L I N G , E S Q U I R E
` O ' M E L V E N Y & M Y E R S , L L P
` T w o E m b a r c a d e r o C e n t e r , 2 8 t h F l o o r
` S a n F r a n c i s c o , C a l i f o r n i a 9 4 1 1 1 - 3 8 2 3
` ( 4 1 5 ) 9 8 4 - 8 9 5 9
` d a l m e l i n g @ o m m . c o m
`
` M I C H A E L H A W K I N S , E S Q U I R E
` F I S H & R I C H A R D S O N
` 3 2 0 0 R B C P l a z a
` 6 0 S o u t h S i x t h S t r e e t
` M i n n e a p o l i s , M i n n e s o t a 5 5 4 0 2
` ( 6 1 2 ) 3 3 7 - 2 5 6 9
` h a w k i n s @ f r . c o m
`
` M I C H A E L D . J A Y , E S Q U I R E
` B O I E S , S C H I L L E R & F L E X N E R , L L P
` 4 0 1 W i l s h i r e B o u l e v a r d , S u i t e 8 5 0
` S a n t a M o n i c a , C a l i f o r n i a 9 0 4 0 1
` ( 3 1 0 ) 7 5 2 - 2 4 0 0
` m j a y @ b s f l l p . c o m
`
`A T T O R N E Y S F O R P A T E N T O W N E R
` A N T O N H O P E N , E S Q U I R E
` A U B R I Y L Y T V Y N , E S Q U I R E
` N I C H O L A S R . P F E I F E R , E S Q U I R E
` S M I T H & H O P E N
` 1 8 0 P i n e A v e n u e N o r t h
` O l d s m a r , F l o r i d a 3 4 6 7 7
` ( 8 0 0 ) 8 0 7 - 3 5 3 1
`
`1
`
`2 3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`1 0
`
`1 1
`
`1 2
`
`1 3
`
`1 4
`1 5
`1 6
`
`1 7
`
`1 8
`
`1 9
`2 0
`2 1
`2 2
`2 3
`2 4
`2 5
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 3
`
`3
`
`
`
` INDEX
`
`Jay Bhatia
`
` PAGE
`
`WITNESS - JAY BHATIA
`
`DIRECT EXAMINATION BY MR. ALMELING 5
`
`CROSS EXAMINATION BY MR. PFEIFER 142
`
`REDIRECT EXAMINATION BY MR. ALMELING 147
`
` EXHIBITS
`
`Exhibit 1018 Workshare Comparison, 43
`
` Muller/Bhatia
`
`Exhibit 1019 Workshare Comparison 45
`
` Israni/Bhatia
`
`Exhibit 1020 Webster's Encyclopedic 85
`
` Unabridged Dictionary, definition of
`
` project
`
`Exhibit 1021 The American Heritage 86
`
` Dictionary, definition of project
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 4
`
`4
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
` JAY BHATIA,
`
`was called as a witness and having first been duly
`
`sworn, was examined and testified as follows:
`
` DIRECT EXAMINATION
`
`BY MR. ALMELING:
`
` Q Per agreement between the parties, there will 09:02:42
`
`be one transcript today. And that transcript will be 09:02:44
`
`applicable in both IPR2015-00849 and 2015-00851, will 09:02:48
`
`apply to both of those as if it was taken in them. 09:03:01
`
` Please state your full name, sir. 09:03:04
`
` A My name is Jay Bhatia, B as in boy, h-a-t, as 09:03:05
`
`in Tom, i-a. 09:03:09
`
` Q Please state your home address. 09:03:11
`
` A 311 Depot Road, D-e-p-o-t, Boxborough, 09:03:13
`
`B-o-x-b-o-r-o-u-g-h, Massachusetts, 01719. 09:03:18
`
` Q Please state your work address. 09:03:24
`
` A 311 Depot Road, Boxborough, Massachusetts, 09:03:26
`
`01719. 09:03:29
`
` Q Do you understand that you're under oath? 09:03:32
`
` A Yes, sir. 09:03:33
`
` Q Is there any reason that you cannot give 09:03:34
`
`truthful and accurate testimony today? 09:03:35
`
` A No, sir. 09:03:37
`
` Q To ensure clarity throughout the deposition, I 09:03:38
`
`want to define several terms upfront that I will use. 09:03:40
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 5
`
`5
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
`When I use the term "patent owner" or "AmNav," I'm 09:03:44
`
`referring to American Navigation Systems, Inc. 09:03:48
`
` Do you understand? 09:03:51
`
` A I do. 09:03:51
`
` Q When I use the term "Samsung," I'm referring 09:03:55
`
`to Samsung Electronics Co., Ltd., and Samsung 09:03:57
`
`Electronics America, Incorporated. 09:04:00
`
` Do you understand? 09:04:02
`
` A Yes, I do. 09:04:03
`
` Q When I use the term "Google," I'm referring to 09:04:05
`
`Google, Inc. 09:04:08
`
` Do you understand? 09:04:09
`
` A Yes, sir. 09:04:10
`
` Q When I use the term "Apple," I'm referring to 09:04:10
`
`Apple, Inc. 09:04:13
`
` Do you understand? 09:04:14
`
` A Yes. 09:04:14
`
` Q When I use the term "petitioners," I'm 09:04:15
`
`referring to Samsung, Google, and Apple. 09:04:16
`
` Do you understand? 09:04:20
