WILLIAM W. CHUANG - CONFIDENTIAL
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`RPX Corporation,
`
`IPR2015-01750
`Case No.:
`Patent No: 8,484,111
`
`Petitioner,
`
`V.
`
`Applications in Internet Time
`LLC,
`
`Patent Owner.
`
`Case No.
`Case No.
`
`IPR2015-01751
`IPR2015-01752
`
`Patent No.: 7,356,482
`
`CONFIDENTIAL - PROTECTIVE ORDER MATERIAL
`
`DEPOSITION OF WILLIAM W. CHUANG
`
`San Francisco, California
`
`January 30, 2019
`
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`Reported by:
`Kayla Knowles
`CSR No.
`14071
`
`1
`
`
`
`RPX Exhibit 1095
`
`RPX V. AIT
`
`IPR2015-01751
`
`RPX Exhibit 1095
`RPX v. AIT
`IPR2015-01751
`BARKLEY—‘—
`Courl Riparian
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`RPX Corporation,
`
`IPR2015-01750
`Case No.:
`Patent No: 8,484,111
`
`Petitioner,
`
`V.
`
`Applications in Internet Time
`LLC,
`
`Patent Owner.
`
`Case No.
`Case No.
`
`IPR2015-01751
`IPR2015-01752
`
`Patent No.: 7,356,482
`
`CONFIDENTIAL - PROTECTIVE ORDER MATERIAL
`
`DEPOSITION OF WILLIAM W. CHUANG
`
`San Francisco, California
`
`January 30, 2019
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`Reported by:
`Kayla Knowles
`CSR No.
`14071
`
`1
`
`
`
`RPX Exhibit 1095
`
`RPX V. AIT
`
`IPR2015-01751
`
`RPX Exhibit 1095
`RPX v. AIT
`IPR2015-01751
`BARKLEY—‘—
`Courl Riparian
`
`
`
`WILLIAM W. CHUANG - CONFIDENTIAL
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`RPX Corporation,
`
`vs.
`
`Petitioner,
`
`Applications in Internet
`Time LLC,
`
`Patent Owner.
`
`IPR2015—01750
`Case No.:
`Patent No: 8,484,111
`
`Case No.
`Case No.
`
`IPR2015—01751
`IPR2015—01752
`
`Patent No.: 7,356,482
`
`Deposition of WILLIAM W.
`
`CHUANG, at Barkley Court
`
`Reporters, 201 California Street,
`
`Suite 375, San
`
`Francisco, California, beginning at 9:55 a.m., Wednesday,
`
`January 30, 2019, before KAYLA KNOWLES, Certified
`
`Shorthand Reporter No. 14071.
`
`
`
`BARKLEY—‘—
`Cour! Riparian
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`A P P E A R A N C E S
`
`FOR THE PETITIONER:
`
`WOLF, GREENFIELD & SACKS, P.C.
`
`RICHARD F. GIUNTA
`By:
`ELISABETH H. HUNT, PH.D.
`By:
`600 Atlantic Avenue
`
`Boston, Massachusetts 02210—2206
`617.646.8000
`
`rich.giunta@wolfgreenfield.com
`ehunt@wolfgreenfield.com
`
`RPX CORPORATION
`
`STEVE CHIANG
`By:
`One Market Plaza
`Steuart Tower
`
`San Francisco, California 94105
`415.852.3188
`
`schiang@rpxcorp.com
`
`FOR THE PATENT OWNER:
`
`SOCAL IP LAW GROUP, LLP
`
`STEVEN C. SEREBOFF
`By:
`310 N. Westlake Boulevard, Suite 120,
`
`Westlake Village, California 91362
`805.230.1356
`
`ssereboff@socalip.com
`
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`I N D E X
`
`EXAMINATION BY MR. SEREBOFF
`
`EXAMINATION BY MS. HUNT
`
`PAGE
`
`119
`
`EXHIBIT
`
`Exhibit
`2214
`
`Exhibit
`2215
`
`Exhibit
`2216
`
`Exhibit
`2217
`
`Exhibit
`2218
`
`Exhibit
`2219
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`Exhibit
`2220
`
`Exhibit
`2221
`
`Exhibit
`2222
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`Exhibit
`2223
`
`E X H I B I T S
`
`DESCRIPTION
`
`PAGE
`
`Declaration of William W. Chuang,
`Bates Numbers RPX000099 to RPXOOOlZl
`
`Second Declaration of William W.
