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` UNITED STATES PATENT AND TRADEMARK OFFICE
` ____________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________________________
` DR. MICHAEL FARMWALD and RPX COPORATION
` Petitioner
`
` v.
` PARKERVISION, INC.,
` Patent Owner
`
` ____________________________
`
` Case IPR2014-00946
` Patent 6,266,518
` Case IPR2014-00947
` Patent 6,061,551
`
` Case IPR2014-00948
` Patent 6,370,371
` VOLUME 1 OF 3
`
` Thursday, May 28, 2015 - 10:01 a.m.
`
` Oral deposition of BRUCE A. FETTE,
` Ph.D., a witness, taken by Petitioner, pursuant
` to Notice, held at the Offices of Sterne,
` Kessler, Goldstein & Fox, P.L.L.C., 1100 New
` York Avenue NW, Washington, DC, before RYAN K.
` BLACK, a Registered Professional Reporter,
` Certified Livenote Reporter and Notary Public
` for the District of Columbia.
`
`Veritext Legal Solutions
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`Farmwald and RPX Exhibit 1065, pg. 1
`Farmwald and RPX v. ParkerVision
`IPR2014-00946
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`Page 1 of 46
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`VIRNETX EXHIBIT 2049
`Mangrove v. VirnetX
`Trial IPR2015-01047
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`Page 2
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`Page 4
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`1 I N D E X
`2 TESTIMONY OF: BRUCE A. FETTE, Ph.D. PAGE
`3 By Mr. Bailey..................................5
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`4 5 6
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` E X H I B I T S
`7 EXHIBIT DESCRIPTION PAGE
`8 * * * NO EXHIBITS MARKED * * *
`9
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`1 A P P E A R A N C E S:
`
`2 3
`
` OBLON SPIVAK
`4 BY: W. TODD BAKER, ESQ.
`5 1940 Duke Street
`6 Alexandria, VA 22314
`7 703.412.6383
`8 tbaker@oblon.com
`9 Representing - Dr. Michael Farmwald and RPX
`10 Corporation
`11
`12
`13 LAW OFFICE OF JAMES T. BAILEY
`14 BY: JAMES T. BAILEY, ESQ.
`15 504 West 136th Street, Suite 1B
`16 New York, New York 10031
`17 917.626.1356
`18 jtb@jtbaileylaw.com
`19 Representing - Dr. Michael Farmwald and RPX
`20 Corporation
`21
`22
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`24
`25
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`Page 3
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`Page 5
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`1 Whereupon --
`2 BRUCE A. FETTE, Ph.D.,
`3 called to testify, having been first duly sworn
`4 or affirmed, was examined and testified as
`5 follows:
`6 EXAMINATION
`7 BY MR. BAILEY:
`8 Q. Good morning, Dr. Fette. Have you
`9 been deposed before?
`10 A. Never.
`11 Q. Okay. Never served as an expert in
`12 any adversarial proceeding?
`13 A. That's correct.
`14 Q. Okay. I'm sure your counsel went over
`15 this, but I'll go over the ground rules anyway
`16 to make sure we're on the same page. I'll be
`17 asking questions. You'll be giving answers.
`18 Ryan writes down every word each one of us says.
`19 So Rule Number 1, because I've already
`20 met Ryan, he's a nice guy, let's try to make his
`21 day not horrible. So try to wait until I'm done
`22 with my question, and I'll try to do the same
`23 with your answers.
`24 Do you understand?
`25 A. Yes.
`
` A P P E A R A N C E S (Cont'd):
`
`1 2
`
`3 4
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` STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C
`5 BY: MICHAEL Q. LEE, ESQ.
`6 JOHN HARRIS CURRY, ESQ.
`7 CHRISTIAN A. CAMARCE, ESQ.
`8 1100 New York Avenue, NW
`9 Washington, D.C. 20005
`10 202.772.8674
`11 mlee@skgf.com
`12 jcurry@skgf.com
`13 ccamarce@skgf.com
`14 Representing - ParkerVision, Inc.
