Narayan B. Mandayam, Ph.D. - May 18, 2016
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` Patent 7,295,532
`
`___________________________________
`
`SAMSUNG ELECTRONICS CO., LTD., )
`
`SAMSUNG ELECTRONICS AMERICA, INC. )
`
`and APPLE, INC. ) Case No.
`
` Petitioner, ) IPR2015-01443
`
` v. )
`
`IXI IP, LLC, )
`
` Patent Owner. )
`
`___________________________________)
`
` VIDEOTAPED DEPOSITION of
`
` NARAYAN B. MANDAYAM, Ph.D.
`
` May 18, 2016
`
` Pepper Hamilton, LLP
`
` 125 High Street
`
` Boston, Massachusetts
`
`Reporter: Michael D. O'Connor, RMR, CRR, CBC, CCP
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`1
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`Samsung v. IXI
`IPR2015-01444
`Exhibit 1018
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`
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` Patent 7,295,532
`
`___________________________________
`
`SAMSUNG ELECTRONICS CO., LTD., )
`
`SAMSUNG ELECTRONICS AMERICA, INC. )
`
`and APPLE, INC. ) Case No.
`
` Petitioner, ) IPR2015-01443
`
` v. )
`
`IXI IP, LLC, )
`
` Patent Owner. )
`
`___________________________________)
`
` VIDEOTAPED DEPOSITION of
`
` NARAYAN B. MANDAYAM, Ph.D.
`
` May 18, 2016
`
` Pepper Hamilton, LLP
`
` 125 High Street
`
` Boston, Massachusetts
`
`Reporter: Michael D. O'Connor, RMR, CRR, CBC, CCP
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`1
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`Samsung v. IXI
`IPR2015-01444
`Exhibit 1018
`
`
`
`Narayan B. Mandayam, Ph.D. - May 18, 2016
`
`Page 2
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` Wednesday, May 18, 2016
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` 9:49 a.m.
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` DEPOSITION OF NARAYAN B. MANDAYAM,
`
`Ph.D. at the offices of Pepper Hamilton, LLP, 125
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`High Street, Boston, Massachusetts, before
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`Michael D. O'Connor, a Registered Merit Reporter
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`and Notary Public in and for the Commonwealth of
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`Massachusetts.
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`Narayan B. Mandayam, Ph.D. - May 18, 2016
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`Page 3
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` A P P E A R A N C E S
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` COUNSEL FOR THE PETITIONER:
`
` FISH& RICHARDSON
`
` 500 Arguello Street, Suite 500
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` Redwood City, California 94063
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` (650) 839-5070
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` BY: KATHI VIDAL, ESQ.
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` vidal@fr.com
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` COUNSEL FOR THE PETITIONER:
`
` FISH& RICHARDSON
`
` 1425 K Street, N.W.
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` Washington, D.C. 20005
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` (202) 783-5070
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` BY: JEREMY J. MONALDO, ESQ.
`
` monaldo@fr.com
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` COUNSEL FOR THE PATENT OWNER:
`
` PEPPER HAMILTON, LLP
`
` 333 Twin Dolphin Drive
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` Redwood City, California 94065
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` (650) 802-3600
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` BY: ANDY H. CHAN, ESQ.
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` chana@pepperlaw.com
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`Narayan B. Mandayam, Ph.D. - May 18, 2016
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`Page 4
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` A P P E A R A N C E S (continued)
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` COUNSEL FOR THE PLAINTIFF:
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` PEPPER HAMILTON, LLP
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` 125 High Street
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` Boston, Massachusetts 02110
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` (617) 204-5100
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` BY: GRIFFIN N. MESMER, ESQ.