`
`Chuang
`
`Protective Order Material, Bates
`Numbers RPXOOOO77 to RPXOOOO9O
`
`Protective Order Material, Bates
`Numbers RPX000091 to RPX000093
`
`Protective Order Material, Bates
`Numbers RPXOOOO94 to RPXOOOO98
`
`Membership and License Agreement,
`Bates Numbers RPX000014 to RPX000025
`
`First Amendment to the Membership and
`License Agreement, Bates Numbers
`RPXOOOOO9 to RPXOOOOll
`
`Second Amendment to the Membership and
`License Agreement, Bates Numbers
`RPX000012 to RPX000013
`
`Validity Challenge Identification,
`Bates Numbers RPXOOOO68 to RPXOOOO73
`
`Validity Challenge Identification
`Process and Best Practices, Bates
`Numbers RPXOOOO74 to RPXOOOO75
`
`---oOo-—-
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`San Francisco, California
`
`Wednesday, January 30, 2019
`
`--—oOo——-
`
`BE IT REMEMBERED that set on Wednesday,
`
`the 30th day
`
`of January, 2019, commencing at the hour of 9:55 a.m., at
`
`the office of Barkley Court Reporters, 201 California
`
`Street, Suite 375, San Francisco, California, before me,
`
`Kayla Knowles, CSR No. 14071, a Certified Shorthand
`
`Reporter, personally appeared
`
`WILLIAM W. CHUANG,
`
`having been called as a witness by the Patent Owner, who,
`
`being by me first duly sworn, was thereupon examined and
`
`testified as hereinafter set forth.
`
`--—oOo——-
`
`EXAMINATION
`
`BY MR. SEREBOFF:
`
`Q
`
`A
`
`Q
`
`Would you state your name for the record, please.
`
`My name is Will Chuang, C-H—U-A—N-G.
`
`Are you the same -- are you also known as William
`
`W. Chuang?
`
`A
`
`Q
`
`That's my full name, yes.
`
`I go by Will.
`
`Okay. Well, can we see some form of
`
`identification so that we can confirm that you are you?
`
`A
`
`Q
`
`Happy to.
`
`I have a California driver's license.
`
`Thank you.
`
`So before we get into the questions
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
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`and the answers,
`
`some general admonishments. Actually,
`
`just curious.
`
`Have you ever been deposed before?
`
`I have not.
`
`Okay.
`
`Interesting. You're a lucky person.
`
`I View myself that way. Thanks.
`
`Okay.
`
`So we probably will take some breaks,
`
`A
`
`Q
`
`A
`
`Q
`
`but -- and if you need to take a break,
`
`just let me know.
`
`We're not allowed to take a break unless I give the go
`
`ahead, but I try to be a reasonable person about it.
`
`One thing that I'm not reasonable about is if
`
`there's a question pending, we won't take a break.
`
`Generally speaking, what we try to do is take breaks at
`
`logical breaking points,
`
`like, you know, a line of
`
`questioning gets resolved, and then we can take a break.
`
`During the course of this deposition, you can't
`
`ask any of your attorneys for help. And I noticed that
`
`Mr. Chiang is here.
`
`MR. SEREBOFF: Steve, are you here as an
`
`attorney? What's the basis for your appearance today?
`
`MR. CHIANG: You can address me as Mr. Chiang
`
`instead of Steve, and my basis is I am in-house counsel
`
`for RPX. Unless there's a rule that you can point to that
`
`prohibits my attendance here, please go on with the
`
`deposition.
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`MR. SEREBOFF: All I asked is why you're here.
`
`So you're here as an attorney for RPX.
`
`MR. CHIANG:
`
`I'm in—house counsel for RPX.
`
`MR. SEREBOFF: Rich,
`
`is that correct?
`
`Is he here
`
`as an attorney for RPX?
`
`I'm not trying to play games.
`
`I'm just trying to understand what the basis for his being
`
`in the room is.
`
`MR. GIUNTA: Why do you need to understand what
`
`the basis for -- this is a public proceeding; right? We
`
`have confidential information, but he's available from
`
`RPX.
`
`And just so that we're clear, we want to mark the
`
`transcript confidential protective order material.
`
`What's the problem with Mr. Chiang being here?
`
`MR. SEREBOFF:
`
`I didn't say that there was.
`
`MR. GIUNTA: Okay.
`
`MR. SEREBOFF:
`
`I just asked why.
`
`He got
`
`defensive.
`
`You got defensive.
`
`I just asked a simple
`
`question why.
`
`MR. CHIANG: Please proceed with the deposition,
`
`Mr. Sereboff. You're wasting time.
`
`MR. SEREBOFF:
`
`It's my deposition, Mr. Chiang.
`
`I
`
`will decide how we run it.
`
`So for the record, my appearance,
`
`I am Steven
`
`Sereboff appearing for Applications in Internet Time.
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
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`MR. CHIANG:
`
`Do we need to confirm your identity,
`
`Mr. Sereboff? Have you brought a driver's license here
`
`today?