`
` A Yes. 09:04:20
`
` Q When I use the term "these IPRs," I'm 09:04:20
`
`referring to both IPRs that petitioner filed regarding 09:04:23
`
`the '347 patent. 09:04:28
`
` Do you understand? 09:04:30
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 6
`
`6
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
` A Yes. 09:04:30
`
` Q When I use the acronym "POSITA," I'm referring 09:04:32
`
`to a person of ordinary skill in the art at the time of 09:04:36
`
`the alleged invention. 09:04:39
`
` Do you understand? 09:04:40
`
` A Yes. 09:04:41
`
` Q POSITA is spelled P-o-s-i-t-a. 09:04:42
`
` Please describe how you prepared for today's 09:04:49
`
`deposition. 09:04:51
`
` A So, I read all the documents that are in 09:04:51
`
`question. I met with the counsels. And we had 09:04:55
`
`discussions yesterday. 09:05:03
`
` Q Approximately how long did you meet with 09:05:04
`
`counsel? 09:05:06
`
` A Seven or eight hours. 09:05:08
`
` Q And you said you reviewed the documents in 09:05:11
`
`question. Are you referring to the documents you've 09:05:14
`
`identified in your materials-considered list or any 09:05:17
`
`other documents? 09:05:20
`
` A At least the materials-considered list. 09:05:21
`
` Q What additional materials did you review 09:05:24
`
`yesterday that are not identified on the 09:05:27
`
`materials-considered list in your declarations in these 09:05:28
`
`IPRs? 09:05:32
`
` A Yesterday? None. 09:05:33
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 7
`
`7
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
` Q Not limiting my answer to yesterday, what 09:05:34
`
`materials have you reviewed, either for purposes of 09:05:39
`
`preparing your deposition or preparing your testimony 09:05:42
`
`today, that are not included within the 09:05:46
`
`materials-considered list of your two declarations? 09:05:49
`
` A I looked at my resume, and I also looked at 09:05:53
`
`the cases that I have worked with. And I looked at some 09:05:57
`
`of the invoices that I have raised for the case. 09:06:00
`
` Q Anything else? 09:06:07
`
` A That's it. 09:06:07
`
` Q When you say "the cases that I've worked 09:06:09
`
`with," you're referring to previous cases on which you 09:06:11
`
`have served as an expert? 09:06:14
`
` A That is correct. 09:06:15
`
` Q As part of your preparation to testify today, 09:06:16
`
`did you do any independent searches such as online 09:06:23
`
`searches? 09:06:27
`
` A As part of the -- I had looked at for the, you 09:06:29
`
`know, definitions, and yes, I did. 09:06:31
`
` Q And can you please describe what searches you 09:06:34
`
`performed in order to prepare to testify today? 09:06:37
`
` A As I sit here today? At least the one that I 09:06:40
`
`recall were the -- as part of preparing my declaration, 09:06:42
`
`I had looked at various terms that I used, so I referred 09:06:47
`
`to dictionaries available. 09:06:53
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 8
`
`8
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
` Q Did you review any dictionary definitions that 09:06:57
`
`you did not subsequently cite in either of your 09:06:59
`
`two declarations? 09:07:03
`
` A Not that I sit here, can I recall. 09:07:04
`
` Q You are not named on any patents regarding 09:07:07
`
`navigation systems; correct? 09:07:18
`
` A That is correct. 09:07:20
`
` Q You have not worked at a company that has 09:07:21
`
`manufactured navigation systems; correct? 09:07:23
`
` A That is correct. 09:07:26
`
` Q You have not received any formal training 09:07:27
`
`regarding navigation systems; correct? 09:07:30
`
` A I wouldn't say that -- 09:07:33
`
` Q What -- 09:07:36
`
` A -- because navigation is a broad material. It 09:07:36
`
`includes indexing. It includes retrieving data. So the 09:07:39
`
`underlying technologies in navigation is to seek data, 09:07:45
`
`to seek specific amount of data, to identify a location, 09:07:51
`
`and then display that. 09:07:55
`
` So I have worked on several individual 09:07:58