`
` mesmerg@pepperlaw.com
`
`Also Present: Won S. Yoon, Technology
`
` Specialist/Patent Agent,
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` Fish & Richardson
`
` Usman Khan, Technology
`
` Specialist/Patent Agent,
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` Fish & Richardson
`
` Alex Daunais, Videographer
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`Narayan B. Mandayam, Ph.D. - May 18, 2016
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`Page 5
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` I N D E X
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`Deposition of:
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`NARAYAN B. MANDAYAM
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`Examination by: Page
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` By Ms. Vidal 8
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`Narayan B. Mandayam, Ph.D. - May 18, 2016
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`Page 6
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` E X H I B I T S
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`No. Page
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`Exhibit 1013 U.S. Patent Application U.S. 102
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` 202/0198958 A1
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`Exhibit 1014 Patent Owner's response in 137
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` IPR2015-01444
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` -0-
`
` PREVIOUSLY MARKED EXHIBITS REVIEWED
`
` BY THE WITNESS:
`
`Samsung 1001 United States Patent 47
`
` No.: US 7,295,532 B2
`
`Samsung 1005 International Publication 67
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` No. WO 01/76154 A2
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`Samsung 1006 Computer Communication Review 144
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` P R O C E E D I N G S
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` -------------
`
` VIDEOGRAPHER: We are on the record.
`
`This is the videographer Alex Daunais speaking.
`
`Today's date is May 18, 2016, and the time is
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`9:49 a.m.
`
` We are here to take the deposition of
`
`Narayan Mandayam in the matter of Samsung
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`Electronics Company Ltd., Samsung Electronics
`
`America, Inc. and Apple, Inc., versus IXI IP,
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`LLC, case number IPR 2015-01443.
`
` Will counsel please state themselves.
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` MS. VIDAL: Kathi Vidal representing
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`Petitioner.
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` MR. MONALDO: Jeremy Monaldo
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`representing Petitioner.
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` MR. YOON: Won Yoon representing
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`Petitioner.
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` MR. KHAN: Usman Khan representing
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`Petitioner.
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` MR. CHAN: Andy Chan representing
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`Patent Owner. With me is my colleague, Griffin
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`Mesmer.
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` VIDEOGRAPHER: Would the court
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`reporter please swear in the witness.
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`Narayan B. Mandayam, Ph.D. - May 18, 2016
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`Page 8
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` NARAYAN B. MANDAYAM
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`having been satisfactorily identified by the
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`production of his driver's license, and duly
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`sworn by the Notary Public, was examined and
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`testified as follows:
`
` DIRECT EXAMINATION
`
`BY MS. VIDAL:
`
` Q. Dr. Mandayam, could you please state
`
`your name for the record.
`
` A. Sure. My name is Narayan Mandayam.
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` Q. Have you ever been deposed before,
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`Dr. Mandayam?
`
` A. Yes, I have.
`
` Q. In what context?
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` A. Basically in an IPR litigation, and
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`even before that.
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` Q. In one IPR litigation?
`
` A. Mostly two, two of them. I've also
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`done a deposition before.
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` Q. And which two IPR litigations were
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`you deposed in?
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` A. I don't remember the exact details,
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`but they were related to wireless systems,
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`wireless networks, and location tracking. That
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`was one of the aspects.
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` Q. Who were you hired by in those two
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`litigations?
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` A. So I'm actually -- I was recruited by
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`a consulting company, and the attorneys in the
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`two IPR cases. The attorneys I worked with were
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`from Pepper Hamilton.
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` Q. And which company did you work for?
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` A. I forget the exact name. Maybe it
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`was something like Callwave. I'm sorry, I just
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`don't remember.
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` Q. That's fine. For each of those, what
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`was your ultimate conclusion?
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` A. I'm not sure what exactly that
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`question means.
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` Q. Were you asked to opine on whether
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`the patents were valid or invalid?
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` A. So I was actually asked to provide
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`opinions on the validity of the patents.
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` Q. And did you conclude that the patents
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`were valid or invalid or was it a mix?
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` MR. CHAN: Objection. Form.
