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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`--------------------------------:
`AMERICAN HONDA MOTOR CO., INC., :
`et al., :
` : Case
` Petitioner, : IPR2015-01004
` :
` vs. : Patent 6,012,007
` :
`SIGNAL IP, INC., :
` :
` Patent Owner. :
`--------------------------------:
`
` Washington, D.C.
` Tuesday, December 1, 2015
`Deposition of:
`
` KIRSTEN M. CARR
`called for oral examination by counsel for
`Patent Owner, pursuant to notice, at Fish &
`Richardson, P.C., 1425 K Street, Northwest, 11th
`Floor, Washington, D.C., before Erick M. Thacker,
`RPR, of Capital Reporting Company, a Notary Public
`in and for the District of Columbia, beginning at
`8:55 a.m., when were present on behalf of the
`respective parties:
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2015
`
`American Honda v. Signal IP
`IPR2015-01004 Ex. 2001
`
`
`
`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`--------------------------------:
`AMERICAN HONDA MOTOR CO., INC., :
`et al., :
` : Case
` Petitioner, : IPR2015-01004
` :
` vs. : Patent 6,012,007
` :
`SIGNAL IP, INC., :
` :
` Patent Owner. :
`--------------------------------:
`
` Washington, D.C.
` Tuesday, December 1, 2015
`Deposition of:
`
` KIRSTEN M. CARR
`called for oral examination by counsel for
`Patent Owner, pursuant to notice, at Fish &
`Richardson, P.C., 1425 K Street, Northwest, 11th
`Floor, Washington, D.C., before Erick M. Thacker,
`RPR, of Capital Reporting Company, a Notary Public
`in and for the District of Columbia, beginning at
`8:55 a.m., when were present on behalf of the
`respective parties:
`
`(866) 448 - DEPO
`www.CapitalReportingCompany.com © 2015
`
`American Honda v. Signal IP
`IPR2015-01004 Ex. 2001
`
`
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`2
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
`
`1 A P P E A R A N C E S
`2 On behalf of Petitioner:
`3 JOSHUA A. GRISWOLD, ESQUIRE
` Fish & Richardson, P.C.
`4 3200 RBC Plaza
` 60 South Sixth Street
`5 Minneapolis, Minnesota 55402
` (612) 335-5070
`6 griswold@fr.com
`7 On behalf of Patent Owner:
`8 TAREK N. FAHMI, ESQUIRE
` Ascenda Law Group, P.C.
`9 333 West San Carlos Street
` Suite 200
`10 San Jose, California 95110
` (866) 877-4883
`11 patents@ascendalaw.com
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`
` * * * * *
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`American Honda v. Signal IP
`IPR2015-01004 Ex. 2001
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 C O N T E N T S
`2 EXAMINATION BY: PAGE
`3 Counsel for Patent Owner 4
`
`3
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`4 5 6 7 8 9
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`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21 (*No exhibits were marked.)
`22
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`American Honda v. Signal IP
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 P R O C E E D I N G S
`2 WHEREUPON,
`3 KIRSTEN M. CARR
`4 called as a witness, and having been first duly
`5 sworn, was examined and testified as follows:
`6 EXAMINATION BY COUNSEL FOR PATENT OWNER
`7 BY MR. FAHMI
`8 Q Would you state your name for the
`9 record, please?
`10 A Kirsten Carr.
`11 Q Dr. Carr, my name is Tarek Fahmi. Good
`12 morning. And as you know, we're here today for
`13 your deposition in connection with a declaration
`14 that you submitted in Inter Partes Review
`15 2015-01004 before the U.S. Patent Office, and
`16 that proceeding concerns U.S. Patent 6,012,007.
`17 Do you understand that?
`18 A Yes.
`19 Q Have you ever been deposed before?
`20 A Yes.
`21 Q How many times?
`22 A Seven.
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 Q When was the most recent one?
`2 A I believe in 2012.
