Mark N. Horenstein - February 16, 2016
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________________
`
`MICROSOFT CORPORATION and )
`
`MICROSOFT MOBILE, INC. ) IPR2015-01147
`
` Petitioners, )
`
` vs. ) Patent No.
`
`GLOBAL TOUCH SOLUTIONS, LLC, ) 7,994,726
`
` Patent Owner. )
`
` ***CAPTION CONTINUED*** )
`
`_______________________________)
`
` Deposition of
`
` MARK N. HORENSTEIN, Ph.D., P.E.
`
` February 16, 2016
`
`Reported by: Cappy Hallock, RPR, CRR, CLR
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`GLOBAL EX. 2001
`Microsoft Corporation, et al. v. Global Touch Solutions, LLC
`IPR2015-01151
`
`
`
`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________________
`
`MICROSOFT CORPORATION and )
`
`MICROSOFT MOBILE, INC. ) IPR2015-01147
`
` Petitioners, )
`
` vs. ) Patent No.
`
`GLOBAL TOUCH SOLUTIONS, LLC, ) 7,994,726
`
` Patent Owner. )
`
` ***CAPTION CONTINUED*** )
`
`_______________________________)
`
` Deposition of
`
` MARK N. HORENSTEIN, Ph.D., P.E.
`
` February 16, 2016
`
`Reported by: Cappy Hallock, RPR, CRR, CLR
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`GLOBAL EX. 2001
`Microsoft Corporation, et al. v. Global Touch Solutions, LLC
`IPR2015-01151
`
`
`
`Mark N. Horenstein - February 16, 2016
`
`Page 2
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________________
`
`MICROSOFT CORPORATION and )
`
`MICROSOFT MOBILE, INC. ) IPR2015-011478
`
` Petitioners, )
`
` vs. ) Patent No.
`
`GLOBAL TOUCH SOLUTIONS, LLC, ) 7,498,749
`
` Patent Owner. )
`
`_______________________________)
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________________
`
`MICROSOFT CORPORATION and )
`
`MICROSOFT MOBILE, INC. ) IPR2015-01149
`
` Petitioners, )
`
` vs. ) Patent No.
`
`GLOBAL TOUCH SOLUTIONS, LLC, ) 7,329,970
`
` Patent Owner. )
`
` ***CAPTION CONTINUED*** )
`
`_______________________________)
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`Mark N. Horenstein - February 16, 2016
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`Page 3
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________________
`
`MICROSOFT CORPORATION and )
`
`MICROSOFT MOBILE, INC. ) IPR2015-01150
`
` Petitioners, )
`
` vs. ) Patent No.
`
`GLOBAL TOUCH SOLUTIONS, LLC, ) 7,781,980
`
` Patent Owner. )
`
`_______________________________)
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________________
`
`MICROSOFT CORPORATION and )
`
`MICROSOFT MOBILE, INC. ) IPR2015-01151
`
` Petitioners, )
`
` vs. ) Patent No.
`
`GLOBAL TOUCH SOLUTIONS, LLC, ) 8,288,952
`
` Patent Owner. )
`
`_______________________________)
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`Mark N. Horenstein - February 16, 2016
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` The Deposition of MARK N. HORENSTEIN,
`
`Ph.D., P.E. was taken on Tuesday, February 16,
`
`2016, commencing at 9:05 a.m. at the law offices
`
`of Baker Hostetler, Cira Centre, 12th Floor, 2929
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`Arch Street, Philadelphia, Pennsylvania 19104,
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`before Cappy Hallock, Registered Professional
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`Reporter, Certified Realtime Reporter, Certified
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`Livenote Reporter and Notary Public in and for the
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`District of Columbia.
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` A P P E A R A N C E S:
`
` On behalf of Petitioners:
`
` JOHN F. MURPHY, ESQUIRE
`
` DANIEL J. GOETTLE, ESQUIRE
`
` SARAH C. DUKMEN, ESQUIRE
`
` Baker Hostetler
`
` 2929 Arch Street
`
` Circa Centre, 12th Floor
`
` Philadelphia, Pennsylvania 19104-2891
`
` 215-564-1603 (P) 215-568-3439 (F)
`
` johnmurphy@bakerlaw.com
`
` dgoettle@bakerlaw.com
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`
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`Mark N. Horenstein - February 16, 2016
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`Page 5
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` A P P E A R A N C E S (continued):
`
` On behalf of Patent Owner:
`
` FADI N. KIBLAWI, ESQUIRE
`
` Sughrue Mion, PLLC
`
` 2100 Pennsylvania Avenue, NW
`
` Washington, D.C. 20037-3213
`
` 202-663-7386 (P) 202-293-7860 (F)
`
` fkiblawi@sughrue.com
`
` - and -
`
` NATHAN H. CRISTLER, ESQUIRE
`
` Roberts Mlotkowski Safran & Cole, P.C.