`
`MR. SEREBOFF: Mr. Chiang, if you're going to
`
`interrupt me,
`
`I am going to ask you to leave.
`
`MR. GIUNTA:
`
`So he didn't interrupt you.
`
`I am
`
`Richard Giunta with Greenfield representing RPX. With me
`
`is Elisabeth Hunt, also from Wolf Greenfield and
`
`Mr. Chiang from RPX.
`
`MR. SEREBOFF: Great.
`
`Thank you.
`
`BY MR. SEREBOFF:
`
`Q
`
`So getting back to the ground rules.
`
`During the course of the deposition, while we are
`
`on the record, you're not allowed to ask any of your
`
`attorneys for help.
`
`Do you understand that?
`
`A
`
`Q
`
`Yes.
`
`And as you've already done capably, when I ask
`
`you a question, you need to answer audibly, for example,
`
`yes or no.
`
`Do you understand?
`
`A
`
`Q
`
`I do.
`
`Great.
`
`So shaking your head doesn't go on the
`
`record, but something —- something spoken does.
`
`Do you
`
`understand?
`
`A
`
`Q
`
`I do.
`
`Great. And as I am asking questions, your
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
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`attorneys may state objections. What I will tell you is,
`
`irrespective of an objection, you do have to answer every
`
`one of my questions I ask unless your attorneys
`
`specifically say not to. Now, of course, if you don't
`
`understand a question, you can say that as well.
`
`Do you
`
`understand?
`
`A
`
`Q
`
`I do understand.
`
`Great. And,
`
`furthermore,
`
`in order to keep the
`
`record relatively clean, it works best if we don't
`
`interrupt one another.
`
`So, for example,
`
`if you're
`
`speaking,
`
`I'm not going to interrupt you; if I'm speaking,
`
`you won't interrupt me.
`
`Do you understand?
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`I do.
`
`So you are an employee of RPX;
`
`is that correct?
`
`That is correct.
`
`And what is your title?
`
`My current title is executive Vice president of
`
`client services.
`
`Q
`
`A
`
`And how long have you worked for RPX?
`
`I guess it would be -- I started at the beginning
`
`of 2011; so since January of 2011.
`
`Q
`
`A
`
`Q
`
`And do you have -- did you go to university?
`
`For —-
`
`Strike that.
`
`Do you have a bachelor's degree?
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`I do have a bachelor's degree.
`
`And what is that degree in?
`
`My bachelor's degree is in industrial and
`
`A
`
`Q A
`
`operations engineering.
`
`And did you go to graduate school?
`
`I went to law school after undergraduate.
`
`Did you work after undergraduate and before law
`
`I did not.
`
`And where did you go to law school?
`
`I went to law school at Harvard.
`
`And when did you graduate from Harvard?
`
`In summer of 1993.
`
`And are you a member of a bar anywhere?
`
`I'm an active member of the California Bar.
`
`Q A
`
`Q s
`
`chool?
`
`(3FE)F(JPE)F
`
`And how long have you been an active member of
`
`the California Bar?
`
`Well,
`
`I guess that would be since December of
`
`A 1
`
`993.
`
`Q m
`
`Okay. And since the time that you've been a
`
`ember of the California Bar, aside from your work at RPX,
`
`have you worked as an attorney?
`
`Yes, I've worked as a practicing attorney.
`
`I'm sorry. You worked as what?
`
`I worked as an attorney in private practice.
`
`A
`
`Q A
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`Q
`
`Could you just briefly summarize your work
`
`history as an attorney?
`
`A
`
`Well,
`
`I Clerked for a year for a federal district
`
`court judge in San Francisco in 1993,
`
`the year after I
`
`graduated.
`
`And then I went to a law firm that was called
`
`McCutchen Doyle Brown & Enersen back then. And I was
`
`there for until 1998, at which point I moved law firms.
`
`You want me to --
`
`Q
`
`A
`
`Yeah, keep going, please.
`
`Okay.
`
`From McCutchen,
`
`I went to another firm
`
`called Brobeck Phleger & Harrison, and I was there until
`
`the -— until Brobeck dissolved, at which point I went to
`
`O'Melveny & Myers, and I was at O'Melveny & Myers up
`
`until -— that was my previous job before going to RPX.
`
`Q
`
`And in your current work at RPX, do you consider
`
`any of that to be legal work?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS: Yeah,
`
`I'm not sure how you would --
`
`I am not sure I understand your question. Are you —- can
`
`you clarify your question?
`
`BY MR. SEREBOFF:
`
`Q
`
`Do you View your work at RPX as the work of an
`
`attorney?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`THE WITNESS:
`
`I don't
`
`-— we have attorneys at
`
`RPX,
`
`in—house attorneys.