`15
`16
`17 ALSO PRESENT:
`18 Thomas F. Presson, Esq. - ParkerVision
`19 Asad Abidi, Ph.D.
`20 Gregory L. Pollaro
`21
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`Farmwald and RPX Exhibit 1065, pg. 2
`Farmwald and RPX v. ParkerVision
`IPR2014-00946
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`Page 2 of 46
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`Page 6
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`Page 8
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`1 Q. Okay. It's also important to give
`2 your answers verbally, as opposed to gestures
`3 like uh-huhs and mm-hmms. Do you understand?
`4 A. I do.
`5 Q. Also, at some point over the course of
`6 the deposition, probably more than once, I'm
`7 going to ask a question that you don't
`8 understand. If that happens, what I want you to
`9 do is tell me, hey, Jim, I don't understand your
`10 question. I'll do what I can to fix it. But if
`11 you don't tell me you don't understand, I'm
`12 going to assume that you did.
`13 Sound fair?
`14 A. Yes.
`15 Q. From time to time, your attorney
`16 may make objections to my questions. Do you
`17 understand that, unless he instructs you not to
`18 answer, you're to go ahead and answer to the
`19 best of your ability?
`20 A. Yes.
`21 Q. Okay. I take it -- I heard you've
`22 got some health problems. I'm sorry you're not
`23 feeling well. It doesn't affect your ability
`24 to testify fully and truthfully today, does it?
`25 A. That's correct.
`
`1 Apreotesi. When were you retained?
`2 A. Probably September time frame last
`3 year.
`4 Q. I was having trouble knowing what year
`5 to write.
`6 A. 2014.
`7 Q. I had to do the minus one. It took me
`8 a second. I'm sorry.
`9 So do you know -- in your
`10 declarations, you mentioned that you reviewed
`11 the patent owner's preliminary responses in
`12 these IPRs. Do you know if you were hired
`13 before or after those were filed?
`14 A. I don't know whether it was before or
`15 after.
`16 Q. All right. Do you have any
`17 recollection of helping in formulating those,
`18 the preliminary responses?
`19 A. I did not help with the formulation of
`20 the preliminary responses.
`21 Q. And, say, up through your declaration,
`22 how much work did you do on this case?
`23 A. I'm sorry. I'm trying to think about
`24 that.
`25 Q. Hard to remember, isn't it?
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`Page 7
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`Page 9
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`1 Q. Okay. Let's get down to business.
`2 When was the first time you heard of
`3 the patent owner in this case, ParkerVision?
`4 A. It was summer of last year.
`5 Q. And how did you hear about them?
`6 A. Phone call from somebody who asked me
`7 if I would be interested in being helpful on the
`8 topic.
`9 Q. Do you remember who that was?
`10 A. No, I do not, actually. Eventually, I
`11 ended up talking to Mario Apreotesi at McKool in
`12 Dallas, but I think it was somebody that was
`13 searching.
`14 Q. Okay. Now, are you retained by the
`15 law firm of McKool, as well?
`16 A. No.
`17 Q. Okay. So as far as working for
`18 ParkerVision, I know from your declaration
`19 and the fact that you're here today that you're
`20 working on these three IPRs. Are you doing
`21 other consulting or expert witness work for
`22 ParkerVision?
`23 A. No.
`24 Q. Okay. Okay. So some service calls
`25 you up, and you eventually talk to Mario
`
`1 A. Yes, it is.
`2 I'm going to guess it was in the order
`3 of 180 to 200 hours.
`4 Q. Did you do that work here in D.C. or
`5 in Maryland or wherever you live?
`6 A. Mostly, yes, it was at home and here.
`7 Q. Okay. Did you travel to Florida at
`8 all as part of your work?
`9 A. There were two visits to Florida.
`10 Q. When were those?
`11 A. Well, I certainly don't remember --
`12 Q. Just ballpark.