`
`projects that use those technologies. 09:08:02
`
` Q You understand that the '347 patent relates to 09:08:10
`
`a particular navigation system; correct? 09:08:13
`
` A '347 describes a way of using, in a displaying 09:08:16
`
`map that includes the -- some of the technologies that I 09:08:23
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 9
`
`9
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
`referenced before. 09:08:26
`
` Q And I want to talk about those technologies 09:08:27
`
`because you seem to make a distinction between 09:08:29
`
`technologies for navigation and underlying technologies 09:08:32
`
`that enable technologies for navigation. 09:08:35
`
` Focusing just on technologies for navigation, 09:08:38
`
`have you received any formal training regarding 09:08:41
`
`navigation systems? 09:08:44
`
` A I will say yes, because I have worked on, you 09:08:45
`
`know, computer graphics, the indexing. I have worked 09:08:48
`
`with -- I have had the formal training in my master's 09:08:50
`
`degree for, you know, how to index a file and how to 09:08:55
`
`optimally compress and how to display. 09:08:58
`
` So those are the technologies. Whether you 09:09:01
`
`call them as underlying or related, they are the one 09:09:04
`
`that are used in navigation. 09:09:07
`
` Q Please provide your understanding of what 09:09:20
`
`qualifies as a navigation system. 09:09:22
`
` A So, again, it's a broad term. So navigation 09:09:26
`
`typically to me would mean that it could have the 09:09:30
`
`ability to identify a location, ability to then access 09:09:34
`
`the data related to that location. 09:09:41
`
` That could include cartographic maps. It 09:09:45
`
`could include the places of interest. So various 09:09:49
`
`related data needs to be accessed. 09:09:52
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 10
`
`10
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
` And it also includes identifying, you know, 09:09:54
`
`understanding the routing and the optimal place of -- 09:10:00
`
`optimal way of routing the -- from the point from A to 09:10:02
`
`B. 09:10:10
`
` Q Are you familiar with various routing 09:10:10
`
`algorithms in the art? 09:10:12
`
` A I'm generally familiar with the routing 09:10:16
`
`algorithms. 09:10:16
`
` Q Please identify each routing algorithm of 09:10:18
`
`which you're aware. 09:10:22
`
` A So what you could do is you could identify 09:10:22
`
`your source to destination and then look at all the 09:10:24
`
`available alternatives and find the optimal path. And 09:10:28
`
`within that -- that's the overall intent. 09:10:31
`
` And then within that, there are several 09:10:34
`
`different ways that you could do. You could find, you 09:10:36
`
`know, predetermined paths that are far well known and 09:10:39
`
`then build around it for the end miles, the last twins. 09:10:43
`
` You could also take the two points and find 09:10:49
`
`all the port possible -- that's the worst case -- all 09:10:54
`
`possible opportunities to traverse from A to B, and then 09:10:58
`
`look at what is the most optimal. 09:11:00
`
` Or as I said, that, you know, you look at 09:11:04
`
`segments that are predetermined that if I'm going from A 09:11:09
`
`to B, I would take this, and then you can categorize or 09:11:15
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 11
`
`11
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
`identify within those segments. 09:11:18
`
` Q You identified three elements of a navigation 09:11:20
`
`system: One, identifying location; two, accessing data 09:11:22
`
`for the location; and three, optimal routing. 09:11:25
`
` You've given me examples of optimal routing. 09:11:28
`
`I would now like for you to give me examples of 09:11:31
`
`identifying a location. Please identify each example 09:11:33
`
`that you know of for identifying a location for an 09:11:36
`
`entity or a person. 09:11:39
`
` A Okay. So there are at least three I will 09:11:40
`