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` A. Again, I don't remember the, you
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`know, I don't remember the exact details. But I
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`believe I did conclude that, at least, the
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`patents I was asked to analyze certain aspects of
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`it, certain claims, and I believe I did conclude
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`that they were valid.
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` Q. So each claim in each of those
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`petitions you concluded were valid?
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` MR. CHAN: Objection. Form.
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`Foundation.
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` A. Again, I don't remember the details.
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`But yeah, I would say yes.
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` Q. And were you asked to opine on
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`anticipation?
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` A. I'm really sorry, I don't remember
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`enough.
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` Q. Were you asked to opine on
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`obviousness?
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` A. I believe so. But again, I don't
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`remember the details of this.
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` Q. When were your depositions in those
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`two cases?
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` A. Probably sometime in the last two
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`years. Again, I can't remember exactly.
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` Q. Last two years?
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` A. Yeah, sometime in the last two years,
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`I would think.
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` Q. Do you know when the most recent one
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`was?
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` A. Last year.
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` Q. 2015?
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` A. I think, again -- I don't remember,
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`to tell you the truth. I think it was in the
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`last two years. I have to go -- I'm sorry, I
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`don't have a clear answer on that for you.
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` Q. That's fine. And you mentioned that
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`you had been deposed before those two
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`depositions; is that correct?
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` A. Yes.
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` Q. And when was that?
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` A. Probably over five years ago or
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`something like that. Again...
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` Q. And what was the context of that
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`deposition?
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` A. That also had to do with essentially
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`wireless. Again, my expertise is wireless,
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`systems wireless networks, systems technologies
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`related to that.
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` Q. Were you acting as an expert in a
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`case?
`
` A. Yes, I believe so.
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` Q. Was it only one case?
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` A. I really don't have a good
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`recollection of it. I'm sorry.
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` Q. Do you recall the parties in that
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`matter?
`
` A. No. Unfortunately, no or
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`fortunately, no.
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` Q. Was that work for Pepper Hamilton as
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`well?
`
` A. No.
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` Q. Do you know who that work was for?
`
` A. No, I don't remember.
`
` Q. Is there anything that would prevent
`
`you from testifying truthfully and fully today?
`
` A. No.
`
` Q. And you understand that over the next
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`three days you're going to be asked to testify on
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`IPR 2015-01443, 01444, 01445 and 01446?
`
` A. Yes, that is my understanding, yes.
`
` Q. And we're going to start with 01443,
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`which relates to the '532 patent. I'm going to
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`start by asking you some general questions about
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`your background and understanding.
`
` A. Sure.
`
` MS. VIDAL: My understanding is that
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`I only need to ask those in this one deposition
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`Narayan B. Mandayam, Ph.D. - May 18, 2016
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`Page 13
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`that you don't want me to repeat that for each
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`deposition; is that correct?
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` MR. CHAN: My understanding is that
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`previously we didn't have an agreement as to all
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`the background questions, but I think if you ask
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`him specific questions about his background here,
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`and they carry over, you can ask him in the next
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`proceeding whether or not he agrees with --
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` MS. VIDAL: Okay.
`
` MR. CHAN: Because I think they're
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`separate depositions basically.
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` MS. VIDAL: Okay.
`
` MR. CHAN: So I want to make the
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`record clear so that there's no need to then, I
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`guess, incorporate by reference or that kind of
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`thing.
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` MS. VIDAL: Okay.
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` MR. CHAN: So I think to the extent
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`that there's direct overlap of those same
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`questions, and Dr. Mandayam provides his answers,
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`and I think you ask him in his next proceeding
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`whether or not he agrees with those things or he
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`has anything to change, I think that should be
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`fine.
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` MS. VIDAL: Okay.
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`Narayan B. Mandayam, Ph.D. - May 18, 2016
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`Page 14
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` Q. So what I'm going to do is I'm going
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`to ask you a series of what I'm going to call
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`background questions. I'll let you know when
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`I've moved on and no longer asking background
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`questions.
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` A. Okay.