`13 A. -- the details, but I'm going to
`14 assume that it was, like, October or November.
`15 Q. Are you saying one was in October and
`16 one was in November?
`17 A. Yeah.
`18 Q. Okay. Let's start with the first one
`19 that you believe is around October. How long
`20 did you go down to Florida for?
`21 A. Just a couple days.
`22 Q. And what did you do down there?
`23 A. Well, I met the founder of the company
`24 and his chief engineer and his engineering team,
`25 and then we talked about how I would help them.
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`Farmwald and RPX Exhibit 1065, pg. 3
`Farmwald and RPX v. ParkerVision
`IPR2014-00946
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`Page 3 of 46
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`Page 12
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`1 Q. Okay. And when you say founder,
`2 you're talking about Jeff Parker?
`3 A. That's it, yes.
`4 Q. And chief engineer, David Sorrells?
`5 A. Yes.
`6 Q. Do you remember any of the names of
`7 the people on the engineering team?
`8 A. Greg Rawlins, Mike Rawlins, are the
`9 ones I remember.
`10 Q. Any attorneys there?
`11 A. Tom Preston.
`12 Q. And did they give you any materials to
`13 review?
`14 A. Well, they certainly gave me copies of
`15 the patents --
`16 Q. Sure.
`17 A. -- to review.
`18 Q. Anything else you can think of
`19 associated with the first meeting?
`20 A. No. That was all.
`21 Q. Okay. And how about the November
`22 meeting, or the November trip down to Florida,
`23 how long did you go down to Florida on that one?
`24 A. Well, again, it was two days.
`25 Q. Same cast of characters?
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`Page 11
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`1 A. Oh, yes.
`2 Q. Did you get any new documents?
`3 A. No, actually. I don't think so.
`4 Q. Do you think your conversations with
`5 Mr. Sorrells informed your opinions that you
`6 provided in your declaration?
`7 A. I came to understand his thinking
`8 about those patents.
`9 Q. So would you say Mr. Sorrells'
`10 opinions and his thinking about the patents
`11 influenced yours?
`12 A. No. The opinions that I have about
`13 the patents are my opinions.
`14 Q. Did you guys run any tests,
`15 simulations, anything while you were down
`16 there in either October or November?
`17 A. Not in -- not in those trip -- not in
`18 those two trips.
`19 Q. All right. Did you take any other
`20 two trips -- any other trips to Florida?
`21 A. Yes. After the IPR, is that the right
`22 phrase? Yeah. Yes. After they responded to
`23 the patent judges, there were two more trips in
`24 the spring.
`25 Q. Okay. And are those before or after
`
`1 you filed your declaration?
`2 A. I believe they were before.
`3 Q. Okay. When were these trips? Can you
`4 do better than the spring?
`5 A. February, March.
`6 Q. Okay. And the February trip, how long
`7 did you go down for?
`8 A. Again, both of them were two-day
`9 trips.
`10 Q. Okay. Let's start with the February.
`11 What did you do when you were down there?
`12 A. It was similar. I talked about my
`13 perception of the patents and the issues.
`14 Q. Same cast of characters?
`15 A. It was almost -- almost entirely
`16 Tom and Greg Rawlins and Mike Rawlins. Dave
`17 Sorrells and Jeff were not in attendance in
`18 February, that I can remember.
`19 Then in March, Jeff stopped by. But
`20 other than that, it was the same list.
`21 Q. Okay. And did you do any testing,
`22 analysis, simulation during the February trip?
`23 A. I did simulations during one of those
`24 two trips using their Cadence Spectre tools to
`25 do simulations and analysis.
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`Page 13
`1 Q. Had you used Cadence Spectre before
`2 then?
`3 A. I had not.
`4 Q. So who guided you through the process?
`5 A. Mike Rawlins.
`6 Q. So in addition to the trips to
`7 Florida, I assume you had other meetings with
`8 your attorneys?
`9 A. We had meetings here at these offices.
`10 Q. Lots of them?
