1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` ____________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
` SIERRA WIRELESS AMERICA, INC., SIERRA WIRELESS, INC.
`
` AND RPX
`
` Petitioners
`
` V.
`
` M2M SOLUTIONS LLC
`
` Patent Owner
`
`
`
` Inter Partes Review No. IPR2015-01823
`
`
`
` DEPOSITION OF JOEL R. WILLIAMS
`
` PALO ALTO, CALIFORNIA
`
` TUESDAY, JULY 26, 2016
`
` 8:58 A.M.
`
`Job No. 117278
`
`Pages 1 - 145
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`Reported by: Anne M. Torreano, CSR, RPR, CCRR, CLR
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`Sierra Wireless EX 1022 p 1
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`
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ____________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
` SIERRA WIRELESS AMERICA, INC., SIERRA WIRELESS, INC.
`
` AND RPX
`
` Petitioners
`
` V.
`
` M2M SOLUTIONS LLC
`
` Patent Owner
`
`
`
` Inter Partes Review No. IPR2015-01823
`
`
`
` DEPOSITION OF JOEL R. WILLIAMS
`
` PALO ALTO, CALIFORNIA
`
` TUESDAY, JULY 26, 2016
`
` 8:58 A.M.
`
`Job No. 117278
`
`Pages 1 - 145
`
`Reported by: Anne M. Torreano, CSR, RPR, CCRR, CLR
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`Sierra Wireless EX 1022 p 1
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`
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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` Deposition of JOEL R. WILLIAMS, held at
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`the offices of:
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`2
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` FOLEY & LARDNER LLP
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` 975 Page Mill Road
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` Palo Alto, California 94304
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` 650.856.3700
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`
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` Pursuant to Notice, before Anne M. Torreano,
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`California Certified Shorthand Reporter #10520,
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`Registered Professional Reporter, California Certified
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`Realtime Reporter, Certified LiveNote Reporter.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Sierra Wireless EX 1022 p 2
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`
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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`3
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` A P P E A R A N C E S
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`FOR THE PETITIONERS:
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` NIXON PEABODY LLP
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` BY: JENNIFER HAYES
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` 2 PALO ALTO SQUARE
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` 3000 EL CAMINO REAL, SUITE 500
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` PALO ALTO, CALIFORNIA 94306
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` 650.320.7725
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` jenhayes@nixonpeabody.com
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`FOR THE PATENT OWNER:
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` FOLEY & LARDNER LLP
`
` BY: MARC N. HENSCHKE
`
` 111 HUNTINGTON AVENUE
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` BOSTON, MASSACHUSSETTS 02199
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` 617.342.4000
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` mhenschke@foley.com
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`Sierra Wireless EX 1022 p 3
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`
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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`4
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` EXAMINATION INDEX
`
`JOEL R. WILLIAMS PAGE
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` BY MS. HAYES 6
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` BY MR. HENSCHKE 120
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` FURTHER BY MS. HAYES 141
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` EXHIBIT INDEX
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` DEPOSITION PAGE
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` EXHIBIT 1 Petitioners' Amended Notice of 6
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` Deposition of Joel R. Williams
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` EXHIBIT 2 Petition for Inter Partes Review 62
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` EXHIBIT 3 Decision, Institution of Inter 78
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` Partes Review
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` EXHIBIT 4 ETSI TS 123 060 V3.3.0 Technical 90
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` Specification
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` EXHIBIT 5 Excerpts: "Mobile Handset Design" 96
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` by Sajal Kumar Das
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` EXHIBITS PREVIOUSLY MARKED
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` M2M
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` EXHIBIT 2011 Expert Declaration of Joel R. 12
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` Williams
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` EXHIBIT 2012 International Standard 7816-3 56
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` SIERRA WIRELESS
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` EXHIBIT 1001 International Publication Number 108
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` WO 99/49680
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` EXHIBIT 1004 ETSI TS 100 977 V7.4.0 Technical 56
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` Specification
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`Sierra Wireless EX 1022 p 4
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`
`
`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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` TUESDAY, JULY 26, 2016; 8:58 A.M.