`3 Q Okay. Just a couple of reminders,
`4 then. During today's proceeding, I'll be asking
`5 questions and you'll be providing answers, but if
`6 at any time I ask a question that is unclear or
`7 you didn't hear or you didn't understand, just
`8 let me know. I'll be happy to repeat it or
`9 rephrase it if it was unclear. Okay?
`10 A Okay.
`11 Q And also, by the same token, if you
`12 answer a question and you haven't asked me to
`13 clarify it, I'm going to assume that you're
`14 answering the question that I've asked.
`15 Is that fair?
`16 A That is fair.
`17 Q And as you're doing now, if you'd
`18 please continue to give audible answers, that
`19 helps the court reporter do his job. He has a
`20 difficult time taking down things like nods of
`21 the head or shrugs of the shoulder, that sort of
`22 thing, so audible answers, please.
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 A Okay.
`2 Q And also, as you're doing now, if
`3 you'll be so kind as to wait before you give your
`4 answer until I've finished asking the questions,
`5 I'll try and extend the same courtesy and wait
`6 until you've finished answering before I ask
`7 another question. That also helps the court
`8 reporter, makes it easier. He only has to take
`9 down one person speaking at a time.
`10 Is that all right?
`11 A That's fine.
`12 Q Is there any reason why you can't give
`13 your best testimony here today?
`14 A No.
`15 Q Are you taking any medications that
`16 might affect your memory or your ability to
`17 testify truthfully?
`18 A No.
`19 Q Any other reason you couldn't give your
`20 best testimony today?
`21 A No reasons.
`22 Q Do you have any questions before we
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 begin?
`2 A No, I don't.
`3 (Document tendered.)
`4 MR. GRISWOLD: Thank you.
`5 MR. FAHMI: Sure.
`6 BY MR. FAHMI
`7 Q Dr. Carr, I've handed you what's been
`8 previously marked as Exhibit 1004.
`9 Do you recognize this exhibit?
`10 A Yes.
`11 Q What do you recognize it as?
`12 A I recognize it as a patent by Schousek.
`13 Q And this is U.S. Patent 5,474,327; is
`14 that right?
`15 A That is correct.
`16 Q Was the Schousek patent one of the
`17 references that you considered during the
`18 preparation of your declaration in this
`19 proceeding?
`20 A Yes, it is.
`21 Q When's the last time you had an
`22 opportunity to review it?
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 A Yesterday.
`2 Q Well, I'm going to ask you some
`3 questions about the Schousek patent, and if at
`4 any time you feel you need to review any portion
`5 of the reference in order to answer those
`6 questions, you should feel free to do so. Okay?
`7 A Okay.
`8 Q Let's turn to Figure 5A, please.
`9 Would you agree that Figure 5A shows
`10 part of a flow chart that represents a computer
`11 program for seat occupant detection and
`12 supplemental inflatable restraint control?
`13 A Yes.
`14 Q Do you see reference in the flow chart
`15 to a total weight parameter?
`16 A Yes, I do.
`17 Q What would the person of ordinary skill
`18 in the art understand the total weight parameter
`19 that is referred to in Figure 5A to be?
`20 A They would have that weight be the
`21 weight of the object or person occupying the
`22 seat.
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`Capital Reporting Company
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`1 Q And how is that determined, according
`2 to Schousek?
`3 A According to Schousek, it is determined
`4 by sensors that are in the seat and -- may I
`5 reference --
`6 Q Yeah, please.
`7 A It is determined by sampling the
`8 voltages on the sensors and subtracting a
`9 calibration value from those voltages and then
`10 summing those voltages.
`11 Q Let's go back to Figure 5A. I'm
`12 looking at the decision block labeled 72, and
`13 there's reference to a maximum infant seat
`14 threshold. Do you see that?
`15 A I do.
`16 Q What would the person of ordinary skill
`17 in the art understand the maximum infant seat
`18 threshold to be?
`19 A It would be a value representing the
`20 maximum weight that the sensor system would see
`21 when a infant seat is in -- in the passenger seat
`22 of the vehicle.