`11 A. Many.
`12 Q. Okay. You have -- in your
`13 declaration, it's a fairly lengthy section on
`14 claim construction. Prior to working on this
`15 matter, you had never addressed claim
`16 construction before, had you?
`17 A. I had not addressed it from a legal
`18 perspective.
`19 Q. Okay. All right. So who informed
`20 your opinions on -- who told you how to do it?
`21 A. The notion of addressing claims is
`22 certainly something I've been involved in in the
`23 nearly 40 patents that I had developed when I
`24 was at Motorola and General Dynamics.
`25 The notion of understanding how to
`
`4 (Pages 10 - 13)
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`Farmwald and RPX Exhibit 1065, pg. 4
`Farmwald and RPX v. ParkerVision
`IPR2014-00946
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`Page 4 of 46
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`Page 14
`1 address claim construction was explained to me
`2 by the legal team here.
`3 Q. Okay. I'm just -- which ones? Which
`4 lawyers explained it to you?
`5 A. Led by Mike, Mike Lee, and with
`6 participation by the rest of the table.
`7 Q. So when you were at Motorola, you had
`8 never heard of ParkerVision?
`9 A. That's correct.
`10 Q. Never heard of them trying to pitch
`11 their technology to Motorola?
`12 A. That's correct.
`13 Q. Okay. I'll go ahead and give you your
`14 declaration, previously marked as Exhibit 2024.
`15 Just looking at the first page of
`16 text in Paragraph 3 you say, I have reviewed
`17 and am familiar with the specification and the
`18 claims of, and then I'm paraphrasing, '518, '551
`19 and '371 patents.
`20 How much time did just that take?
`21 A. It takes a long time to go through
`22 those patents. They're very long.
`23 Q. Yeah. Did you -- but you read through
`24 all three of the patents, right?
`25 A. Yes.
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`Page 16
`1 with the work that was done before you started,
`2 right?
`3 A. I'm unable to answer that, because
`4 I'm not familiar with work that was done before
`5 I started.
`6 Q. Well, it's in the preliminary
`7 statement, the preliminary patent owner's
`8 statement, which I believe you said you
`9 reviewed.
`10 A. I read that material.
`11 Q. Okay.
`12 A. I don't know the process that went
`13 into that.
`14 Q. No. I'm just asking, sitting
`15 here right now, you read the preliminary
`16 statements, --
`17 A. Mm-hmm.
`18 Q. -- which contained -- the patent
`19 owner's preliminary responses, which contained
`20 their claim construction positions, or at least
`21 some of them. To your knowledge, are any of
`22 your claim construction positions that are in
`23 Exhibit 2024 inconsistent with those that were
`24 previously developed by the patent owner?
`25 A. Not to my knowledge. They would be
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`Page 15
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`Page 17
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`1 Q. And did you read all the claims?
`2 A. Yes.
`3 Q. Even the ones that aren't asserted?
`4 A. Yes.
`5 Q. Okay. So when you say you're familiar
`6 with the claims, you're talking about the ones
`7 that were being challenged in the IPR, plus all
`8 of the other ones that show up in those patents?
`9 A. Let's say that I read all of the
`10 patents, but certainly we focused on the ones
`11 that are relevant to the IPR.
`12 Q. Did Mike Lee or one of the other
`13 lawyers tell you sometimes other claims in the
`14 patent can inform the construction of a
`15 different claim?
`16 MR. LEE: Objection. Work product.
`17 THE WITNESS: He did not say that, and
`18 I had not heard that.
`19 BY MR. BAILEY:
`20 Q. So as far as you know, the claim
`21 constructions that went into ParkerVision's
`22 preliminary responses, you weren't involved in
`23 helping formulate; is that correct?
`24 A. Yes. Correct.
`25 Q. But your constructions are consistent
`
`1 consistent.
`2 Q. Now, you're aware that the patents
`3 involved in these three IPRs were also involved
`4 in a litigation between ParkerVision and
`5 Qualcomm, correct?