`
` JOEL R. WILLIAMS,
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` having been duly sworn to tell the truth,
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`5
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`testified as follows:
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` EXAMINATION
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`BY MS. HAYES:
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` Q. Good morning, Mr. Williams. Thank you for
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`coming in today. Can you please state your full name
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`for the record?
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` A. Yeah, Joel Robert Williams.
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` Q. And where do you live, Mr. Williams?
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` A. I live in San Jose.
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` Q. Can you give a precise address in San Jose?
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` A. It's 1240 McKendrie Street, San Jose,
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`California.
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` Q. Okay. I'm going to hand you -- or the court
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`reporter will hand you the first exhibit.
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` (DEPOSITION EXHIBIT 1 MARKED.)
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`BY MS. HAYES:
`
` Q. So the court reporter has handed you
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`Deposition Exhibit 1, which is Petitioners' Amended
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`Notice of Deposition of Joel R. Williams.
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` Have you seen this document before?
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` A. I have.
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` Q. Okay. Have you testified at trial before?
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`Sierra Wireless EX 1022 p 5
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`
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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` A. I have.
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` Q. And how many times?
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` A. Three.
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` Q. And were those all patent cases?
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` A. Yes.
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` Q. And have you been deposed before?
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` A. I have.
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` Q. Approximately how many times have you been
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`deposed?
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` A. Probably ten or twelve.
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` Q. And of those approximately ten or twelve
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`depositions, how many of them related to patent cases?
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` A. Most of them. Probably -- maybe all. I don't
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`remember.
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` Q. And --
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` A. Actually, not all of them but most of them.
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` Q. And how many of those related to validity of a
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`patent?
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` A. I don't recall off the top of my head.
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` Q. Can you provide an estimate?
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` A. Just off -- just rough would be somewhere
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`around half.
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` Q. Okay. You understand today that you're under
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`oath?
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` A. I do.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Sierra Wireless EX 1022 p 6
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`
`
`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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`7
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` Q. And I'll be asking you a series of questions
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`today. The court reporter will be transcribing our
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`conversation, as you know. In order for her to create
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`an accurate record, there should be a clear
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`back-and-forth. So please give verbal answers, and
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`also please wait until I finish my question before
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`answering, and likewise, I'll wait until you finish
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`your answer before asking my next question.
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` Is that okay?
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` A. That's okay.
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` Q. If you don't hear or understand me, please let
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`me know. If you answer, I will assume you heard and
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`understood the question.
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` Is that fair?
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` A. Yes.
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` Q. Counsel may object. After the objection you
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`can answer, unless counsel instructs you not to answer.
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` Is there any reason why you can't give full,
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`accurate and truthful testimony today?
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` A. No.
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` Q. When were you first retained to -- for this
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`case?
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` A. It was in this March or April of this year.
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` Q. And was that the first time you had heard of
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`the case?
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`Sierra Wireless EX 1022 p 7
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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` A. Well, I discussed the case before I was
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`engaged, so I'm not sure --
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` Q. Approximately how much time before you were
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`engaged did you --
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` A. It was probably a week, maybe two weeks. I
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`don't recall.
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` Q. And were you retained to prepare a declaration
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`in this case?
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` A. I was engaged to review the case and give my
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`opinion and later asked to prepare a report. I don't
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`remember exactly when the discussion of our first
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`report came in.
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` Q. And when you say you were engaged to review
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`the case, what did you do to review the case?
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` A. Well, certainly I read the patents and -- read
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`the patent I mean, and did some of my own I'd call
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`homework of refreshing my memory on some of the
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`standards and what they were talking about in the
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`patent. And then after I was engaged, I was given the
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`information on the -- on the -- I guess the petitions,
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`was given the petition and the appendices that went
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`with the petition.