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 Q And if it's determined that the total
`2 weight parameter is greater than the maximum
`3 threshold for an occupied infant seat, air bag
`4 deployment is permitted; is that right?
`5 A Correct.
`6 Q And now looking at decision block 76,
`7 do you see the reference to a minimum infant seat
`8 threshold?
`9 A Yes, I do.
`10 Q What would the person of ordinary skill
`11 in the art understand the minimum infant seat
`12 threshold to be?
`13 A That would be the lightest weight,
`14 hence the minimum weight that the sensor system
`15 would measure when an infant seat is in the
`16 passenger -- front passenger seat of the vehicle.
`17 Q And according to the flow chart in
`18 Figure 5A, if it's determined that the total
`19 weight parameter is less than the minimum
`20 threshold for an occupied infant seat, then air
`21 bag deployment is inhibited; is that right?
`22 A That is correct.
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 Q And also according to the flow chart in
`2 Figure 5A, if the total weight parameter is
`3 determined to be between the minimum and maximum
`4 infant seat thresholds, then the determination
`5 about whether or not to deploy the air bag
`6 depends on other factors; is that right?
`7 A That is correct.
`8 Q And if we look at column 5, lines 42
`9 through 50, Schousek describes some of those
`10 other factors, right?
`11 A Yes.
`12 Q So, for example, one of the factors
`13 would depend upon where the center of weight
`14 distribution is with respect to some reference
`15 line, correct?
`16 A Correct.
`17 Q Let's look at Figure 5B. At the top of
`18 Figure 5B, there's a reference label C.
`19 Do you see that?
`20 A I do.
`21 Q And at the bottom of Figure 5A, there's
`22 also a reference label C; do you see that?
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 A Yes, I do.
`2 Q Would the person of ordinary skill in
`3 the art understand that Figure 5B is a
`4 continuation of Figure 5A, then?
`5 A Yes, they would.
`6 Q So this is a continuation of the flow
`7 diagram that represents the computer program for
`8 seat occupant detection and supplemental
`9 inflatable restraint control; is that right?
`10 A Yes, that is.
`11 Q And in particular, Figure 5B includes
`12 what Schousek describes as fault monitoring; is
`13 that correct?
`14 A Yes, that is.
`15 Q And in particular, the faults are
`16 detected by comparing the inhibit or permit
`17 decisions reached in a series of loops; is that
`18 right?
`19 A Yes, that is.
`20 Q Can you describe those loops, please?
`21 MR. GRISWOLD: Objection. Form.
`22
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 BY MR. FAHMI
`2 Q Did you understand the question,
`3 Doctor?
`4 A Can you repeat it?
`5 Q Sure. So you see in Figure 5B, there
`6 is -- well, there actually are a couple of
`7 different loops, right?
`8 A Yes, there are.
`9 Q And one of the loops includes steps
`10 100, 102 and 104. Do you see that?
`11 A I do see that.
`12 Q Can you describe what is transpiring in
`13 those steps?
`14 A I can. So, when all of the five
`15 decisions are the same, that's in step 98. Then
`16 it moves to the step labeled 100, and it
`17 transmits a decision to the SIR module. And then
`18 the current decision is now the previous
`19 decision, and the fault decision center is
`20 cleared.
`21 Q So you started your description at, I
`22 think, step 98 with the decision block asking are
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 all five decisions the same, right?
`2 A Correct.
`3 Q Let's back up a bit, then, and see if
`4 we can decide what those decisions are.
`5 At step 90, the flow chart indicates
`6 that that decision is stored in an array,
`7 correct?
`8 A Correct.
`9 Q Which decision is that?
`10 A That is the decision that resulted from
`11 the flow chart in Figure 5A.
`12 Q So this is a decision concerning
`13 whether or not air bag deployment is permitted or
`14 inhibited, correct?
`15 A Correct.