`6 A. I'm aware.
`7 Q. Okay. You reviewed the petitions that
`8 were filed on behalf of my clients, correct?
`9 A. Yes.
`10 Q. Okay. And in those petitions, we
`11 cited some documents from that prior litigation.
`12 Did you go and actually review the documents
`13 from --
`14 A. No.
`15 (Whereupon Dr. Abidi entered the
`16 room.)
`17 BY MR. BAILEY:
`18 Q. Okay. And then, other than the
`19 descriptions and the text itself of the three
`20 petitions, did you -- were you provided, as part
`21 of your work on this case, any information from
`22 that litigation?
`23 A. No.
`24 Q. Did you ever speak to a gentleman
`25 named Dr. Paul Prucnal?
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`Farmwald and RPX Exhibit 1065, pg. 5
`Farmwald and RPX v. ParkerVision
`IPR2014-00946
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`1 A. No, not that I remember.
`2 Q. So in terms of whether the opinions
`3 you're providing are consistent with positions
`4 that ParkerVision took in the litigation or
`5 ParkerVision's previous experts took, you simply
`6 don't know?
`7 A. Correct.
`8 Q. Let's talk a little bit about noise
`9 figure. There's stuff in your report -- this
`10 is Dr. Abidi, by the way, who just entered.
`11 There's stuff in his report on noise figure.
`12 First of all, the concept of noise
`13 figure is not actually discussed in any of the
`14 three patents that are at issue in the IPRs,
`15 correct?
`16 A. Not correct.
`17 Q. Okay.
`18 A. In all of the patents, the notion of
`19 substantant -- let's see. Let me use the right
`20 phrase here -- non-negligible energy, is by
`21 reference to noise. And because it's by
`22 reference to noise, noise figure is the way in
`23 which anyone that was skilled in the art would
`24 choose to analyze that question. So each of the
`25 patents addresses the notion of non-negligible
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`1 figures you can expect to get for a given
`2 application.
`3 Q. Okay. So you agree with Dr. Abidi
`4 that noise figure is a important figure of merit
`5 in RF, correct?
`6 A. Yes.
`7 Q. Okay. And you did a calculation, it's
`8 in your report, on what you're calling an energy
`9 transfer sampler, and you came up with close to
`10 20 dB as the noise figure, right?
`11 A. 19.5, I believe, when there's no
`12 impedance matching.
`13 Q. Okay.
`14 A. At certain frequencies, 18.5 gigahertz
`15 and associated sampling rates and so forth, they
`16 all play into it.
`17 Q. But almost 20 dB is not a very good
`18 noise figure, is it?
`19 A. It's an excellent noise figure
`20 compared with the state of the art at the time
`21 for the bandwidth, for the carrier frequencies,
`22 for the sampling rates involved.
`23 Q. What are you basing that on?
`24 A. So I'm basing that on my experience
`25 as an engineer in the field in radio design in
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`Page 19
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`1 energy as relevant to noise, and anyone skilled
`2 in the art would choose to assess that through
`3 the noise figure measurement.
`4 Q. Okay.
`5 A. Noise figure measurement is commonly
`6 used by radio engineers as an important design
`7 property. Noise figure is essential to
`8 understanding the ability to have excellent
`9 communication range for a given receiver design.
`10 Q. Okay. There is -- the words noise
`11 figure together, or noise factor, don't appear
`12 in any one of the three patents, correct?
`13 A. Those words don't appear in the
`14 patent, but anyone skilled in the art would have
`15 to understand that.
`16 Q. All right. It doesn't give you any
`17 idea what the noise figure or noise factor would
`18 be in any of the patents, correct?
`19 A. That is correct. And,
`20 of course, it's application-dependent.
`21 It's situation-dependent. There's many design
`22 factors that affect what's going to be a
`23 practical noise figure. Bandwidth and carrier
`24 frequencies and antenna properties all play into
`25 the design and how and what kinds of noise
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`Page 21
`1 every -- radar design, in signal intelligence
`2 design. All of these domains have the
`3 importance of designing the receiver to be a
`4 high-performance receiver.