`
` 7918 Jones Branch Drive, Suite 500
`
` McLean, Virginia 22102
`
` 703-584-3270 (P) 703-848-2981 (F)
`
` ncristler@cristlerip.com
`
`Reported by:
`
` Cappy Hallock, RPR, CRR, CLR
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`Mark N. Horenstein - February 16, 2016
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`Page 6
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` I N D E X
`
` Deposition of Mark N. Horenstein, Ph.D., P.E.
`
` February 16, 2016
`
`EXAMINATION BY: PAGE
`
` Mr. Kiblawi 7
`
` -o0o-
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` E X H I B I T S
`
` (exhibits attached)
`
`HORENSTEIN PAGE
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`Exhibit 1 U.S. Patent Number 7,994,726 9
`
`Exhibit 2 Declaration for '726 patent 9
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`Exhibit 3 Jahagirdar reference 27
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`Exhibit 4 Schultz reference 41
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`Exhibit 5 Declaration for '980 patent 77
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`Exhibit 6 Declaration for '952 patent 78
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`Exhibit 7 Declaration for '749 patent 78
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` -o0o-
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`Mark N. Horenstein - February 16, 2016
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`Page 7
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` P R O C E E D I N G S
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` - - - - - -
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`WHEREUPON,
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` MARK N. HORENSTEIN, Ph.D., P.E.
`
` A Witness called for examination, having been
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`first duly sworn, was examined and testified as
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`follows:
`
` EXAMINATION
`
`BY MR. KIBLAWI:
`
` Q So good morning, Dr. Horenstein.
`
`Welcome -- well, I guess thank you for meeting us
`
`again. And, as you know, we met about a month or
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`so ago in a related matter, but again I would like
`
`to introduce myself.
`
` My name is Fadi Kiblawi and I'm an
`
`attorney representing Global Touch Solutions in a
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`number of Inter Partes Reviews that we are going
`
`to discuss today, cases dealing with Microsoft
`
`Corporation and Microsoft Mobile.
`
` Would you please for the record state
`
`your name and spell it.
`
` A Mark Horenstein. M-a-r-k,
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`Mark N. Horenstein - February 16, 2016
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`Page 8
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`H-o-r-e-n-s-t-e-i-n.
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` Q And we are here this morning to talk
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`about six U.S. patents in total that are the
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`subject of six Inter Partes Reviews.
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` I'm sorry. Let me restate that. We are
`
`here to discuss five Inter Partes Review cases
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`today. Is that your understanding?
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` A I believe so.
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` Q Okay. I'm sorry, for my lack of
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`precision here.
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` Now, among them is Patent Number
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`7,994,726. Is that your understanding?
`
` A Yes.
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` Q I will be referring to that as the '726
`
`patent throughout the morning. Is that
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`understandable to you?
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` A Yes.
`
` Q Good.
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` MR. KIBLAWI: So I think because this is
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`a different -- we discussed this earlier, if this
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`is acceptable to you -- this is a different Inter
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`Partes Review from the previous one, we will
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`Mark N. Horenstein - February 16, 2016
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`restart the exhibit number.
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` MR. MURPHY: That's fine with me.
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` MR. KIBLAWI: And this is the '726
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`patent. Can this please be labeled Exhibit
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`Number 1.
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` (Horenstein Deposition Exhibit No. 1 was
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`marked for identification.)
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` THE WITNESS: Thank you.
`
`BY MR. KIBLAWI:
`
` Q Now, you prepared a declaration with
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`respect to an Inter Partes Review with respect to
`
`the '726 patent; is that correct?
`
` A That's correct.
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` MR. KIBLAWI: I will go ahead and hand
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`you that as Exhibit Number 2.
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` (Horenstein Deposition Exhibit No. 2 was
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`marked for identification.)
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` THE WITNESS: Thank you.
`
`BY MR. KIBLAWI:
`
` Q Okay, great.
`
` Actually, before we get into the
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`substance, I guess I should just go through a few
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`preliminary matters.
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` Are you suffering from any medical
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`problems or taking any medications that might
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`affect your ability to answer questions today
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`accurately and completely?