`16 Q And after that decision is stored in
`17 the array at step 90, the flow chart in Figure 5B
`18 proceeds to a decision block at step 92, right?
`19 A That is correct.
`20 Q And at that decision point, the program
`21 determines whether less than five such decisions
`22 have been stored, right?
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`Capital Reporting Company
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`1 A Correct.
`2 Q What happens if less than five
`3 decisions have been stored?
`4 A The decision counter is incremented,
`5 and the flow chart goes to the return box.
`6 Q What happens when the flow chart goes
`7 to the return box?
`8 A It goes back over to the algorithm part
`9 in Figure 5A.
`10 Q So that would compute another decision
`11 as to whether or not air bag deployment is
`12 permitted or inhibited; is that right?
`13 A That is correct.
`14 Q And this looping process continues
`15 until five decisions have been stored in step 92;
`16 is that right?
`17 A That is correct.
`18 Q What happens when five decisions have
`19 been stored?
`20 A Then the decision counter is cleared,
`21 and then the five decisions are compared to see
`22 if all five decisions are the same.
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 Q So this is the five decisions that have
`2 just been stored in the array are compared with
`3 one another at step 98, right?
`4 A Yes.
`5 Q And if all five decisions are the same,
`6 then the process that you outlined a few moments
`7 ago about transmitting the decision to the SIR
`8 module, making the current decision the previous
`9 decision and clearing the faulty decision center
`10 at steps 100, 102 and 104 takes place, right?
`11 A Correct.
`12 Q If we go back to the decision block at
`13 step 98, what happens if all of the five stored
`14 decisions are not the same?
`15 A When the five decisions are not the
`16 same, then the previous decision is transmitted
`17 to the SIR module.
`18 Q What would the previous decision be in
`19 that case?
`20 A The previous decision would be the --
`21 the decision that was set when -- if you go to
`22 98, when it said all the decisions are the same
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 and you have a yes, then it transmits that
`2 decision to the SIR module, and it labels that
`3 decision as the previous decision. So that would
`4 be the decision from the previous time that five
`5 decisions were all the same.
`6 Q Now, the very first time that the
`7 algorithm in Figure 5A is executed, how many
`8 decisions are made?
`9 A The very first time the -- the
`10 algorithm is executed would be the first time
`11 there's a decision.
`12 Q Is that decision stored?
`13 A No, it would not be.
`14 Q Wouldn't it be stored in step 90?
`15 A Oh, I'm sorry. It would be stored --
`16 yes, it is stored in the decision array. Thank
`17 you for the correction.
`18 Q Is it labeled as a previous decision?
`19 A It would not be.
`20 Q So the very first time through the
`21 process, there is no previous decision; is that
`22 right?
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 A That is correct.
`2 Q It's only after a first loop through a
`3 subsequent five decisions that there might be a
`4 previous decision; is that right?
`5 A That is right according to these flow
`6 charts; however, I do believe Schousek does
`7 discuss how the system initializes itself and
`8 begins.
`9 Q Where is that discussion?
`10 A I would have to look.
`11 Q Please.
`12 A Thanks.
`13 It appears I am wrong. There is not an
`14 initialization.
`15 Q Okay. So the first time through the
`16 algorithm in Figure 5A, the decision is stored in
`17 the array at step 90, correct?
`18 A Correct.
`19 Q But no previous decision is stored,
`20 correct?
`21 A Correct.
`22 Q And it's only after a subsequent five
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`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
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`1 decisions that a previous decision might be
`2 stored if all five of those decisions are the
`3 same, right?
`4 A Correct.
`5 Q And if they're not the same, there's
`6 still no previous decision stored, right?
`7 A Correct.
`8 Q And that stays that way until there are
`9 a series of five loops in which all the decisions
`10 are the same, correct?
`11 A Not quite.
`12 Q How is it different?
`13 A If a sequence of five decisions are not
`14 the same for -- until the maximum allowable
`15 unstable readings have been reached, then it will
`16 transmit a fault to the SIR module.