`5 Q. Right. But wouldn't just a simple,
`6 basic mixer that's been used for decades have a
`7 noise figure way below 20?
`8 A. Well, it depends an awful lot on the
`9 properties you're trying to accomplish with your
`10 receiver design.
`11 In this particular case, there was a
`12 lot -- a fairly wide bandwidth that was being
`13 analyzed.
`14 Q. In which particular case?
`15 A. In the cases that are discussed in
`16 this IPR.
`17 Q. So you think the patents require a
`18 wide bandwidth?
`19 A. The patents do not require a wide
`20 bandwidth.
`21 Q. And so why are we talking about wide
`22 bandwidth?
`23 A. Because in the IPR you brought in
`24 examples, particularly the Weisskopf example,
`25 which uses as one of the situations an 18.5
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`6 (Pages 18 - 21)
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`Farmwald and RPX Exhibit 1065, pg. 6
`Farmwald and RPX v. ParkerVision
`IPR2014-00946
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`Page 6 of 46
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`Page 22
`1 gigahertz carrier and a 30-megahertz bandwidth.
`2 Q. Okay. You mentioned the Friis paper
`3 in your declaration, and that's F-r-i-i-s. Had
`4 you read the Friis paper prior to your work on
`5 this case?
`6 A. The Friis equation, as it's
`7 commonly used by persons skilled in the art,
`8 is a standard equation that's used to analyze
`9 noise figure. And it is commonly used by any RF
`10 engineer that would analyze a receiver -- what
`11 we call an RF front end, the receiver's
`12 performance. So the first equation is the
`13 standard way of performing that analysis.
`14 Q. Okay. My question: You cite a Friis
`15 paper -- is it Freeze or Friis?
`16 A. Friis is the way I've always heard it
`17 pronounced.
`18 Q. I'll go with you. Start a new
`19 question:
`20 You cite a Friis paper from 1944 in
`21 your declaration. Had you ever read it before
`22 your work on this case?
`23 A. I had not read the paper, but, of
`24 course, was familiar with the principles of it.
`25 Q. Have you ever discussed how to
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`Page 23
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`1 calculate noise figure in a peer-reviewed
`2 journal that you authored?
`3 A. I have not authored peer-reviewed
`4 papers in the IEEE Communications Journal. But
`5 at every design review at Motorola, we would
`6 always include noise figure as part of the
`7 design review process.
`8 Q. Are you aware that in the 70 years
`9 since Friis published his paper that other
`10 engineers and scientists have formulated other,
`11 not identical, but equivalent equations for
`12 calculating noise figure?
`13 A. The IEEE standards are based on the
`14 Friis paper, and I'm satisfied with that.
`15 Q. So my question is, are you aware that,
`16 in the 70 years since the Friis paper, lots of
`17 engineers and scientists have developed other
`18 equations that are not identical to Friis, but
`19 are equivalent?
`20 A. I am not aware of other equations that
`21 are equivalent.
`22 Q. If we look at Exhibit 2024, on Page
`23 34, it's Paragraph 70, towards the bottom you
`24 say, noise figure may not be the most useful
`25 test of whether a circuit transfers
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`Page 24
`1 non-negligible amounts of energy. There are
`2 certainly other measures that can be used to
`3 judge this character.
`4 Is that still your opinion?
`5 A. Yes, sir.
`6 Q. Okay. But noise figure -- I thought
`7 earlier in your testimony you said it was a good
`8 way to measure whether there's non-negligible
`9 energy?
`10 A. It is a good way to assess
`11 non-negligible amounts of energy.
`12 Q. And, in fact, you use it to do just
`13 that. You take your simulation and you look
`14 at the results and you say, Weisskopf does not
`15 transfer non-negligible energy because of the
`16 noise figure, correct?
`17 A. That is correct, sir.