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` Q. So you were provided with a copy of the
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`exhibits to the petition?
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` A. Yes.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Sierra Wireless EX 1022 p 8
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`
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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` Q. And were you provided with a copy of the
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`patent office board's institution decision?
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` A. Yes. The grant decision? Is that what you
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`call the grant? I'm not sure. Yeah.
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` Q. What did you do to prepare for your deposition
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`today?
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` A. I reviewed the report, I reviewed the material
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`at issue in my report, and I met with the attorney
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`for -- for the patent.
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` Q. And when you said you met with an attorney for
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`the patent, are you referring to Mr. Henschke?
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` A. Yes, I am.
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` Q. And how long did you meet with Mr. Henschke?
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` A. I met with him on Sunday for a few hours and
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`yesterday for a few hours.
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` Q. Did you review documents with Mr. Henschke to
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`prepare for your deposition?
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` A. We reviewed -- yes, we reviewed my report and
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`reviewed some of the references cited in my report.
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` Q. Which references did you review with
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`Mr. Henschke?
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` A. I don't recall all of them, but the primary
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`reference would be the SIM spec and the SAT spec, the
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`patent, the -- is that me? Let me turn it off. Forgot
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`I had it.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Sierra Wireless EX 1022 p 9
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`
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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` Sorry about that.
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` Q. That's okay.
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` A. Okay.
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` Q. Did you review any other documents on your own
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`apart from the ones you reviewed with Mr. Henschke?
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` A. In preparation for this?
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` Q. Correct.
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` A. I don't recall. I may have reviewed some of
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`the other documents that are cited in my report.
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` Q. Did you review the deposition transcript of
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`Dr. Negus in preparation for your deposition today?
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` A. I did look at it. I did not read every word
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`of it.
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` Q. What specifically did you look at in that
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`transcript?
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` A. I think it was the part where he was talking
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`about -- I'm not even sure I remember which parts I
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`looked at. As I sit here, I don't recall which parts I
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`looked at.
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` Q. What was the purpose of looking at Dr. Negus's
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`deposition transcript?
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` A. To understand his position.
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` Q. And what specifically were you trying to
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`understand about his position?
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` A. This business of sending a packet over -- a
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Sierra Wireless EX 1022 p 10
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`
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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`SMS-PP packet over GPRS.
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` Q. And do you agree with Dr. Negus's opinion?
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` A. No.
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` Q. And why not?
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` A. Well, we've got to go through what's in my
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`report, and I think it's in my report.
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` Q. And so your report outlines the different
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`areas in which you disagree with Dr. Negus?
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` A. Well, no. I did -- like I said, I did not go
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`through everything in his deposition, so I'm not
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`sure -- I'm not prepared to talk about everything in
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`his deposition and take a position opposite everything
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`in his deposition. I'm prepared to talk about the
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`positions in my report, and the report talks about
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`particular ones of his particular positions he's taken.
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` So we can go through what's in the report.
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` Q. So specifically with respect to sending an SMS
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`over a GPRS network, do you disagree with Dr. Negus's
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`opinion?
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` A. Let's go through my report --
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` Q. Okay.
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` A. -- and the details. It's a broad question.
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` Q. The court reporter has handed you Exhibit 2011
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`to the IPR proceedings.
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` Have you seen this document before?
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`Sierra Wireless EX 1022 p 11
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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` A. Yeah, it appears to be a copy of my report.
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` Q. And the report is referred to as the expert
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`declaration of Joel R. Williams; is that correct?
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` A. That is correct.
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` Q. And when did you prepare this declaration?
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` A. So May 25th, 2016.
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` Q. When did you first begin preparing your expert
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`declaration?
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` A. I don't recall when I started exactly.
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` Q. Approximately how much time did you spend
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`preparing your declaration?
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` A. I haven't divided up the time I spent
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`declaring the declaration, the actual document from the
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`time I've spent on the case. I didn't divide things up
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`that way.