`17 Q What happens when a fault is
`18 transmitted to the SIR module?
`19 A The patent does not say what the SIR
`20 module does with that fault.
`21 Q If we look at column 6, lines 5 and 6,
`22 there's an indication that "Extended instability
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`Capital Reporting Company
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`1 triggers the fault signal which results in
`2 energizing the fault indicator 20."
`3 Do you see that?
`4 A I do see that.
`5 Q Other than energizing the fault
`6 indicator, though, Schousek does not provide any
`7 discussion about what happens during the fault
`8 condition, right?
`9 A Schousek does not provide any
`10 directions on what happens for the -- the allow
`11 or inhibit state of the air bag during fault
`12 decision, no.
`13 Q So we've -- we've just been through the
`14 algorithm part of the program in Figure 5A and
`15 the fault monitoring portion of the program in
`16 Figure 5B, and I'd like to ask you some questions
`17 about those processes.
`18 I'm going to pose a series of
`19 conditions that I'd like you to consider that may
`20 occur during the execution of these program steps
`21 and get your thoughts on what happens during
`22 those conditions. Okay?
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`1 A Okay.
`2 Q And if any of the hypotheticals that
`3 I'm going to pose are unclear, just let me know,
`4 and I'll try as best I can to clarify them.
`5 All right?
`6 A Okay.
`7 Q So, in the first example, I'd like you
`8 to consider a case where a previous decision has
`9 been stored to permit deployment of the air bag,
`10 and now assume that for each of the next five
`11 loops, the decision is to permit deployment.
`12 Do you have that situation in mind?
`13 A Yes, I do.
`14 Q And in this instance, the decisions
`15 from each of the iterations in the five loops are
`16 the same, right?
`17 A Correct.
`18 Q And each decision is to permit
`19 deployment. Okay?
`20 A Correct. Yes.
`21 Q According to the flow chart in Figure
`22 5B, this means the decision to permit deployment
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`Capital Reporting Company
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`1 will be the current decision, right?
`2 A The -- can you repeat that?
`3 Q Yes. So, again, the situation is that
`4 we have a previous decision to permit deployment,
`5 and in each of the five loops, a decision was to
`6 permit deployment. And so, in that case, the
`7 decision block at step 98 asking if all five
`8 decisions are the same would be yes, correct?
`9 A Correct.
`10 Q And the current decision would be to
`11 permit deployment, right?
`12 A That is correct.
`13 Q And that current decision will be
`14 transmitted to the SIR module at step 100, right?
`15 A Yes, it will be.
`16 Q And the current decision to permit
`17 deployment will now be the previous decision at
`18 step 102, right?
`19 A Yes.
`20 Q At this time, air bag deployment will
`21 be permitted, right?
`22 A Correct.
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`1 Q Okay. Let's go on to a second
`2 situation. Now, in this situation, I'd like you
`3 to assume that the previous decision was to
`4 inhibit deployment. Okay?
`5 A Okay.
`6 Q And that for each of the next five
`7 loops, the decision is to inhibit deployment.
`8 Okay?
`9 A Okay.
`10 Q Now, the current decision is to inhibit
`11 deployment, right?
`12 A Correct.
`13 Q And the current decision to inhibit
`14 deployment will be sent to the SIR module at step
`15 100, right?
`16 A Yes, it will be.
`17 Q And the current decision to inhibit
`18 deployment will be the previous decision at step
`19 102, right?
`20 A Correct.
`21 Q And at this time, air bag deployment
`22 will be inhibited, correct?
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`
`1 A Yes, it will.
`2 Q Okay. Let's consider a third case.
`3 Now I'd like you to assume that the previous
`4 decision was to inhibit deployment.
`5 A Okay.
`6 Q And for each of the next five loops,
`7 the decision is to permit deployment. Okay?
`8 A Okay.
`9 Q So, now, the current decision is to
`10 permit deployment, right?
`11 A Correct.