`
` Q. In your next three depositions, I'm
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`going to ask you if you have anything to change
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`or if you, you know, can confirm --
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` A. Okay. So can I look at the
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`transcript of what I said about -- I just wanted
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`to know. When you say --
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` Q. I'll get back to you on that.
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` A. Okay.
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` Q. I will ask if you have any different
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`answers in the next couple of days.
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` A. Okay. Sounds good.
`
` Q. Are you currently employed other than
`
`as an expert, Dr. Mandayam?
`
` A. Yes.
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` Q. And what is your occupation?
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` A. So I'm a professor, actually a
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`distinguished professor at Rutgers University, in
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`New Jersey. So I'm a faculty member in the
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`department of electrical and computer
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`engineering.
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` And I'm also the associate director
`
`of an Industrial University Cooperative Research
`
`Center called WIN Lab. It stands for the
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`Wireless Information Network Laboratory.
`
` Q. And you have a Ph.D.; is that
`
`correct?
`
` A. Yes, I do.
`
` Q. What year did you graduate with your
`
`Ph.D.?
`
` A. 1994.
`
` Q. During your Ph.D., and shortly
`
`thereafter, what areas of research did you focus
`
`on?
`
` A. Basically I have been working on
`
`wireless networks, wireless technology since
`
`1989. That has been, you know, various aspects
`
`of the wireless systems.
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` Q. Which specific aspects were you
`
`focused on for your Ph.D.?
`
` A. So my Ph.D. at the time I was working
`
`on something called code division multiple access
`
`systems, also referred to as CDMA. I also did
`
`some work on both radio aspects of it as well as
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`how to use something like that in a context of
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`optical networks.
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` Q. And were those all long-range
`
`networks versus short range?
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` MR. CHAN: Objection. Form.
`
` A. So I'm not sure what exactly that
`
`question means. CDMA has been the technology
`
`that's been used for various applications -- I
`
`mean various system scenarios. Historically it
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`started with the defense where essentially these
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`technologies were first actually founded in the
`
`context of defense, going back to the second
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`world war.
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` So it really had very many benefits
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`for that type of communications. So I would say
`
`the popularity of CDMA for more commercial
`
`mainstream communications happened primarily with
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`second generation cellular systems. That's how
`
`it started.
`
` Also, as I said, this question of
`
`short range versus long range, it has been used
`
`in various contexts over a long period of time.
`
` Q. Do you understand what a WAN is?
`
` A. Yes, I do.
`
` Q. What is a WAN?
`
` A. A term that is generically used to
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`describe a wide area network. So it could have
`
`many components to it.
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` Q. Is CDMA used in WANs?
`
` A. Yes, in some WANs CDMA is used.
`
` Q. What is your understanding of what a
`
`LAN is?
`
` A. Again, it stands for a local area
`
`network. So LAN is a local area network. So
`
`it's typically a short-range network.
`
` Q. And is CDMA used in LANs?
`
` A. There is some what's called direct
`
`sequence spread spectrum techniques that are
`
`used. For instance, in some of the early
`
`versions of wireless LANs.
`
` Q. Was any of your Ph.D. work on those
`
`direct spread spectrums?
`
` A. Direct sequence spread spectrum CDMA.
`
`So if you're looking for an acronym it's DSSS
`
`CDMA.
`
` Q. Was any of your Ph.D. work focused on
`
`DSSS CDMA?
`
` A. Yes, it was.
`
` Q. What aspect of DSSS CDMA of your
`
`Ph.D. focused on?
`
` MR. CHAN: Objection. Form.
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` A. I was basically interested in
`
`designing transceivers, essentially algorithms to
`
`improve performance. There are many aspects to
`
`it.
`
` Q. Did those transceivers apply in both
`
`the wide area as well as the local area context?
`
` A. Yes. DSSS CDMA, as I said, is a
`
`generic technique. So...
`
` Q. What do you mean by "generic
`
`technique"?