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` Q. How much time have you spent on the case?
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` A. The time -- well, the time spent specifically
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`on the case until this report -- until this was -- are
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`you asking about from the time of today or from the
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`time that this was prepared and submitted?
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` Q. The time from when you were first retained
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`until the time that the expert declaration was
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`finalized.
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` A. It would be somewhere 80 to 100 hours, that
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`time frame. I don't have an accurate number.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Sierra Wireless EX 1022 p 12
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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` Q. And during that 80-to-100-hour time period,
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`you reviewed the '717 patent, the IPR petition, the
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`Board's institution decision, the various documents
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`cited and your expert declaration, and prepared your
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`declaration?
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` A. I don't understand that question. Did I
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`review my declaration?
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` Q. Did you review the documents cited in your
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`declaration, the '717 patent, the IPR petition and
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`prepare your expert declaration during that time
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`period?
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` A. Yes.
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` Q. Did you review any documents related to the
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`litigation pending in the Delaware District Court
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`during that time period?
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` A. I don't -- I may have seen a court
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`construction. Don't recall exactly where that was
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`from.
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` Q. Did you review the preliminary infringement
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`contentions M2M served to Sierra Wireless?
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` A. I did see some contentions. I don't know
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`where they were from.
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` Q. Did those contentions influence your opinions
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`in this case?
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` A. I would say they were a starting point or an
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Sierra Wireless EX 1022 p 13
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`
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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`14
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`input to my analysis. I wouldn't -- I would say -- I
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`wouldn't use the word "influence." They were an input.
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` MR. HENSCHKE: I should state for the record
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`at this point so there's no confusion about what
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`contentions we're referring to that Mr. Williams has
`
`never been provided or seen the infringement
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`contentions in the '717 patent litigation.
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`BY MS. HAYES:
`
` Q. Are you familiar with the name Dr. Nettleton?
`
` A. I am familiar with the name Dr. Nettleton.
`
` Q. Have you reviewed any materials that
`
`Dr. Nettleton has prepared?
`
` A. I believe I got an excerpt of something that
`
`he wrote. And I do know Dr. Nettleton.
`
` Q. How do you know Dr. Nettleton?
`
` A. I worked with him on another case unrelated to
`
`this. Cellular stuff.
`
` Q. Are you familiar with Mr. Konchitsky?
`
` A. No.
`
` Q. No?
`
` A. I'm sorry. Who?
`
` Q. Alon Konchitsky.
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` A. I know who he is.
`
` Q. Did you review any materials that
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`Mr. Konchitsky has prepared in relation to this case?
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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` A. I have not.
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` Q. If you turn to page 3 of your declaration --
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` A. That's interesting. There's now two pages in
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`15
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`here. When you say "page 3," is it the --
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` Q. The upper number.
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` A. The upper number? This one?
`
` Q. Correct. There's a section called "Materials
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`Relied Upon"?
`
` A. Yes.
`
` Q. And it starts at paragraph 12 and it continues
`
`to paragraph 13. Do you see that?
`
` A. I do.
`
` Q. And are these the materials that you reviewed
`
`in preparation of your expert declaration?
`
` A. Yes.
`
` Q. And in paragraph 13 you refer to other
`
`materials to confirm your understanding.
`
` Do you see that?
`
` A. I do see that.
`
` Q. And how did you use these materials cited in
`
`paragraph 13 to confirm your understanding?
`
` A. Generally I would say they were background
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`information or -- to help confirm my -- what I was
`
`looking at and specs and other material.
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` Q. And why did you look at these materials?
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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` A. Some of them because I had them on my
`
`bookshelf and they were readily available. Some of
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`them -- it just was -- just helpful to me.
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` Q. In what way were they helpful to you?
`
` A. As I said, they confirmed my understanding of
`
`what I was -- of the technology I was looking at and
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`the issues.