`
`I'm not one of them.
`
`BY MR. SEREBOFF:
`
`Q
`
`Now, as a member of the California Bar,
`
`I assume
`
`that -- strike that.
`
`As a member of the California Bar, are you
`
`familiar with your duties as an attorney, generally?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS:
`
`Do you mean —— do you mean ethical
`
`duties?
`
`BY MR. SEREBOFF:
`
`Q
`
`A
`
`Q
`
`Yes, ethical duties.
`
`Yes.
`
`And those ethical duties include duty of loyalty?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS:
`
`To m
`
`——
`
`BY MR. SEREBOFF:
`
`Q
`
`That an attorney has a duty of loyalty to their
`
`client?
`
`A
`
`Q
`
`A
`
`Yes.
`
`An attorney has a fiduciary duty to their client?
`
`Yes.
`
`MR. SEREBOFF: Okay.
`
`I want to put into the
`
`record Will's first and second declaration.
`
`(Exhibit No. 2214 marked for
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`identification.)
`
`MR. SEREBOFF: That's the first. Here's the
`
`second.
`
`(Exhibit No. 2215 marked for
`
`identification.)
`
`BY MR. SEREBOFF:
`
`Q
`
`So, Mr. Chuang,
`
`these were previously marked as
`
`Exhibits 1019 and 1073.
`
`Do you see that?
`
`A
`
`Q
`
`I do.
`
`Okay.
`
`MR. GIUNTA:
`
`I'm sorry, Steve,
`
`to interrupt.
`
`I'm
`
`not sure it's clear which one is which.
`
`Can we make sure
`
`the record is clear that -— I assume 2214 is his first
`
`declaration, which was formerly 1019, but it wasn't clear
`
`to me.
`
`MR. SEREBOFF: Yeah.
`
`MR. GIUNTA:
`
`Thank you.
`
`MR. SEREBOFF:
`
`I'm sorry if I was unclear.
`
`MR. GIUNTA:
`
`Thank you.
`
`BY MR. SEREBOFF:
`
`Q
`
`So do you have any reason to believe that these
`
`aren't copies of the declarations that you've submitted in
`
`these IPRs?
`
`A
`
`I haven't looked at them; so I don't know.
`
`I
`
`don't have a reason.
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`Okay. And as far as --
`
`I'm assuming.
`
`As far as I know,
`
`they are accurate copies. And
`
`Q
`
`A
`
`Q
`
`if you want to take a minute and leaf through just to
`
`confirm, that's fine.
`
`A
`
`That would help.
`
`Thank you.
`
`I don't see a reason to doubt that they're
`
`copies.
`
`Q
`
`Great.
`
`Thank you.
`
`Now, within these two declarations, you use some
`
`terms, and I just want to confirm that we can continue
`
`using those terms in the way that you use them in your
`
`declaration, and these terms are RPX. Okay?
`
`A
`
`Q
`
`A
`
`Q
`
`A
`
`Q
`
`I think so, yes.
`
`Salesforce?
`
`Yes.
`
`AIT?
`
`Yes.
`
`AIT patents?
`
`If you want to look and see how
`
`you've defined them, that's fine. But, honestly,
`
`these
`
`are terms I pulled out of your declaration just to make
`
`sure that we could just use these so I don't --
`
`A
`
`You're talking about the defined term AIT
`
`patents?
`
`Q
`
`Right, AIT patents.
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`Okay.
`
`CBM.
`
`Do you know where that's used?
`
`Not offhand.
`
`Okay.
`
`So if you're referring to the use of CBM
`
`>E)PC)F
`
`in paragraph 26 of my first declaration, Exhibit 1019,
`
`then, yes,
`
`I agree.
`
`Q
`
`Great.
`
`So we will keep using CBM in the same way
`
`that you used it there.
`
`A
`
`Q
`
`A
`
`Yes.
`
`Great.
`
`IPR.
`
`I guess I'm not sure how that's defined.
`
`It's --
`
`you know,
`
`I understand what it means, at least I think I
`
`do.
`
`Q
`
`Well, what I am just trying to confirm is that
`
`we're going to use the term —- so just to understand, one
`
`of the other terms is AIT IPRs.
`
`A
`
`Q
`
`Okay.
`
`So IPR is a general term, and then we will talk
`
`about the AIT IPRs. And these are terms you used in your
`
`two declarations, and I want to confirm that we can
`
`continue using them in the deposition the same way you
`
`used them in your declaration.
`
`A
`
`So I agree we should continue using them in the
`
`same way.
`
`I'm just not —-
`
`I think it will depend on the
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`context.
`
`The reference to it may vary, depending on the
`
`context of the question or the specific topic that we're
`
`talking about.