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` A No.
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` Q Great. You understand you are testifying
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`under oath today?
`
` A That's correct.
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` Q And just as before, I guess my next
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`question is you are accompanied by a counsel for
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`the Petitioners today; is that correct?
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` A That's right.
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` Q As you know, as we went through this last
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`time, throughout the day I will ask you a question
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`and if there is something that you don't
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`understand about my question that might be vague,
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`would you please just let me know that and I can
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`re-ask it?
`
` A Yes.
`
` Q Great.
`
` Now, again probably during the day at
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`some point Petitioners' counsel may object to one
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`or more of the questions, and you are aware just
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`as last time that the witness, yourself, are still
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`to answer the question unless Petitioners' counsel
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`specifically directs you not to. Do you
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`understand that?
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` A Yes.
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` Q Okay, great.
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` And I guess since the last time we met,
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`since the last time, the deposition that took
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`place with respect to the related case, have you
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`been deposed in any other matters?
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` A No.
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` Q Okay, and have you been retained as an
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`expert by any other parties?
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` A Since the last deposition?
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` Q Yes.
`
` A No.
`
` Q Okay.
`
` And, I guess, did you do anything to
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`prepare for today's deposition?
`
` A I did.
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` Q And did you speak with anybody in
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`preparation for today's deposition?
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` A Yes.
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` Q Did you speak with Petitioners' counsel
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`in preparation for today's deposition?
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` A Yes.
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` Q And how long did you take to prepare for
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`today's deposition?
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` A I would say all together about two or two
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`and a half days.
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` Q Okay.
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` So I've handed you the '726 patent and I
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`have also -- that was Exhibit Number 1, as well as
`
`your declaration. Now, are you, have you reviewed
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`the '726 patent?
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` A Yes.
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` Q And did you review the '726 patent in
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`preparation for your deposition today?
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` A Yes.
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` Q Great. Okay, so you might be pretty
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`familiar with this patent.
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` If you can, please turn to Exhibit
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`Number 1, the '726 patent, and specifically I just
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`want to, I guess, get your general understanding
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`of the invention. And if you need to review the
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`specification, you know, by all means to refresh
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`your memory, but I guess this might be some pretty
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`simple questions.
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` If you can turn to Figure 1, please.
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` A Figure 1.
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` Q Yes. And I guess what is your
`
`understanding of what is illustrated in Figure 1?
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` MR. MURPHY: Object to the form of the
`
`question.
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` A Well, it's an embodiment that's outlined
`
`in the specification.
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` Q Okay, great. If you can turn to the
`
`specification. I guess I would ask you, what is
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`this an embodiment of?
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` MR. MURPHY: Object to the form.
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` A Figure 1 is a schematic of a device
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`having a microchip-controlled push button or
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`sliding type activation/deactivation switch
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`according to one embodiment of the invention.
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` Q I guess, in a general sense, what is your
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`understanding of what the invention purports to be
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`in this patent?
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` MR. MURPHY: Object to form.
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` A Well, my understanding is described in my
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`declaration. I guess I could summarize it by what
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`is in the abstract. That would be consistent with
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`my understanding.
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` Q If you could turn to your declaration,
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`because I was reading through it and I don't
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`believe I actually saw where you describe the
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`'726 -- your understanding of the '726 patent in
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`the declaration, so if you can, you know, direct
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`me to what your understanding is as set forth in
`
`the '726 patent declaration that you prepared,
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`Exhibit Number 2.
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` A My understanding of the '726 is included
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`in all the paragraphs that comprise my obviousness
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`analysis.
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` Q Okay, and so with respect to the prior
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`art that's cited in this patent; is that correct?
`
` A Well, it's the aggregate of what I have
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`written in the declaration.
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` Q Okay.
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` If you can please put the declaration to
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`the side because you mentioned earlier -- and
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`correct me if I am wrong, I can re-read it -- that
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`you believe the abstract provides an overview of
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`this patent; is that correct?
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` MR. MURPHY: Object to form.
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` A Well, generally the abstract of a patent
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`does provide an overview of what the patent is
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`about.
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` Q Okay, great.
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` If you can take a minute to read that, if
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`you like, but I guess I would like to know what
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`your understanding of the invention is of the '726
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`patent.
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` MR. MURPHY: Object to form.
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` A So I've read the abstract and it is
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`consistent with my understanding of this patent.
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` Q And what would that understanding be?
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` A Well, it's --
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` MR. MURPHY: Object to form.