`
` A. Meaning it's essentially a strategy
`
`for how you design your transmission sequence.
`
`So it can very well be used in the context of any
`
`type of network.
`
` I'm sorry, I have a little bit of
`
`allergies, some postnasal drip. I will be
`
`clearing my throat quite frequently. I
`
`apologize.
`
` Q. Of course. If you need to take a
`
`break at any time, that's okay as well.
`
` So would you say that DSSS CDMA is
`
`network agnostic?
`
` MR. CHAN: Objection. Form.
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`Foundation.
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` A. I'm not even sure what that question
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`means. It's really physical layer technology.
`
` Q. By physical layer, are you referring
`
`to the OSI stack?
`
` A. Yes, typically at the -- I'm not sure
`
`I'm -- physical layer basically is a term that is
`
`associated with techniques that are used where
`
`you do the actual transmission of signals.
`
` Q. What are the other layers of the OSI
`
`stack besides the physical layer?
`
` A. Usually it's the physical layer, and
`
`then there's a data link and MAC layer above it,
`
`and then there's a network layer, transport
`
`layer, application layer.
`
` Q. The layers you just listed are from
`
`the bottom up; is that correct?
`
` A. Yes. That's how they usually -- it's
`
`just a way to depict things. So it's usually
`
`like that.
`
` Q. What generally happens at the
`
`physical layer?
`
` MR. CHAN: Objection. Form.
`
` A. The physical layer usually has to do
`
`with the design of waveforms, signals that you
`
`transmit. Perhaps there might be some
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`overlapping strategies that you use for encoding,
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`decoding signals.
`
` Q. You said the next layer up was the
`
`data link/MAC layer; is that correct?
`
` A. Yes.
`
` Q. What happens at that layer?
`
` MR. CHAN: Objection. Form.
`
` A. So those layers typically you try to
`
`sort of design mechanisms by which the medium
`
`that is being used can be shared. MAC stands for
`
`medium access control.
`
` Q. And the next layer up is the network
`
`layer, correct?
`
` A. Yes.
`
` Q. What happens at the network layer?
`
` MR. CHAN: Objection. Form.
`
` A. So usually, again, it's sort of --
`
`it's hard to characterize what happened. There
`
`are many things that happen. So generically the
`
`network layer is associated with, in some sense,
`
`directing traffic, you know, from a source to,
`
`say, a destination. So it's in a network.
`
` Q. So is another word for directing
`
`traffic routing?
`
` MR. CHAN: Objection. Form.
`
` A. No. Routing is actually a generic
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`term that can be used in many contexts. So I
`
`wouldn't really characterize it like that. But
`
`it's really sort of to make associations between
`
`the source and destination in the context of a
`
`network.
`
` Q. In the OSI model, does routing from
`
`source to destination in the context of a network
`
`occur at the network layer?
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` MR. CHAN: Objection. Form.
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`Foundation.
`
` A. You know, so that's why I said,
`
`routing is determined by many factors. For
`
`instance, it also sometimes has to do with the
`
`underlying PHY and MAC technology. Sorry,
`
`physical layer and MAC layer techniques.
`
` So therefore, to answer your
`
`question, you can characterize it in that way.
`
` Q. Are IP packets routed at the network
`
`layer?
`
` A. I'm sorry, what is that?
`
` Q. Are IP packets routed at the network
`
`layer?
`
` MR. CHAN: Objection to form.
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`Foundation.
`
` A. Yes. So typically networking layer
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`protocols, IPs, yes, is associated with the
`
`networking layer protocol.
`
` Q. What happens at the transport layer?
`
` MR. CHAN: Objection. Form.
`
` A. So transport layer is typically sort
`
`of associated with doing what is called an
`
`end-to-end quality of service. So you can try to
`
`make sure that you have some end-to-end
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`performance guarantees between source and
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`destination.
`
` Q. Your lawyer is going to object to my
`
`questions. That's for later. It's part of the
`
`process. Just please give him a second to object
`
`so that he can object, that gets on the record,
`
`and then you can answer.