`
`I am just not certain. But happy to be
`
`consistent with my declaration.
`
`Q
`
`So do you find that sometimes terms can have
`
`different meanings in different contexts?
`
`A
`
`Yeah,
`
`the same term could mean something
`
`different, depending on the circumstances.
`
`Q
`
`So during the course of today's deposition,
`
`the
`
`same term could have different meanings, depending on the
`
`context?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS:
`
`I don't know.
`
`It depends on the
`
`your question.
`
`I don't know where your line of
`
`questioning will go; so I can't tell you there will be a
`
`definitive difference in the use of the term.
`
`MR. SEREBOFF: Will you read back my question?
`
`(Record read.)
`
`THE WITNESS: And my response is I don't know
`
`where your line of questions is going to go; so I don't
`
`know that it will definitively have a different meaning
`
`because I don't know what the context is until I hear it.
`
`BY MR. SEREBOFF:
`
`Q
`
`A
`
`Right. But it's possible?
`
`I would think so, yes.
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`Q
`
`And just curious, you think that,
`
`in your
`
`declarations, could there have been some inconsistent use
`
`of terminology?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS: Not that I'm aware of, but I'm
`
`happy to go through and assess it in each instance,
`
`if you
`
`want.
`
`BY MR. SEREBOFF:
`
`Q
`
`Okay. Let's talk about some other terms just to
`
`keep things easy for everybody.
`
`When I refer to the petitions, what I'm referring
`
`to are the petitions for IPR in the AIT IPRs.
`
`Is that
`
`clear?
`
`A
`
`Q
`
`Our petitions.
`
`Yes. That would be RPX's petitions.
`
`So if you'd
`
`like, I'll call them RPX's petitions. Would that be
`
`clearer?
`
`A
`
`Q
`
`Yes.
`
`Okay. And if I refer to the PTAB, do you
`
`understand that's the Patent Trial and Appeal Board at the
`
`US Patent and Trademark Office?
`
`A
`
`Q
`
`Yes.
`
`Great. And if I talk about the CAFC or the
`
`federal circuit, you can understand that's the Court of
`
`Appeals for the federal circuit?
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`A
`
`Q
`
`Yes.
`
`Am I speaking too fast?
`
`(Reporter clarification.)
`
`BY MR. SEREBOFF:
`
`Q
`
`As you were leafing through your declarations,
`
`you didn't happen to notice if there was any assertion of
`
`privilege in these declarations, did you?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`BY MR. SEREBOFF:
`
`Q
`
`A
`
`Q
`
`I just asked if you noticed.
`
`I'm confused by the question.
`
`As you were leafing through your declarations
`
`right now, did you notice if there was any assertion of
`
`attorney—client privilege?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS:
`
`I didn't notice, but I wasn't
`
`looking for that purpose.
`
`BY MR. SEREBOFF:
`
`Q
`
`Okay. Could you take a few minutes and go
`
`through these declarations and tell me if you find any
`
`assertion of attorney—client privilege in either of those
`
`declarations?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS:
`
`So just so I understand what I
`
`should be doing, you want me to go through and determine
`
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`whether something in the declaration should be deemed
`
`privileged or we would claim that it's privileged?
`
`Is
`
`that ——
`
`BY MR. SEREBOFF:
`
`Q
`
`No.
`
`I'm just asking you if there's any statement
`
`in your declarations that something is privileged.
`
`A
`
`Q
`
`I can look.
`
`I'm not asking for your opinion as a lawyer if
`
`something is privileged;
`
`I'm just asking if there's an
`
`assertion of privilege.
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS:
`
`I can look for it.
`
`I'll be honest.
`
`I'm still confused by the question. What's an example of
`
`something that would be a declaration that would be
`
`privileged?
`
`BY MR. SEREBOFF:
`
`Q
`
`I'm sorry.
`
`I'm the one asking the questions; so
`
`if you don't understand a question, that's a legitimate
`
`response.
`
`A
`
`Q
`
`Okay.
`
`But you do understand what the attorney-client
`
`privilege is, don't you?
`
`A
`
`Q
`
`I do, yes.
`
`And you're familiar with assertions of
`
`attorney-client privilege?
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`I am.
`
`So all I'm asking is,
`
`is there any assertion of
`
`A
`
`Q
`
`attorney—client privilege in either of these declarations?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS: You mean an express assertion as
`
`part of the declaration?
`
`BY MR. SEREBOFF:
`
`Q
`
`A
`
`Q
`
`A
`
`Yes. Great.
`
`Let me look.
`
`Thanks.
`
`I don't see any express assertions of privilege
`
`in any declarations.
`
`Q
`
`A
`
`Q
`
`A
`
`Q
`
`Thank you.