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`Mark N. Horenstein - February 16, 2016
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` A As is outlined in the abstract, the
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`invention described in '726 is directed to
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`portable electronic devices which operate on
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`exhaustible power sources which are typically
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`batteries. And the device has a signal switch and
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`a microchip that is in communication with a
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`switch, and the switch is capable of transmitting
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`a signal to the microchip, telling the microchip
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`that it's been activated or deactivated.
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` And the microchip is in communication
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`with the battery of the device and controls either
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`the power on/off function of the device -- not
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`either but controls the power on/off function of
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`the device and at least one other function in
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`response to activation and deactivation signals
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`from the switch, and also an automatic shutoff
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`function in response to receiving the activation
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`signal from the switch.
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` Q Okay, so if you can turn back to
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`Figure 1, would you say that description in the
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`abstract is consistent with what is illustrated in
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`Figure 1?
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`Mark N. Horenstein - February 16, 2016
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` MR. MURPHY: Object to form.
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` A One has to read the specification to
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`understand what Figure 1 is doing, and I would
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`have to read the specification to ascertain
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`whether all the components that are outlined in
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`the abstract are contained in the description of
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`Figure 1. So if you would like me to do that --
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` Q Go ahead, sure.
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` A -- do that analysis, I will do that.
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` Okay, so if you look at the '726 patent,
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`Column 6, Line 62 is where the description begins,
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`and the description to which I refer ends at
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`Column 7, about Line 57, and I believe that all or
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`most of the elements that are described in the
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`abstract are explained in the paragraphs that I've
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`just cited.
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` Q All right. Okay, so if you can turn to
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`Figure 1 then.
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` A Okay.
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` Q Can you please provide me with your
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`understanding of what specific components are
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`illustrated in the embodiment of Figure 1.
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`Mark N. Horenstein - February 16, 2016
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`Page 18
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` MR. MURPHY: Object to form.
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` A Well, as the excerpt I cited explains,
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`there is a push button or sliding switch, that's
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`102, and that's meant to not carry current to the
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`load. The load is 105. But it's in communication
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`with the microchip 103. This particular
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`configuration, the microchip is grounded, which is
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`the negative terminal of the battery 101.
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` And there is an implied current switch
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`that transfers current from the battery to the
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`load that is not shown in the picture but is
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`controlled as to its on/off state by the
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`microchip.
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` And then starting about Line 15 in
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`Column 7, the excerpt explains that the operator
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`activates input switch when it's moved to the on
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`position, that means pressing the button or
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`closing the switch, and that sends a command to
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`the microchip. That signal pass by switch 102 is
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`very low current, but it causes the microchip to
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`turn on the high current switch and the battery
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`gets connected to the load.
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`Mark N. Horenstein - February 16, 2016
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` And then starting at about Line 32 of
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`Column 7, the specification explains how the
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`microchip could be programmed to flash the load,
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`which is a light in this case, on and off to
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`provide information to the user, and also the
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`on/off functionality can be set to a timer which
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`will truncate the entire operation after a certain
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`amount of time.
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` Q Sorry, I want to make sure that you're
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`finished.
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` A That's okay. I'm done.
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` Q Okay, great.
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` So based on your description and
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`explanation there, and based on your understanding
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`of Figure 1, would you say the microchip manages
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`the conducting of the current from the power
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`source to the load?
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` MR. MURPHY: Object to the form of the
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`question.
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` A Sorry, could you say the question again?
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` Q Yes.
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` So would you say looking at Figure 1 that
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`the microchip in Figure 1 conducts current from
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`the power source to the load?
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` MR. MURPHY: Same objection.
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` A Well, the specification talks about how a
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`switch, which is not shown, conducts current from
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`the power source 101 to the load 105. The
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`microchip controls that switch on command from
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`signal from switch, I believe it's 102 -- yes,
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`switch 102.
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` Q Okay.
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` So can you turn to Column 3 of the '726
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`patent, Exhibit 1?
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` A Okay.
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` Q So there in Column 3 do you see the
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`section titled Summary of the Invention around
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`Line 59?
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` A Yes.
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` Q And, you know, the first sentence of that
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`section reads, "According to one embodiment of the
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`present invention, there is a provided a
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`microchip-controlled switch to manage both the
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`current conducting functions and the MMI functions
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`Mark N. Horenstein - February 16, 2016
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`in an electronic device such as a flashlight on a
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`low current basis, i.e. without the MMI device
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`having to conduct or switch high current."
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` A I see that.