`describe that come to my mind as I sit here. 09:11:46
`
` One is essentially seeking fixed -- so at the 09:11:50
`
`highest level, identifying fixed points, and then two or 09:11:52
`
`more fixed points and then triangulate to identify a 09:11:57
`
`location. And then depending on the accuracy that you 09:12:00
`
`would want, you would seek out more points, fixed 09:12:06
`
`points. 09:12:08
`
` So that is the underlying concept. That is 09:12:10
`
`one concept that you could use. 09:12:14
`
` In that, you could have things like what the 09:12:15
`
`cell phone would do, like you have a cell phone 09:12:17
`
`stations, base stations that are known to be in a fixed 09:12:21
`
`place, you know, that coordinates. And then you figure 09:12:24
`
`out the time for the cell phone data to come to -- or 09:12:27
`
`the signal to come to you, and then you triangulate and 09:12:29
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 12
`
`12
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
`identify. 09:12:32
`
` The second is in the airplane, there were 09:12:33
`
`beacons that were laid out all over the world. And then 09:12:35
`
`you would -- and each beacon had a unique identifier 09:12:38
`
`that you would associate with. And then you would look 09:12:41
`
`at the time signal that is received from that with the 09:12:43
`
`time stamp. 09:12:49
`
` The third is the United States Department of 09:12:49
`
`Defense, the GPS system that you all are familiar with. 09:12:52
`
`The GPS system has 24 satellites, and then you will use 09:12:57
`
`the same, essentially the technology. Each one will 09:13:01
`
`identify what -- each one will identify which particular 09:13:03
`
`satellite it is and what the time stamp is, and then you 09:13:08
`
`triangulate based on that. 09:13:12
`
` And then, of course, there is a Russian 09:13:14
`
`satellite, and now there are a lot of other countries 09:13:15
`
`that are putting up their satellite-based navigation 09:13:20
`
`system. 09:13:22
`
` Q Are you familiar with inertial navigation 09:13:23
`
`systems? 09:13:26
`
` A Inertial? I-n-i -- inertial? Inertial, yes? 09:13:26
`
` Q Correct. 09:13:34
`
` A No. 09:13:34
`
` Q Okay. Using your definition of a navigation 09:13:35
`
`system as something that identifies a location, access 09:13:38
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 13
`
`13
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
`the data for the location, and has an optimal routing 09:13:40
`
`element -- 09:13:43
`
` A There's one other thing. We have not 09:13:43
`
`finished. 09:13:45
`
` Q Oh. I apologize. I didn't mean to -- 09:13:46
`
` A It's all right. And then -- 09:13:49
`
` Q In order to ensure a clear transcript, it's 09:13:49
`
`helpful if I have a clear question and you have a clear 09:13:52
`
`answer. So I will stop talking when you do, and I 09:13:54
`
`appreciate the reciprocal courtesy. 09:13:56
`
` A I will try. 09:14:01
`
` Q You said there was a fourth part that you 09:14:02
`
`would like to add to your definition of a navigation 09:14:03
`
`system. What is that fourth one? 09:14:06
`
` A The fourth one would be the display of the 09:14:08
`
`actual maps that is to be shown to the user. Thank you. 09:14:09
`
` Q Using that four-part definition of what 09:14:19
`
`qualifies as a navigation system -- you have never -- 09:14:21
`
`I'm going to ask you a series of questions. You have 09:14:24
`
`never been a member of an organization that was 09:14:26
`
`dedicated to navigation systems; correct? 09:14:29
`
` A It's a broad question. But as I sit here 09:14:38
`
`today, I can't think of... 09:14:40
`
` Q You never wrote source code for a navigation 09:14:42
`
`system; correct? 09:14:45
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 14
`
`14
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
` A I have written several source code for 09:14:47
`
`indexing part. I have written several source code 09:14:50
`
`examples of how to display the part -- display the 09:14:54
`