`12 Q And at step 100, the decision to permit
`13 deployment will be transmitted to the SIR module,
`14 right?
`15 A Yes, it will be.
`16 Q And the current decision will now be
`17 the previous decision at step 102, right?
`18 A Yes, it will be.
`19 Q And air bag deployment will now be
`20 permitted, correct?
`21 A Correct.
`22 Q Even though, previously, it was
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`1 inhibited, correct?
`2 A Yes, that's correct.
`3 Q Okay. And one last case to consider.
`4 So, this time, I'd like you to consider or assume
`5 that the previous decision was to permit
`6 deployment. Okay?
`7 A Okay.
`8 Q And assume that for each of the next
`9 five loops, the decision is to inhibit
`10 deployment. Okay?
`11 A Okay.
`12 Q Now the decision to inhibit deployment
`13 is the current decision, right?
`14 A Yes.
`15 Q And that current decision to inhibit
`16 deployment will be sent to the SIR module at step
`17 100, right?
`18 A Yes, it will be.
`19 Q And the current decision to inhibit
`20 deployment will now be the previous decision,
`21 right?
`22 A Correct.
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`1 Q And air bag deployment will now be
`2 inhibited; is that right?
`3 A Yes.
`4 (Document tendered.)
`5 Q Dr. Carr, this time I've handed you
`6 what's been previously marked as Exhibit 1001.
`7 Do you recognize this exhibit?
`8 A Yes, I do.
`9 Q What do you recognize it as?
`10 A As Patent 6,012,007.
`11 Q And this was one of the references that
`12 you considered during the preparation of your
`13 declaration in this proceeding; is that right?
`14 A Yes, it is.
`15 Q When's the last time you had an
`16 opportunity to review it?
`17 A Yesterday, I looked at some of the
`18 claims.
`19 Q Okay. Well, let's look at claim 1,
`20 please. In the last step -- excuse me -- the
`21 second to last step of claim 1, it reads:
`22 "Clearing the flag when the relative weight
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`1 parameter is below the unlock threshold for a
`2 time."
`3 Do you see that?
`4 A I do see that.
`5 Q Would the person of ordinary skill in
`6 the art understand that the flag that is recited
`7 in this step is the lock flag that is recited in
`8 the step for setting a lock flag?
`9 MR. GRISWOLD: Objection. Form.
`10 THE WITNESS: So the -- the clearing of
`11 flag in the relative weight parameter, that -- if
`12 you're reading this, you would most likely think
`13 that is the lock flag that's referenced above.
`14 BY MR. FAHMI
`15 Q Is that the conclusion that the person
`16 of ordinary skill in the art reading the claim
`17 would reach?
`18 A Yes.
`19 Q If we look at claim 17 in addition to
`20 the claim that's in the top of column 8, we see
`21 also the first step there is "set a lock flag,"
`22 and then a few lines down, beginning about line
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`1 6, we see "clear the flag."
`2 Do you see that?
`3 A I do see that.
`4 Q And would the person of ordinary skill
`5 in the art understand that the flag that is
`6 referenced in the step to clear the flag is the
`7 lock flag described in the step for set lock
`8 flag?
`9 A Yes.
`10 MR. FAHMI: I don't have any other
`11 questions. Thank you.
`12 MR. GRISWOLD: That's it?
`13 MR. FAHMI: Yes, sir.
`14 MR. GRISWOLD: Okay. I don't have any
`15 questions.
`16 MR. FAHMI: Thank you, Dr. Carr.
`17 (Whereupon, at 9:27 a.m., the
`18 deposition of KIRSTEN M. CARR
`19 was concluded.)