`
` Q. And if you turn to page 1 of your declaration,
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`there's a section called "Qualifications."
`
` See that?
`
` A. I do see that.
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` Q. And here you provide a summary of certain
`
`background that you think pertains to your
`
`qualifications for providing expert testimony in this
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`matter; is that correct?
`
` A. That is correct.
`
` Q. And you describe some past consulting
`
`assignments. Do you see that at paragraph 9?
`
` A. I see that.
`
` Q. And you include there T-Mobile.
`
` Do you see that?
`
` A. I do.
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` Q. What specifically did you do for T-Mobile?
`
` A. I did two major things that had to do with
`
`integration of Wi-Fi and cellular so that you could,
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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`for example, make a telephone call on one cellular and
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`then move into an area where there was Wi-Fi, and the
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`phone would just transfer over and use your Wi-Fi
`
`instead of the cellular network. And that handoff or
`
`moving back and forth was a new technology that I
`
`worked on.
`
` And I should further add, in paragraph 10
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`where I talk about industry standards, I realize I left
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`one off there that I should talk about in connection
`
`with my T-Mobile thing. There was a consortium or
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`group of companies, including T-Mobile, called
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`Unlicensed Mobile Alliance, UMA for short. And they
`
`were setting the cellular standards for this
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`technology, this Wi-Fi integration stuff that I was
`
`talking about, and I was involved with that group
`
`through my work with T-Mobile.
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` And the other -- so that was part of what I
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`did with T-Mobile. And the other part I did with
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`T-Mobile is work with handset vendors that were making
`
`the -- and also the people making the equipment in the
`
`network to -- that were designing this capability and
`
`worked with them on the designs of how they were going
`
`to do it and how the network was going to work. It
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`went beyond what was in the specifications.
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` And the third thing I did with them and
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
`
`18
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`related to that was I did specify testing, a test plan
`
`basically, a testing criteria, acceptance testing, and
`
`I developed a test lab at T-Mobile up near Seattle --
`
` Q. And --
`
` A. -- for doing that testing. And I worked with
`
`the vendors and the -- the different vendors in getting
`
`that stuff to work.
`
` Q. So the testing related to whether devices
`
`complied with the handoff standards that this
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`consortium had designed?
`
` A. Yes. Well, that was the main thrust. And
`
`that, of course, bled over to a lot of other areas of
`
`cellular, GSM and cellular technology.
`
` Q. Which other areas are those?
`
` A. Well, the one that we'll probably get to in
`
`here was relating to the SIM card. One of the problems
`
`with that or one of the challenges in that technology
`
`is maintaining the security when you go into a Wi-Fi
`
`network that's unsecured from a cellular network that
`
`is secure. And there are a lot of issues in how to
`
`handle the details of the technology, and my
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`involvement with the SIM was, you know, what security
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`was provided and how to handle that in the Wi-Fi world.
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`And that's probably the first time I worked with a SIM
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`application or was involved with.
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
`
` Q. And the security on the SIM card that you were
`
`working with related to the authentication of the
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`19
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`devices on the network?
`
` A. Yes. Loosely, yes.
`
` Q. What do you mean by "loosely"?
`
` A. Well, again, it was going from the network to
`
`Wi-Fi -- from the cellular network to the Wi-Fi
`
`network, so it was the -- it was how to keep
`
`basically -- how can I summarize this? How to keep the
`
`cellular world happy when you switch over to Wi-Fi. So
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`how to maintain compatibility.
`
` Q. And the network at T-Mobile that you were
`
`working with, that was the GSM?
`
` A. It included the GSM network, yes.
`
` Q. Did it include the GPRS network?
`
` A. I believe they supported GPRS. My involvement
`
`with it did not include GPRS.
`
` Q. During your work experience and consulting
`
`experience, have you had any other experience with GSM?
`
` A. In what sense?
`
` Q. Either consulting or working on products or
`
`network issues related to GSM.