`18 Q. Okay. You say there are other
`19 measures. What are the other measures that
`20 you were thinking about when you wrote this?
`21 A. The performance of non-negligible
`22 energy can be determined not only by noise
`23 figure, but by the application and the utility
`24 in the application.
`25 So, for example, applications
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`Page 25
`1 other than cellular cell phone may have other
`2 important metrics that are important to the
`3 application, and the energy delivered is
`4 essential to a specific application, so a noise
`5 figure may not be the only way in which you
`6 assess the non-negligible energy.
`7 Q. Okay. I mean, you say there are
`8 certainly other measures. Is there one -- can
`9 you give me the name of another one?
`10 A. I would -- I do not want to offer the
`11 name of another one off the top of my head. I
`12 think it's application-dependent, and so I want
`13 to stick with that.
`14 Q. Okay. Have you heard of conversion
`15 loss?
`16 A. Oh, yes.
`17 Q. Could -- well, what's conversion loss?
`18 A. Okay. Well, conversion loss is a
`19 common term that is quite similar to noise
`20 figure, and in many, many applications
`21 it's nearly equal to the noise figure. The
`22 conversion loss is the effective energy loss
`23 in the -- what is typically the mixer of a more
`24 standard receiver design, and it is also a
`25 commonly used metric of a receiver's front end.
`
`Veritext Legal Solutions
`215-241-1000 ~ 610-434-8588 ~ 302-571-0510 ~ 202-803-8830
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`7 (Pages 22 - 25)
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`Farmwald and RPX Exhibit 1065, pg. 7
`Farmwald and RPX v. ParkerVision
`IPR2014-00946
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`Page 7 of 46
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`1 Q. Commonly used in wireless, right?
`2 A. Yes.
`3 Q. And would conversion loss
`4 also be a metric that, at least in wireless
`5 applications, could tell you something about
`6 whether non-negligible energy is transferred?
`7 A. As I said, they're quite closely
`8 related numbers. And so, yes, it can also
`9 inform you about receiver front-end performance.
`10 Q. Okay. All right. So starting on the
`11 same page there, Paragraph 71, it's your opinion
`12 that Dr. Abidi incorrectly performed the noise
`13 figure analysis, right?
`14 A. Correct.
`15 Q. Let me give you what's been previously
`16 marked as Exhibit 1004. It's Dr. Abidi's
`17 declaration.
`18 Okay. So starting with yours, in
`19 Paragraph 71, you have an equation, and this
`20 is what you referred to as the IEEE-approved
`21 definition, right?
`22 A. Yes.
`23 Q. Okay. Now, if we look at Dr. Abidi's
`24 report on Page 11, Equation 5.4, that's the same
`25 as the equation that you have in 71, right?
`
`1 the interface of the blocks in the block
`2 diagram.
`3 Because there's no indication of how
`4 he addresses the output energy -- the output
`5 impedances associated with the output voltages,
`6 it's difficult to assess how Equation 5.7
`7 addresses that.
`8 Q. Okay. And if you flip forward to Page
`9 15, Section 5.4, --
`10 A. In which document?
`11 Q. Dr. Abidi's.
`12 -- that section describes the impact
`13 of the load resistance, right?
`14 A. I'm sorry. What -- what describes the
`15 impact?
`16 Q. Section -- he uses section -- let me
`17 withdraw.
`18 If you see that, there's a Section 5
`19 -- this is all very confusing with myself.
`20 Withdrawn. Stop.
`21 Dr. Fette, if you just look at Page 15
`22 of Dr. Abidi's declaration, Exhibit 1004, at the
`23 bottom, there's a Section 5.4, Resistive Leakage
`24 on Hold Capacitor.
`25 Do you see that?
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`1 A. Yes.
`2 Q. Okay. And when you get down to 73 --
`3 Paragraph 73 in your report, you say that,
`4 Dr. Abidi's calculations are difficult to
`5 analyze because his analysis provides little
`6 more than