`20
`21 * * * * *
`22
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`1 CERTIFICATE OF NOTARY PUBLIC
`2 I, ERICK M. THACKER, the officer before whom
`3 the foregoing deposition was taken, do hereby
`4 certify that the witness whose testimony appears
`5 in the foregoing deposition was duly sworn by me;
`6 that the testimony of said witness was taken by
`7 me in stenotype and thereafter reduced to
`8 typewriting under my direction; that said
`9 deposition is a true record of the testimony
`10 given by said witness; that I am neither counsel
`11 for, related to, nor employed by any of the
`12 parties to the action in which this deposition
`13 was taken; and, further, that I am not a relative
`14 or employee of any counsel or attorney employed
`15 by the parties hereto, nor financially or
`16 otherwise interested in the outcome of this
`17 action.
`18 ________________________
` ERICK M. THACKER
`19 Notary Public in and for the
` District of Columbia
`20
`21
`22
`
`My commission expires:
`June 14, 2019
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`1 ACKNOWLEDGEMENT OF DEPONENT
`2
`3
`4
`5
`6
`7
`
`I, KIRSTEN M. CARR, do hereby acknowledge I have
`read and examined the foregoing pages of
`testimony, and the same is a true, correct and
`complete transcription of the testimony given by
`me, and any changes or corrections, if any, appear
`in the attached errata sheet signed by me.
`
`8 9
`
`10
`11
`12
`_____________ _____________________
`13 Date KIRSTEN M. CARR
`14
`15
`16
`17
`18
`19
`20
`21
`22
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`1 Joshua A. Griswold, Esquire
`Fish & Richardson, P.C.
`2 3200 RBC Plaza, 60 South Sixth Street
`Minneapolis, Minnesota 55402
`
`31
`
`3 4
`
`5 6
`
`IN RE: American Honda Motor Co., Inc., et al. vs.
` Signal IP, Inc.
`
`Dear Mr. Griswold:
`7 This letter is to advise you that the original
`8 transcript of KIRSTEN M. CARR taken in the above
`9 matter will be available for reading and signing
`10 in our office, Capital Reporting Company, located
`11 at 1821 Jefferson Place, Northwest, Washington,
`12 D.C. 20036, Monday through Friday, between the
`13 hours of 8:30 a.m. to 5:30 p.m. Please call (202)
`14 857-3376 in advance to set up a mutually-agreeable
`15 time.
`16 Pursuant to the rules, the transcript will be
`17 available for 30 days beginning December 8, 2015.
`18 If you have any questions, please do not
`19 hesitate to call. Thank you.
`20 Yours,
`21 Erick M. Thacker, RPR
`Reporter/Notary
`22
`cc: Tarek N. Fahmi, Esq.
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`1 Capital Reporting Company
`1821 Jefferson Place, NW
`2 3rd Floor
`Washington, D.C. 20036
`3 (202) 857-3376
`4 E R R A T A S H E E T
`5 Case Name: American Honda Motor Co., Inc., et al.
` vs. Signal IP, Inc.
`6
`Witness Name: KIRSTEN M. CARR
`7
`Deposition Date: Tuesday, December 1, 2015
`8
`Page No. Line No. Change/Reason for Change
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`____________________ ___________
`22 Signature Date
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`1
`1 1:10 26:19,21
`32:7
`100 13:10,16
`16:10 22:14
`23:15 24:12
`25:17
`1001 26:6
`1004 7:8
`102 13:10 16:10
`22:18 23:19
`24:17
`104 13:10 16:10
`11th 1:16
`14 29:22
`1425 1:16
`17 27:19
`1821 31:11 32:1
`
`2
`
`20 20:2
`200 2:9
`20036 31:12 32:2
`2012 5:2
`2015 1:10 31:17
`32:7
`2015-01004 4:15
`2019 29:22
`202 31:13 32:3
`
`3
`30 31:17
`3200 2:4 31:2
`333 2:9
`335-5070 2:5
`3rd 32:2
`
`Capital Reporting Company
`Carr, Kristen M. 12-01-2015
`Page 1
`877-4883 2:10
`
`9
`9:27 28:17
`90 14:5,17 17:14
`18:17
`92 14:18 15:15
`95110 2:10
`98 13:15,22
`16:3,13,22 22:7
`
`A
`a.m 1:20 28:17
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