`
`Did you prepare for this deposition?
`
`I did.
`
`What did you do to prepare for it?
`
`I read my declarations with our attorneys.
`
`Did you review any other documents besides the
`
`declarations?
`
`A
`
`Q
`
`Some of the exhibits.
`
`Okay. These would be the exhibits to your
`
`declarations?
`
`A
`
`Q
`
`Correct.
`
`Okay.
`
`Paragraph 32 of your first declaration
`
`refers to,
`
`in the second sentence, Bates range RPXOOOO77
`
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`to RPXOOOOQO.
`
`Do you see that?
`
`A
`
`Q
`
`Yes.
`
`Okay.
`
`I'm going to hand you three more exhibits,
`
`which would be the documents in that range.
`
`(Exhibit No. 2216 marked for
`
`identification.)
`
`(Exhibit No. 2217 marked for
`
`identification.)
`
`(Exhibit No. 2218 marked for
`
`identification.)
`
`MR. GIUNTA:
`
`I'm sorry, Counsel.
`
`Just to make
`
`the record clear,
`
`I believe you said the exhibits are
`
`going to be in the range that go up to Bates number ending
`
`in -90, and two of these are outside of that range.
`
`MR. SEREBOFF: You are correct. Thanks, Rich.
`
`BY MR. SEREBOFF:
`
`Q
`
`So, Mr. Chuang, are you familiar with these three
`
`documents? Have you seen any of these three before?
`
`A
`
`It's been a long time since I've seen them, but I
`
`did see them when we put together this first declaration.
`
`Q
`
`So for the benefit of the record, could you tell
`
`me —- so Exhibit 2216 begins -- and as a shorthand, we
`
`will just refer to the last two digits of the Bates
`
`number.
`
`So on Exhibit 2216, it starts with Bates 77.
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`Where does that end?
`
`A
`
`Q
`
`it end?
`
`A
`
`Q
`
`Sorry. Exhibit 2216?
`
`Right.
`
`So it starts with Bates 77. Where does
`
`What's Exhibit 2216?
`
`It starts with -- it starts with Bates 77.
`
`MR. GIUNTA:
`
`I'm sorry. Steve,
`
`I think the
`
`confusion is -- we don't know yet. You handed three
`
`documents, but I am not sure the record was clear about
`
`what exhibit numbers you were adding to each of them.
`
`THE WITNESS:
`
`So I don't know what
`
`the reference
`
`to Exhibit 2216 is or whatever number you said. There is
`
`a Bates stamp RPX000077, but there's no exhibit stamp on
`
`it; so I'm not sure.
`
`BY MR. SEREBOFF:
`
`Q
`
`Right. Bates —- so the document that starts with
`
`Bates 77 is 2216.
`
`A
`
`It is.
`
`MR. SEREBOFF:
`
`See that, Rich? You with me,
`
`Mr. Giunta?
`
`MR. GIUNTA:
`
`I now hear that we're going to mark
`
`the one that begins with 77 as Exhibit 2216.
`
`So is it
`
`okay if the witness is going to write it on his?
`
`MR. SEREBOFF: That's fine.
`
`///
`
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`BY MR. SEREBOFF:
`
`Q
`
`The one that begins with 91 was marked as 2217,
`
`Exhibit 2217. And the one that begins with 94 is marked
`
`as 2218.
`
`MR. GIUNTA:
`
`Thank you.
`
`MR. SEREBOFF: You're welcome.
`
`THE WITNESS:
`
`Thank you.
`
`BY MR. SEREBOFF:
`
`Q
`
`So Exhibit 2216 that begins with Bates 77, where
`
`does that end?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS:
`
`I don't -- what is -- I'm not sure
`
`I understand your question. Where does what --
`
`BY MR. SEREBOFF:
`
`Q
`
`A
`
`What is the last Bates number on that exhibit?
`
`Oh,
`
`the last Bates number on that Exhibit 2216
`
`is —— ends at 90.
`
`Q
`
`And if you look at Exhibit 2217, starting with
`
`Bates 91, and then you see the next page is Bates 92, and
`
`the last page is Bates 93.
`
`Do you see that?
`
`A
`
`Q
`
`I see that, yes.
`
`Great.
`
`Now let's look at Exhibit 2218.
`
`It
`
`starts with Bates 94 and then Bates 95,
`
`then Bates 96,
`
`Bates 97, and Bates 98; correct?
`
`A
`
`Correct.
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`Q
`
`Good. Okay. And you said that you've seen these
`
`before.
`
`Do you understand that these were produced by RPX
`
`in the AIT IPRs?
`
`A
`
`Q
`
`A
`
`were.
`
`Q
`
`A
`
`I do.
`
`And do you know what they are?