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` A. Well, yeah. I mean, I have used products that
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`had cellular modems in them that were GSM capable.
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` Q. And which products are those?
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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`20
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` A. I don't think they're listed in here, but let
`
`me think off the top of my head. I worked with a
`
`company called Natis that does wireless monitoring of
`
`power equipment, what we would today call the E-GRID or
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`IoT stuff for power control.
`
` I have to go back and think. There's other
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`projects I work with cellular modems.
`
` Q. And what time period were you working with
`
`Natis?
`
` A. That would have been after this -- the
`
`priority date. It would be in the 2008 time frame
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`probably. I don't recall exactly. There's other
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`projects I don't recall off the top of my head I've
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`used over the years.
`
` Q. And you don't recall those sitting here today?
`
` A. No.
`
` Q. In your experience, have you done any work
`
`related to the delivery of SMS messages over a GPRS
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`network?
`
` A. No.
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` Q. Do you have any experience with the design of
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`mobile handsets?
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` A. Yes.
`
` Q. In what sense?
`
` A. Again, going back to my T-Mobile experience, I
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
`
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`worked with Motorola, with Samsung and with Nokia on
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`the design of their handsets. I had design reviews
`
`with them of how they work, what they were doing, and
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`I've visited their sites, their labs.
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` Q. And the work you did with Motorola, Samsung
`
`and Nokia, did that relate to the integration of Wi-Fi
`
`and cellular and the handoff issues we talked about
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`earlier?
`
` A. Yes.
`
` Q. Do you have any experience with the design of
`
`programmable communicators?
`
` A. Can you be specific by what you mean by
`
`"programmable communicator"?
`
` Q. What is your understanding of a programmable
`
`communicator?
`
` A. Are you asking me in the context of the '717
`
`patent or just in general industry?
`
` Q. I'm asking as a person of skill in the art,
`
`what is your understanding of a programmable
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`communicator?
`
` A. It's not a typical term of art, typical term.
`
`It is a term that's used in the patent. It's clear
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`what they mean, though.
`
` Q. And what do they mean?
`
` A. I would characterize it as an embedded device,
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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`22
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`and today we would the call it a -- IoT device is a
`
`popular name for it. It's an embedded device with a
`
`cellular capability in it. And the example of the
`
`Natis system that I worked with would be very much like
`
`the devices at issues in this patent.
`
` Q. Did you have any involvement with the GSM
`
`standards?
`
` A. In what sense?
`
` Q. Did you participate in any meetings related to
`
`the GSM standards?
`
` A. The UMA group that I worked with, as I
`
`mentioned before, was adopted and folded into the GSM
`
`standard. It's now called -- part of something called
`
`GAN. It's a generic access network. I did not attend
`
`the specific meetings of the GSM standards organization
`
`where that happened. I attended the meetings of the
`
`UMA group that contributed those.
`
` And I should be clear that those standards,
`
`those written -- well, they weren't written by a group
`
`of the GSM standards committee. They were written very
`
`much by the same people involved and was written to the
`
`same level of -- same style and requirements so that
`
`they could just be basically adopted in whole and
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`folded in, which is what happened.
`
` Q. What is the purpose of a standards document?
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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` A. Of a standard? Sorry.
`
` Q. So, for example, the UMA, what is the purpose
`
`of the documents that they prepared?
`
` A. Well, the purpose of standards is to set a set
`
`of rules by which products from different companies can
`
`interoperate. That's the high-level, ten thousand-foot
`
`view. It sets a framework so that everybody can design
`
`to the same rules and have some hope that they might
`
`work together.
`
` Q. And those rules provide a standard set of
`
`rules?
`
` A. Yeah, that's the standard. Right. I used the
`
`word "rules" loosely.
`
` Q. And so it describes the standard features that
`
`the devices need to have to interoperate with one
`
`another?
`
` A. It may.
`
` Q. What do you mean?
