`
`FOR THE DISTRICT OF DELAWARE
`
`M2M SOLUTIONS LLC,
`
`Civil Action No. 12-30-RGA
`
`Plaintiff,
`
`v.
`
`SIERRA WIRELESS AMERICA, INC.,
`and SIERRA WIRELESS, INC.,
`
`Defendants.
`
`M2M SOLUTIONS LLC,
`
`Civil Action No. 12-32-RGA
`
`Plaintiff,
`
`v.
`
`ENFORA, INC., NOVATEL WIRELESS
`SOLUTIONS, INC., and NOVATEL
`WIRELESS, INC.,
`
`Defendants.
`
`VOLUME I of II
`
`VIDEOTAPED DEPOSITION OF KEVIN J. NEGUS, Ph.D.
`
`Taken at:
`
`Comfort Inn
`
`75 Baxter Lane
`
`Butte, Montana
`
`May 21,2015
`
`9:10 a.m.
`
`1
`
`M2M
`
`EX. 2016
`
`1
`
`M2M
`Ex. 2016
`
`
`
`KEVIN NEGUS, Ph.D.
`
`M2M SOLUTIONS vs. SIERRA
`
`May 21, 2015
`
`(A brief record was taken.)
`
`VIDEOGRAPHER: This is Tape 8 of the
`
`videotaped deposition of Kevin Negus.
`
`The time is 5:38 p.m. We're on the record.
`
`BY MR. HENSCHKE:
`
`Q.
`
`In May of 2000, would a person of ordinary
`
`skill have been familiar with the infrared data
`
`association, IrDA specification, that cover serial
`
`infrared optical communication links?
`
`A.
`
`I would certainly include it.
`
`I knew it very
`
`well.
`
`I was involved with it. And it was actually
`
`written at my division at Hewlett Packard.
`
`Q. And a person of ordinary skill would have
`
`understood that the data transmissions that are made over
`
`a serial infrared link did not involve any packet
`
`switching, correct?
`
`A. No, I don't believe that would be their
`
`understanding. There was nothing in IrDA that would
`
`preclude packet-switched messages from traversing over the
`
`link. I've certainly used IrDA back at that time frame to
`
`pass information that would include packet-switched
`
`messages.
`
`Q. But there was --‘ there would have been no
`
`packet switching occurring over the infrared link,
`
`correct?
`
`NORDHAGEN COURT REPORTING
`
`406-494-2083
`
`2
`
`Page 256
`
`QA@MTQA.NET
`
`M2M
`
`Ex. 2016
`
`2
`
`M2M
`Ex. 2016
`
`
`
`KEVIN NEGUS, Ph.D.
`
`M2M SOLUTIONS vs. SIERRA
`
`May 21, 2015
`
`A.
`
`Packet switching doesn't occur over any link
`
`in any media. That's not what packet switching is.
`
`Packet switching is a reference to routing. Routing
`
`occurs at routers, not over a link. So routing, routing
`
`has nothing to do with the link.
`
`Perhaps you don't understand the difference between
`
`Layer 2 and Layer 3 and the protocol. Packet switching is
`
`a reference to Layer 3 and to routing; a link is a
`
`reference to Layer 2, so which Layer 2 is the link layer.
`
`And so IrDA, you're taxing my memory a little, but I
`
`believe IrDA like, for example, 802.11, Wi-Fi, everybody
`
`knows Wi-Fi is wireless.
`
`Everybody knows Wi-Fi with their router and being
`
`packet switched, but Wi-Fi, like IrDA, is just a Layer 2
`
`and Layer 1 protocol. There is no Layer 3 described in
`
`any of the IEEE standards that we call "Wi-Fi," or in
`
`IrDA. So just as you can do packet-switch stuff over
`
`Wi-Fi, you can equally do it over IrDA, or GSM, or IS-54,
`
`or CDPD, or any number of link-layer standards.
`
`Q. Do the GPRS standards that you cite in your
`
`expert report, those would be the GSM 03.60 and the GSM
`
`07.60, do those, in your opinion, teach a mobile equipment
`
`device that has the capability to process the data content
`
`of a GPRS data message?
`
`MS. BRANN: Objection; form.
`
`NORDI-IAGEN COURT REPORTING
`
`406-494-2083
`
`3
`
`Page 257
`
`QA@MTQA.NET
`
`M2M
`
`Ex. 2016
`
`3
`
`M2M
`Ex. 2016
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