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` Q Do you believe that Figure 1 illustrates
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`such a microchip-controlled switch?
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` MR. MURPHY: Object to form.
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` A Well, as the specification indicates, the
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`microchip-controlled switch is not shown but is
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`understood to be in the serial path from the
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`battery 101 to the load 105.
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` Q Okay, great.
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` So I suppose if you turn to Figure 11 of
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`the '726 patent --
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` A Yes.
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` Q -- there appears to be illustrated
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`another embodiment that includes a diode. Now, if
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`you would like, you can read through the
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`description in Figure 11 of the specification to
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`refresh your memory. But I would like to discuss
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`this figure as well, and particularly your
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`understanding of whether Figure 11 illustrates
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`Mark N. Horenstein - February 16, 2016
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`a -- well, let me reword that.
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` I would like to inquire as to your
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`understanding of whether the embodiment of
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`Figure 11 includes a microchip-controlled switch
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`to conduct current from a power source to a load.
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` MR. MURPHY: Object to form.
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` A Sorry, could you repeat the pending
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`question?
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` Q Absolutely. I want to ask you, is it
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`your understanding -- well, let me reword that.
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` Based on your understanding of the '726
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`patent, does the embodiment in Figure 11 include a
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`microchip-controlled switch to manage current
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`conducting functions from a power source to a
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`load?
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` A Sure.
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` MR. MURPHY: Object to form.
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` Sorry.
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` A And just to correct something you said
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`before in describing the figure, you said there
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`was a diode, but 11-04 is actually described as an
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`LED. So not an ordinary diode, just to be clear.
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`Mark N. Horenstein - February 16, 2016
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` Q Great. Okay, thank you for that
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`clarification. You will have to excuse me, I have
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`a computer science background.
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` Okay, so you've just read the description
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`of Figure 11 I presume in the specification, or
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`would you like to --
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` A I've read Column 9, Lines 46 to about 65,
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`and that's the only description of Figure 11 that
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`I can find in the patent, so ...
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` Q So based on your understanding -- sorry.
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` Based on your understanding of the '726
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`patent as a whole, turning to Figure 11, does the
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`microchip in Figure 11 control activation of that
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`LED 11-04?
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` MR. MURPHY: Object to form.
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` A Well, the microchip can turn the LED on
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`and off.
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` Q Okay, and that's your understanding,
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`activation means on and off here?
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` A Yes.
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` Q Now does the microchip in Figure 11
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`also -- let me strike that question because I
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`Mark N. Horenstein - February 16, 2016
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`think I already asked it and you already answered
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`it.
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` I was going to ask if the microchip also
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`controls conducting currents to the load, and I
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`believe you answered that but you can answer it
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`again if you'd like.
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` MR. MURPHY: Object to form.
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` A So do you mean the load 105?
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` Q That's correct.
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` A Yes, that would be implied because the
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`power source 101 and the load 105 are in the same
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`positions that they are in most of the other
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`figures.
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` Q Right. Okay. So I guess let's look at
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`the claims.
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` Turning to Column 12 of Figure 1, that's
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`where the claims section begins, and feel free at
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`any point to look through the specification or
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`your declaration if you need to refresh your
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`memory at all. And I need to refresh my memory.
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` So if you turn to claim 4, can you read
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`claim 4 to yourself if you would like to refresh
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`Mark N. Horenstein - February 16, 2016
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`your memory on claim 4, and I would also like to
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`direct you to Page 77 of your declaration, Exhibit
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`Number 2, where it appears you have provided an
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`opinion with respect to claim 4.
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` So --
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` A Just one moment.
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` Q Sorry.
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` A Okay, please ask your question.
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` Q So claim 4 recites, inter alia, "Wherein
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`the method also includes this step of activating
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`or deactivating the product via commands received
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`from the user interface."
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` What does activating or deactivating mean
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`in this claim?
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` MR. MURPHY: Object to the form of the
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`question and object to the extent it calls for a
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`legal conclusion and claim construction.
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` A So your question was what is my
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`understanding of activation?
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` Q Yes, for example, in claim 4.
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` MR. MURPHY: Same objection.
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` A In the context of claim 4 my thought is
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`Mark N. Horenstein - February 16, 2016
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`that it means turning on or turning off.
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` Q Okay.
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` A It's talking about activating or
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`deactivating a product.
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` Q Okay.
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` Would you consider changing channels on a
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`television to be an activating or deactivating of
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`the television?
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` MR. MURPHY: Object to the form of the
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`question. Object to the scope.
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` A It would depend on how a television
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`worked.