`
`I was told these were —— I was told what they
`
`What were you told that they were?
`
`They were —-
`
`I was told these were a log of the
`
`responsive information to your -— to AIT's discovery
`
`requests -- to some of them.
`
`Q
`
`And to your best understanding, what is the
`
`information on these documents representative of?
`
`A
`
`You know,
`
`I -— they seem to be a listing of -— in
`
`Exhibit 2218, a listing of e—mails that include someone
`
`from Salesforce and somebody from RPX.
`
`And in Exhibit 2217, it appears to be a listing
`
`of phone calls or meetings between someone from RPX and
`
`someone from Salesforce. Well,
`
`to be more clear,
`
`in
`
`Exhibit 2217,
`
`the meetings between —— this seems to be a
`
`listing of the meetings between someone from Salesforce
`
`and someone from RPX who is responsible -— who was
`
`responsible, at the time, for managing our Salesforce tool
`
`used internally.
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`
`Q
`
`A
`
`What do you mean by "our Salesforce tool"?
`
`We —— RPX uses Salesforce —— Salesforce's general
`
`service for its own internal business purposes. And I'm
`
`not sure exactly what these —-
`
`these phone calls or
`
`meetings were about, but
`
`they involved the person who was
`
`responsible for making sure that we implement —— that
`
`we've implemented Salesforce internally correctly and
`
`managed the -— the effective use and training of it as a
`
`tool.
`
`Q
`
`And how do you know,
`
`from looking at this,
`
`that
`
`that's the case?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS:
`
`The person,—, was ——
`
`her principal responsibility at RPX was to manage our
`
`Salesforce tool for internal use.
`
`BY MR. SEREBOFF:
`
`Does RPX have a name for that Salesforce tool?
`
`We call it Salesforce.
`
`Okay. We will keep calling it the Salesforce
`
`Q
`
`A
`
`Q
`
`tool.
`
`So going back to your declaration, paragraph 32,
`
`the first stack.
`
`So could you read to me the first two
`
`sentences?
`
`A
`
`Q
`
`Of paragraph 32?
`
`Yes.
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`Of my first declaration?
`
`Yes.
`
`Okay.
`
`"AIT's Discovery Request Number 4 calls
`
`A
`
`Q
`
`A
`
`for documents sufficient to show information relating to
`
`meetings or communications between Salesforce and RPX that
`
`are not limited to communications about the AIT—Salesforce
`
`litigation,
`
`the AIT patents, or the AIT IPRs.
`
`The
`
`document provided is Bates range RPXOOOO77 to RPXOOOO9O -—
`
`is responsive to that request."
`
`Q
`
`A
`
`Thank you. Could you please keep reading?
`
`Continuing in paragraph 32, my first declaration,
`
`"The vast majority of e-mail communications were in
`
`connection with setting up meetings and did not include
`
`any substantive content.
`
`The listing of participants in
`
`meetings and phone calls is based on best recollection and
`
`airs on the side of being overinclusive."
`
`You want me to continue?
`
`Q
`
`A
`
`Certainly continue. You stopped at a semicolon.
`
`"It is therefore possible that some of the listed
`
`individuals may not have actually attended."
`
`Q
`
`A
`
`Okay. One more sentence.
`
`"Any meeting or communication not summarized in
`
`the Section Roman III above had nothing to do with the
`
`AIT—Salesforce litigation,
`
`the AIT patents, or the AIT
`
`IPRS."
`
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`Q
`
`Okay.
`
`So at the time that you wrote your
`
`declaration,
`
`this last sentence, you said "any meeting or
`
`communication."
`
`Did you have any reason to believe that there was
`
`anything -- that "any" meant anything other than "any"?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS:
`
`Can you restate your question?
`
`BY MR. SEREBOFF:
`
`Q
`
`No. Actually, I'd like you to try to answer it
`
`as best you can.
`
`A
`
`Okay.
`
`Can you restate your question or have it
`
`read back?
`
`(Record read.)
`
`THE WITNESS:
`
`I think it meant any.
`
`BY MR. SEREBOFF:
`
`Q
`
`A
`
`And you still believe it means any?
`
`I believe it means what I thought it meant back
`
`when I made the declaration.
`
`Q
`
`Okay.
`
`So you have no reason to change your
`
`testimony from what's in paragraph 32?
`
`A
`
`Q
`
`Not that I'm aware of.
`
`So you believe that Exhibit 2216 identifies any
`
`meeting or communication as set forth in the last sentence
`
`of paragraph 32?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`THE WITNESS:
`
`I guess I'm still confused by
`
`that -- I'm confused by that question.
`
`The "any meeting
`
`or communication" —— sorry.
`
`I'm going back to my
`
`declaration.