`
` A. Okay. I will do a delayed start.
`
` Q. It makes everything easier for
`
`everyone.
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` A. I will also speak slowly, because
`
`I've had experience in the past where my bit rate
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`is too high. So I will work on that, too.
`
` Q. What happens at the application layer
`
`of the OSI model?
`
` MR. CHAN: Objection. Form.
`
` A. So an application layer is typically
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`associated with the application that will run
`
`over these connections that you've established.
`
`And again, when you say what happens, we can
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`spend three days going over what happens.
`
` Q. I think your answers are great.
`
` A. An application layer is also
`
`sometimes used to sort of, you know, establish
`
`sessions.
`
` So again, the original OSI layers and
`
`stack, there was a historic way in which it kind
`
`of was established, and then there has been so
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`many, if you will, enhancements that some of
`
`these layers, in fact, some of the more modern
`
`research really gets into doing things that
`
`perhaps historically you would not have thought
`
`of doing.
`
` Q. Do you know what JINI is?
`
` A. (Witness nods).
`
` Q. Please actually say your answer so we
`
`can get it for the record?
`
` A. JINI.
`
` Q. You know what that is?
`
` A. Yes.
`
` Q. What is JINI?
`
` A. It's basically a Java-based
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`framework, tele-programming based framework, that
`
`allows services to be discovered and shared in
`
`networks.
`
` Q. What do you mean by "framework"?
`
` A. Framework is what it is. I mean...
`
` Q. Is it an application?
`
` A. So it's basically a set of rules for
`
`how it works using Java programs.
`
` Q. What is Java?
`
` A. It's a programming language.
`
` Q. It's one of many programming
`
`languages?
`
` A. Sure.
`
` Q. In terms of your research and
`
`technical expertise before 2001, did any of it
`
`focus on JINI or Java?
`
` A. So that's a weird question, because
`
`-- so my research is about wireless networks,
`
`wireless systems. So if I do research on Java or
`
`JINI, no, I don't.
`
` However, Java or JINI is just a
`
`framework that allows you to make assumptions
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`about how you can model networks or what you can
`
`assume about nodes in a network are capable of
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`doing. That's sort of a more precise statement.
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` Q. You don't have any papers on JINI, do
`
`you? You haven't written any papers on JINI?
`
` MR. CHAN: Objection. Form.
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` A. Do you mean like research papers?
`
` Q. Yes.
`
` A. No.
`
` Q. Do you have any U.S. patents?
`
` A. Do I have any U.S. patents? No.
`
`Although, I have tried to get one.
`
` Q. One U.S. patent?
`
` A. Yeah.
`
` Q. Have you tried to apply for patents
`
`in any other country?
`
` A. No.
`
` Q. What did you try to get a U.S. patent
`
`on?
`
` A. Basically, again, related to access
`
`to information in wireless networks, specifically
`
`in the context of, I would say, very short-range
`
`networks, meaning sort of -- the idea was about
`
`information that is cached and stored in
`
`repositories, and you enable access and download
`
`to these -- this information, you know, when
`
`users are in very close proximity.
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` So that way it allows you to get lots
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`of information without worrying about bandwidth.
`
`So the idea was a system concept called Info
`
`Stations.
`
` Q. Could that work apply to JINI?
`
` A. In JINI, it's just a software
`
`framework that allows you to share devices, and
`
`-- I mean, share services. So the system
`
`basically can be architected to, I would say, you
`
`know, that was not a consideration for a patent,
`
`if you're asking that.
`
` It was really about the idea of how
`
`do you sort of get over the lack of bandwidth for
`
`large amounts of information.
`
` Q. Could somebody develop a system that
`
`both uses JINI and your patent?
`
` MR. CHAN: Objection. Form.
`
` A. I really have not been given any
`
`thought to that. So it's hard for me to give you
`
`an answer to that question.