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` Q In what sense?
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` MR. MURPHY: Same objection.
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` A Well, if you changed channels would it
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`turn on some light that wasn't on before, or would
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`it energize some circuitry associated with the
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`channel that wasn't needed for the previous
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`channel? Would it change the information on the
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`screen to tell you that you were on channel 3 and
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`now you are on channel 4. So it's very hard to
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`answer your question without any context
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`Mark N. Horenstein - February 16, 2016
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`whatsoever.
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` Q Let me ask another question then. Would
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`you consider changing channels of the television
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`to be a turning on or turning off of the
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`television?
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` MR. MURPHY: Object to the form of the
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`question.
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` A Again, it depends on what you mean by
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`"the television."
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` Q Would you consider changing the channel
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`of the television to be a turning on or turning
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`off of the display on the television?
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` MR. MURPHY: Object to form.
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` A Again, it would depend on how the
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`television worked.
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` Q Okay. Sorry, I'm going to make some
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`notes down here.
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` MR. KIBLAWI: I would like to hand you
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`what will be marked as Exhibit Number 3, the
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`Jahagirdar reference.
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` (Horenstein Deposition Exhibit No. 3 was
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`marked for identification.)
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`BY MR. KIBLAWI:
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` Q Are you familiar with the Jahagirdar
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`reference before you, Exhibit Number 3?
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` A Yes.
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` Q And you applied this reference in your
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`analysis, in your declaration; is that correct?
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` A Yes.
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` Q You can obviously refer to your
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`declaration, if you like, at this point. I
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`suppose -- and you reviewed this declaration in
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`preparation for your deposition today?
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` A You mean this patent; is that what you
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`meant?
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` Q Yes. Did you review this reference? I
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`apologize for that.
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` A Yes.
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` Q And so do you have a general
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`understanding of what is disclosed in this patent
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`then?
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` A You mean in the Jahagirdar patent?
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` Q Yes.
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` A Yes.
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` Q And can you please provide us with a
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`brief summary of your understanding of what is
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`disclosed in the Jahagirdar reference?
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` MR. MURPHY: Object to form.
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` A Again, as I did with the '726 patent, the
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`abstract generally describes my understanding of
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`what is in the patent. There are numerous
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`embodiments described, but the abstract provides a
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`reasonable summary of the subject matter of the
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`patent. Would you like me to read it or is it
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`good enough to just say the abstract?
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` Q The abstract is fine. If you want to
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`review it, my questions are pretty short, so
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`abstract. But I guess my first question is would
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`it be fair to say that the embodiments in this
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`invention all have a first display area and a
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`second display area?
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` MR. MURPHY: Object to the form.
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` A That's correct.
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` Q Great. If you turn to Figure 1 as well
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`as Figure 2 in the Jahagirdar reference, so you
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`see illustrated there, there is a flip phone; is
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`that correct?
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` A Yes. I think one would typically call
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`that type of phone a flip phone.
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` Q Great. Have you ever owned a flip phone?
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` A Yes.
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` Q How many flip phones have you owned --
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` MR. MURPHY: Object to form. Scope.
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` Q If you recall.
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` A I will have to count.
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` Three or four I would say.
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` Q How would you hold the flip phone when
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`you were carrying it around?
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` MR. MURPHY: Objection to form, and
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`outside the scope, and relevance, too.
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` A So by carry it around, what do you mean?
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` Q Like, would you ever carry it in your
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`hand, for example?
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` MR. MURPHY: Same objection.
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` A Am I talking into it when I'm doing that?
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` Q We will say for this question that you're
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`not talking in it.
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` MR. MURPHY: Same objection.
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`22
`
` A Well, the flip phones I had I carried in
`
`a number of ways.
`
` Q Would you say that it would be common to
`
`carry a flip phone along the lengthwise outer
`
`edges?
`
` MR. MURPHY: Object to form. Relevance.
`
` A The lengthwise outer edges meaning what?
`
` Q So, for example, looking at Figure 1 you
`
`see illustrated a flip phone.
`
` A Yes.
`
` Q And I would say that the outer edges that
`
`are the longest outer edges, for example, I think
`
`there is reference numeral 128 in Figure 2?
`
` A Yes.
`
` Q Would you carry your flip phone along
`
`those edges? Would you say that would be common
`
`practice?
`
` MR. MURPHY: Same objection.
`
` A It's really going to depend on if you're
`
`not talking into it. It's going to depend. You
`
`might put the phone in your pocket. You migh
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