`
`Can you restate the last question, please?
`
`(Record read.)
`
`THE WITNESS: Yes,
`
`I believe that Exhibit 2216
`
`sets forth the "any meeting or communication" summarized
`
`in paragraph 3 of my first declaration.
`
`BY MR. SEREBOFF:
`
`Q
`
`Okay. Great.
`
`Now, you talked about
`
`Exhibit 2217, and you said this relates to the Salesforce
`
`tool;
`
`is that correct?
`
`A
`
`The internal Salesforce tool that we use for our
`
`business, yes.
`
`Q
`
`Okay. And so the -— the meetings logged, as
`
`referenced in or summarized in Exhibit 2217,
`
`there's no
`
`reason to have them included in 2216; correct?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS:
`
`Can you remind me what the
`
`discovery request —— I'm not allowed to ask questions.
`
`I don't know —-
`
`I don't remember -- I don't
`
`remember the specific requests that these were responsive
`
`to.
`
`It's been quite a while.
`
`///
`
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`BY MR. SEREBOFF:
`
`Q
`
`That's fine.
`
`So you just read paragraph 32 of
`
`your first declaration; so I assume that you understand
`
`what Exhibit 2216 covers; right?
`
`Do you not understand
`
`what Exhibit 2216 covers?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS: Hold on.
`
`So please give me a
`
`moment, and let me take a look at Roman III of my
`
`declaration.
`
`BY MR. SEREBOFF:
`
`Q
`
`A
`
`Sure.
`
`Take your time.
`
`Can I ask to see Discovery Request Number 3?
`
`I
`
`just don't remember what that discovery request was.
`
`Q
`
`A
`
`I don't think I have that handy.
`
`It appears to be -- it appears to be a list of
`
`communications that's responsive to Request Number 3, and
`
`I don't know —— I don't remember specifically the
`
`parameters of that request.
`
`Q
`
`Okay.
`
`Do you see any of the —— referring to
`
`Exhibit 2217, do you see any of the entries in
`
`Exhibit 2217 included in Exhibit 2216?
`
`A
`
`Q
`
`I do not.
`
`Okay.
`
`Since we're doing this, why don't you take
`
`a look at Exhibit 2218 now.
`
`Do you see any of the entries in Exhibit 2218
`
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`included in Exhibit 2216?
`
`A
`
`Q
`
`I do not.
`
`Okay. Looking at Exhibit 2218, did you notice
`
`that the entries are not
`
`in chronological order; so you
`
`can see that the first one is January 16th of 2014? You
`
`see that?
`
`A
`
`Yes.
`
`MR. GIUNTA: Objection.
`
`Form and scope.
`
`BY MR. SEREBOFF:
`
`Q
`
`A
`
`And the second is July 14, 2015?
`
`Yes.
`
`MR. GIUNTA: Objection --
`
`BY MR. SEREBOFF:
`
`Q
`
`But then if you keep going,
`
`the third one is now
`
`January 28th of 2015, not in chronological order; right?
`
`MR. GIUNTA: Objection.
`
`Form and scope.
`
`THE WITNESS: Does not appear to be.
`
`BY MR. SEREBOFF:
`
`Q
`
`And as you scan down the list, do you see that a
`
`lot of this is not in chronological order?
`
`MR. GIUNTA: Objection.
`
`Form and scope.
`
`THE WITNESS:
`
`I think that's fair.
`
`BY MR. SEREBOFF:
`
`Q
`
`Why do you think these entries are not in
`
`chronological order?
`
`
`
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`WILLIAM W. CHUANG - CONFIDENTIAL
`
`MR. GIUNTA: Objection.
`
`Form and scope.
`
`Counsel, he didn't testify about this exhibit; so I don't
`
`know why he's being asked about this exhibit.
`
`MR. SEREBOFF:
`
`I'll get there.
`
`THE WITNESS:
`
`I don't know.
`
`BY MR. SEREBOFF:
`
`Q
`
`Okay.
`
`So in your declaration, you testified as
`
`to your knowledge of communications between RPX and
`
`Salesforce;
`
`is that correct?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS:
`
`I testified —- well,
`
`I would not
`
`say that I testified as to all of the discussions between
`
`RPX and Salesforce.
`
`BY MR. SEREBOFF:
`
`Q
`
`And in your declarations, what communications
`
`between RPX and Salesforce did you describe?
`
`MR. GIUNTA: Objection.
`
`Form.
`
`THE WITNESS:
`
`I described the communications that
`
`I was aware of and that I had personal knowledge of and
`
`some of which I was close enough to understand what was
`
`discussed.
`
`But a lot of —-
`
`there are a lot of other
`
`discussions, particularly relating to the use of
`
`Salesforce
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