`
` Q. What about any of the research that
`
`you did, could any of that apply to JINI or be
`
`used with JINI?
`
` MR. CHAN: Objection. Form.
`
`Foundation.
`
` A. Again, I'm saying -- I find this
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`question completely -- I don't have any context
`
`for this question, seriously.
`
` Q. Okay. So would it be accurate to say
`
`that you've not done any research at all in the
`
`JINI area or never worked in that area?
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` MR. CHAN: Objection to form.
`
`Foundation.
`
` A. As I said, as we -- sorry. Finish
`
`your objections.
`
` MR. CHAN: Yes. I think it's on the
`
`record.
`
` A. As I told you, a wireless network, a
`
`telecommunication network, a telecommunication
`
`network, has all of these layers in the protocol
`
`stack. So people work on, you know, everything
`
`comes together because different people work on
`
`different things, and then sort of it is
`
`harmonized into a system.
`
` So this question that you're asking
`
`me about, I really don't get it.
`
` Q. Could JINI harmonize into a system
`
`that also incorporates teachings from your work?
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` MR. CHAN: Objection to form.
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`Foundation.
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` A. I have not given it a thought,
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`seriously. Something to think about.
`
` Q. So if you were to characterize your
`
`background in JINI, when you first learned about
`
`it or what your knowledge is of JINI, how would
`
`you characterize that?
`
` MR. CHAN: Objection. Form.
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`Foundation.
`
` A. I cannot give you an exact answer to
`
`that, because as somebody who has been working in
`
`this field for over 25 years now, there are so
`
`many developments that happen at various times,
`
`as I said, by different people in different
`
`fields who work in these things.
`
` I would say every development informs
`
`other developments. So, you know, how you go
`
`about architecting models, how you start thinking
`
`about problems, they evolve.
`
` Q. When did you first hear about JINI?
`
` A. At about the time when, perhaps, Java
`
`became popular, and then JINI became popular. So
`
`I don't have an exact time frame. I'm sorry. I
`
`don't remember.
`
` Q. Was it before 2001?
`
` A. I really cannot answer that. I
`
`really don't know. I don't remember.
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
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`28
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`Narayan B. Mandayam, Ph.D. - May 18, 2016
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` Q. So you can't say that in 2001 you
`
`were familiar with JINI?
`
` MR. CHAN: Objection to form.
`
`Foundation.
`
` A. I don't remember. That's my answer.
`
` I have to remember to do the delayed
`
`start. Sorry.
`
` Q. What is 802.11?
`
` A. It's a wireless local area networking
`
`technology.
`
` Q. Did you do any work in the 802.11
`
`area before 2001?
`
` A. I'm trying to think. You know, I
`
`cannot remember off the top of my head. I mean,
`
`I worked on 802.11 for a long time, on various
`
`aspects of it. But I don't -- I cannot remember,
`
`to tell you the truth.
`
` Q. So you can't say as of 2001 you had
`
`done any work in 802.11; is that correct?
`
` MR. CHAN: Objection to form.
`
` A. Again, when you say 802.11, 802.11 is
`
`a standard, and a standard for how a holistic
`
`system works, and there are various aspects of
`
`it. Again, people work on it. There's an OSI
`
`stack. Different people work on different
`
`GregoryEdwards, LLC | Worldwide Court Reporting
`GregoryEdwards.com | 866-4Team GE
`
`29
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`Narayan B. Mandayam, Ph.D. - May 18, 2016
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`Page 30
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`elements of it. Things, then, sort of come
`
`together.
`
` As I said -- one thing I can tell you
`
`for sure, I worked at this place called WIN Lab.
`
`I'm an associate director of the Wireless
`
`Information Network Laboratory. So we have been
`
`in existence since 1989.
`
` We do what is called a free
`
`competitive research. So we work on topics that
`
`perhaps will come to fruition maybe five years
`
`down the road, sometimes ten years down the road.
`
`So we work on a lot advanced concept
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