`image. 09:14:59
`
` I have written several programs that would 09:15:00
`
`relate to each of those individual piece of taking the 09:15:04
`
`data from a serial port and then making sure you find 09:15:09
`
`the data stream and then projecting it onto a display. 09:15:12
`
` Q For what navigation system did you write 09:15:17
`
`source code? 09:15:20
`
` A Again, I'm going to say it works -- it relates 09:15:23
`
`to the individual underlying systems. So we have -- I 09:15:26
`
`have written code that would take huge amount of data, 09:15:31
`
`put it into a separate file. Then you go and identify 09:15:35
`
`the right file to be displayed. 09:15:38
`
` Akin to the navigation system which you are 09:15:40
`
`just identifying, that's the part of identifying the 09:15:43
`
`optimal -- optimally identifying the data. 09:15:47
`
` I have done the graphics display of, you know, 09:15:49
`
`both the ASCII characters as well as the CRT, as well as 09:15:53
`
`the LCD. 09:15:57
`
` I go back to those days where I have done and 09:16:00
`
`used the displays of various kinds and then deciding 09:16:02
`
`which kind of a display, push the data accordingly. 09:16:04
`
` I have worked on determining what is the best 09:16:09
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 15
`
`15
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
`way to identify how to look for a specific data that 09:16:11
`
`relates, so indexing it. So remember that -- 09:16:20
`
` Q So I understand that you can write a storage 09:16:29
`
`program and formulate an array. And I understand that 09:16:31
`
`you can write various graphic elements that are going to 09:16:33
`
`a graphics card, all of which could subsequently be used 09:16:37
`
`in a navigation system. 09:16:40
`
` My question is, what navigation system itself, 09:16:41
`
`using your four-part definition of what qualifies as a 09:16:44
`
`navigation system, have you written source code for? 09:16:48
`
` A I have -- if you're asking about written, no. 09:16:51
`
`But I have reviewed individual components of the -- see, 09:16:54
`
`I think -- I don't know what the underlying question is. 09:16:59
`
`But I think if you have done -- you know, we wouldn't 09:17:03
`
`have all done math, addition of 468 plus 273. But we 09:17:08
`
`know how to get there if we had to. In past, if you ask 09:17:13
`
`me a particular mathematical problem, I may not have 09:17:16
`
`solved that particular math problem. 09:17:19
`
` Q And I'm asking you today the particular math 09:17:23
`
`problem of a navigation system. 09:17:25
`
` A All right. 09:17:26
`
` Q So I understand that you may have done 09:17:26
`
`graphics, but I'm saying graphics in a navigation 09:17:27
`
`system. I understand you may have done various storage 09:17:30
`
`systems in your life, but I'm saying storage in 09:17:36
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 16
`
`16
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
`navigation systems. 09:17:39
`
` You have never taught a class in navigation 09:17:41
`
`systems; correct? 09:17:43
`
` A That is correct. 09:17:44
`
` Q You have never authored a publication in 09:17:45
`
`navigation systems; correct? 09:17:47
`
` A Correct. 09:17:48
`
` Q You have never attended a conference 09:17:49
`
`explicitly on navigation systems; correct? 09:17:51
`
` A As I sit here, I have attended, in younger 09:17:55
`
`days, several conferences. And there may have been 09:17:59
`
`paper related to navigation system because I worked in 09:18:03
`
`the IEEE. So I'm not going to say yes or no to that. 09:18:06
`
`And I'm going to say that I don't know, as I sit here 09:18:11
`
`today. I cannot recall. 09:18:13
`
` Q Have you ever attended as ESRI conference? 09:18:14
`
` A Sorry. E-S-R-I? 09:18:18
`
` Q Yes. 09:18:21
`
` A No. 09:18:21
`
` Q Do you know what ESRI is? 09:18:22
`
` A Yes, I do. 09:18:24
`
` Q What is it? 09:18:25
`
` A ESRI is the one that guides the standards 09:18:25
`
`for -- by the way, we have -- and we can talk about when 09:18:27