`
` MR. HENSCHKE: Ms. Hayes, I'm going to
`
`certainly allow you some leeway to ask Mr. Williams
`
`about his background and experience, but I would
`
`caution you about starting to get into areas where
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`you're trying to elicit opinions from him on topics
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`that aren't part of his declaration here in this
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`matter.
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
`
` THE WITNESS: So would you repeat the
`
`24
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`question?
`
`BY MS. HAYES:
`
` Q. The standards documents describe the standard
`
`features that the devices need to have to interoperate
`
`with one another?
`
` MR. HENSCHKE: Asked and answered.
`
` THE WITNESS: Yeah, the answer is maybe.
`
`BY MS. HAYES:
`
` Q. And what do you mean by "maybe"?
`
` A. They don't -- standards have a lot of parts to
`
`them. They're not all required. There are some that
`
`are optional, and so that's why I say "maybe."
`
` Q. Is the programmable communicator described in
`
`the '717 patent a mobile station?
`
` A. Could I see the '717 patent, please?
`
` MR. HENSCHKE: While we have a moment here,
`
`I'm going to object to that question as being outside
`
`the scope of anything that Mr. Williams has opined upon
`
`in his declaration and also because it's unclear what
`
`is meant by the term "mobile station."
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` THE WITNESS: I was looking for where the
`
`patent says "mobile station," and maybe you could point
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`me to it.
`
`BY MS. HAYES:
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
`
`25
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` Q. Well, I'm asking is your understanding that
`
`the programmable communicator described in the '717
`
`patent is a mobile station?
`
` MR. HENSCHKE: Same objection.
`
` THE WITNESS: You know, I think I'm going to
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`go with the -- I'm going stick to what's in my report.
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`If you can show me in my report where I talk about
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`that, I'd be happy to respond.
`
`BY MS. HAYES:
`
` Q. You have no opinion as to whether the
`
`programmable communicator is a mobile station?
`
` MR. HENSCHKE: Same objection.
`
` THE WITNESS: I'm not -- I'm not rendering an
`
`opinion.
`
`BY MS. HAYES:
`
` Q. Is the programmable communicator described in
`
`the '717 patent a wireless subscriber terminal system?
`
` MR. HENSCHKE: Objection as calling for
`
`opinions outside the scope of Mr. Williams' declaration
`
`in this matter and also because of its lack of clarity
`
`in terms of the terminology being used.
`
` THE WITNESS: Same answer.
`
`BY MS. HAYES:
`
` Q. So you have no opinion?
`
` A. I'm not providing an opinion at this time.
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`Deposition of Joel R. Williams
`Conducted on July 26, 2016
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`26
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` Q. Do you understand what a wireless subscriber
`
`terminal system is?
`
` A. I don't know the context that you're using
`
`that in.
`
` Q. You've never heard of that phrase before?
`
` A. Wireless -- what is it again?
`
` Q. Wireless subscriber terminal system.
`
` A. In any particular context? Any particular
`
`patent or just in the term of art?
`
` Q. A term of art.
`
` A. It's not a common term of art. It's pretty
`
`obvious that it has to do with wireless and it's a
`
`terminal, but beyond that, it's not something that's a
`
`familiar term.
`
` Q. And what is a terminal?
`
` A. It's an end device on the cellular network.
`
`Or a terminal is anything in the context of a cellular
`
`terminal. It's something that you can connect to or --
`
`it's an end node in a network.
`
` Q. Do you have an electrical engineering degree?
`
` A. I have an associate's degree in electrical
`
`engineering and a bachelor's degree in computer
`
`science.
`
` Q. So you do not have a bachelor's degree in
`
`electrical engineering?
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`Sierra Wireless EX 1022 p 26
`
`
`
`Deposition of Joel R. Williams
`Conducted on July 26, 2016
`
`27
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` A. No.
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` Q. Do you have work experience designing wireless
`
`subscriber systems?
`
` A. I have design experience in desi
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