`
`we -- you'll ask appropriate question about they have 09:18:29
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 17
`
`17
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
`a -- ArcGIS related standards. I've worked on that. 09:18:34
`
` Q You're familiar with the term GIS? 09:18:39
`
` A Yes, I am. 09:18:41
`
` Q You have? 09:18:42
`
` A Yes. 09:18:42
`
` Q GIS stands for what, sir? 09:18:42
`
` A Geographical information system. 09:18:44
`
` Q Have you ever attended a conference on GIS? 09:18:46
`
` A Actually, quite interestingly, yes. I have 09:18:49
`
`attended, in either 2007 or 2008, a conference on the 09:18:51
`
`vendors of GIS in the State of -- Commonwealth of 09:19:02
`
`Massachusetts. 09:19:05
`
` Q What was the name of that conference? 09:19:08
`
` A It was a vendor -- it was arranged by the 09:19:13
`
`State from the vendors who are providing the GIS data -- 09:19:14
`
`GIS services or products. 09:19:17
`
` Q Before this case, you have never served as an 09:19:21
`
`expert before in a case on navigation systems; correct? 09:19:24
`
` A That is correct. 09:19:29
`
` Q You do not consider yourself an expert on the 09:19:33
`
`state of navigation systems in the mid 1990s; correct? 09:19:36
`
` A No, I wouldn't think so. 09:19:41
`
` Q You also do not consider yourself -- 09:19:43
`
` A I'm sorry, by the way. I'm denying your -- 09:19:44
`
`just so to be clear. 09:19:47
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 18
`
`18
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
` Q Oh. 09:19:49
`
` A I'm saying, No, I do not agree with your 09:19:49
`
`statement. Because your question was, Do you agree 09:19:53
`
`that -- 09:19:54
`
` Q I see. 09:19:54
`
` A -- you are not an expert. So I just want to 09:19:54
`
`clarify, and it could be so. Sorry. Thank you. 09:19:56
`
` Q In your opinion, you are an expert on the 09:20:01
`
`state of navigation systems, as such, in the mid 1990s; 09:20:02
`
`correct? 09:20:07
`
` A Can you repeat that? Because the correct 09:20:09
`
`emphasis was strong, so I want to make sure of that. 09:20:11
`
` Q In your opinion, you are an expert on the 09:20:14
`
`state of navigation systems, as such, in the mid 1990s; 09:20:17
`
`correct? 09:20:22
`
` A No. So... 09:20:23
`
` I consider myself an expert or you don't 09:20:27
`
`consider yourself -- can you please? Sorry. Could you 09:20:29
`
`please repeat that question? 09:20:32
`
` Q I'll make this easy. Are you or are you not 09:20:33
`
`an expert on the state of navigation systems, as such, 09:20:37
`
`in the mid 1990s? 09:20:42
`
` A I believe that I am very familiar with the 09:20:44
`
`state of navigation systems in the mid '90s for various 09:20:47
`
`reasons. A definition of "expert" is a relative term, 09:20:50
`
`Veritext Legal Solutions
`866 299-5127
`
`Page 19
`
`19
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`Jay Bhatia
`
`but I consider myself to be quite knowledgeable about 09:20:54
`
`what were the prevailing alternatives available. I 09:20:58
`
`am -- I'm quite familiar with the underlying 09:21:01
`
`technologies. And I'm quite familiar with the products 09:21:04
`
`that were being offered at that time. 09:21:09
`
` Q Please identify each person that you consider 09:21:12
`
`to be an expert in the state of navigation technologies 09:21:15
`
`in the 1990s. 09:21:19
`
` A As I sit here now? I wouldn't -- I mean, why 09:21:21
`
`would I want to know the experts? So it's a relative 09:21:25
`
`term, again. I know several people who are very 09:21:29
`
`familiar with navigation systems such as myself. 09:21:32
`
` Q Can you identify any that you consider to be 09:21:36
`
`an expert in those technologies, navigation systems, as 09:21:38
`
`such, in the mid 1990s? 09:21:42
`
` A So I'm trying to recall the name, but I don't 09:21:57
`
`now. I'll come back to you on that. 09:22:05
`
` Q Who is the father of GIS? 09:22:07
`
` A As I sit
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
