UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`LG ELECTRONICS, INC. §
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` Petitioner § Case IPR2015-01984
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`VS. § Patent 8,434,020 B2
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`CORE WIRELESS LICENSING §
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`S.A.R.L. § Case IPR2015-01985
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` Patent Owner § Patent 8,713,476 B2
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` Deposition of
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` V. THOMAS RHYNE, Ph.D.
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` Austin, Texas
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` Tuesday, October 25, 2016
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` 9:00 a.m.
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` Job No.: 125671
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` Pages: 1 - 115
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` Reported by: Micheal A. Johnson, RDR, CRR
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`IPR2015-01984 & IPR2015-01985
`Ex. 2011
`Page 1 of 121
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`1
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`LG ELECTRONICS, INC. §
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` Petitioner § Case IPR2015-01984
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`VS. § Patent 8,434,020 B2
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`CORE WIRELESS LICENSING §
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`S.A.R.L. § Case IPR2015-01985
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` Patent Owner § Patent 8,713,476 B2
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` Deposition of
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` V. THOMAS RHYNE, Ph.D.
`
` Austin, Texas
`
` Tuesday, October 25, 2016
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` 9:00 a.m.
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` Job No.: 125671
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` Pages: 1 - 115
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` Reported by: Micheal A. Johnson, RDR, CRR
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`IPR2015-01984 & IPR2015-01985
`Ex. 2011
`Page 1 of 121
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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` Deposition of V. THOMAS RHYNE, Ph.D., held
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` at the location of:
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`2
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` Greenberg Traurig, LLP
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` 300 West 6th Street, Suite 2050
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` Austin, Texas 78701
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` (512) 320-7200
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` Pursuant to Notice, before Micheal A.
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` Johnson, Registered Diplomate Reporter and Certified
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` Realtime Reporter.
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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` A P P E A R A N C E S
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` ON BEHALF OF PETITIONER:
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` Nicholas A. Brown
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` GREENBERG TRAURIG, LLP
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` 4 Embarcadero Center, Suite 3000
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` San Francisco, California 94111-5983
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` (415) 655-1300
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` brownn@gtlaw.com
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` Herbert H. Finn
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` GREENBERG TRAURIG, LLP
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` 77 West Wacker Drive, Suite 3100
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` Chicago, Illinois 60601
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` (312) 456-8400
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` finnh@gtlaw.com
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` ON BEHALF OF PATENT OWNER:
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` Wayne Helge
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` DAVIDSON BERQUIST JACKSON & GOWDEY, LLP
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` 8300 Greensboro Drive, Suite 500
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` McLean, Virginia 22102
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` (571) 765-7708
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` whelge@dbjg.com
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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`4
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` INDEX
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` V. THOMAS RHYNE, Ph.D.
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` October 25, 2016
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`APPEARANCES 3
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`PROCEEDINGS 6
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` EXAMINATION OF V. THOMAS RHYNE, Ph.D.:
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` BY MR. HELGE 6
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`REPORTER'S CERTIFICATION 114
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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`5
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` DEPOSITION EXHIBITS
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` V. THOMAS RHYNE, Ph.D.
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` October 25, 2016
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`NUMBER DESCRIPTION MARKED
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`Exhibit A Random House Webster's 55
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` Computer & Internet
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` Dictionary - Third Edition
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` PREVIOUSLY MARKED EXHIBITS
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`NUMBER DESCRIPTION PAGE
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`Exhibit 1001 ......................... 25
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`Exhibit 1002 ......................... 35
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`Exhibit 1010 ......................... 11
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`Exhibit 1011 ......................... 12
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`Exhibit 1012 ......................... 14
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`Exhibit 1013 ......................... 15
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`Exhibit 1014 ......................... 16
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`Exhibit 1015 ......................... 7
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`Exhibit 2007 ......................... 92
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`Exhibit 2009 ......................... 60
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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` PROCEEDINGS
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` V. THOMAS RHYNE, Ph.D.,
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` having been first duly sworn,
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` testified as follows:
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` EXAMINATION
`
` BY MR. HELGE:
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` Q. Morning, Dr. Rhyne.
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` A. Good morning.
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` MR. HELGE: Nick, just for a quick
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` housekeeping matter, I believe you had filed your
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` reply and reply evidence on September 30th. And we
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` had filed objections to that reply of evidence on
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` October 7th, which is within the five business days.
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` By my calculation, ten business days from those
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` objections was last Friday and I did not receive any
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` supplemental evidence from you on that date; is that
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` correct?
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` MR. BROWN: I believe that's correct.
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` MR. HELGE: Okay.
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` MR. BROWN: Well, not as to all the dates.
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` As to -- those I don't remember, but as to not
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` serving supplemental evidence, that is correct.
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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` MR. HELGE: Okay. Thank you. And then just
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` for confirmation as we've done before, we've got
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` Dr. Rhyne here for two cases and my understanding is
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` that we'll be filing the same transcript in both
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`7
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` cases; is that correct?
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` MR. BROWN: Yes.
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` MR. HELGE: And if you can't hear me, please
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` just let me know.
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` BY MR. HELGE:
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` Q. Dr. Rhyne, I'm going to hand you two
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` documents identified as Exhibit 1015. And you can
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` see on the bottom, one is marked in the case
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` IPR2015-1984. Do you see that, Dr. Rhyne?
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` A. I haven't found that yet, but I'll find it
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` eventually.
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` Q. Very bottom line on both pages there.
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` A. Okay. Way down here. Okay. Yeah.
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` Q. Now, I printed this version out in -- you
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` know, two sheets per page.
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` A. That's fine.
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` Q. And I also have a copy of Exhibit 1015 from
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` the 1985 case. And that's what this document is.
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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` A. Okay. So one of them is -- they both deal
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` with the '020?
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` Q. Well, so that's one of my questions for you.
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` Both of these documents show on the cover page that
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` they're dealing with patent number 8,434,020. But I
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` see in a variety of the paragraphs in here, you
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` refer to both the '020 patent and the '476 patent.
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` A. Right. I think in the initials of what's
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` called the application section, I made the point
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` that essentially my opinions are pretty much the
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` same for the -- for the two different patents.
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` There's some differences, particularly in some of
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` the dependent claims that -- depending on whether
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` they refer to a function or a data type, but
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` basically, that -- in relation to Blanchard,
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` et cetera, that they're pretty much the same
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` opinions.
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` MR. HELGE: Nick, is this correct that
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` there's only one copy of the declaration that
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` applies to both patents?
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` MR. BROWN: Yes.
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` MR. HELGE: Okay. Thank you.
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`PLANET DEPOS
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`Conducted on October 25, 2016
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` BY MR. HELGE:
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` Q. So, Dr. Rhyne, if you would prefer that we
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` use the larger font, we can do that or we can use
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` the smaller font, whichever you prefer.
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` A. I don't care. I mean, I guess I'm confused.
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` Are these two different documents or the same
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` document in different printing?
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` Q. Well, did you prepare two declarations or --
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` A. I don't think I did.
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` Q. Okay. So you prepared one declaration?
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` A. I thought so. I mean, it's been a while
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` since I did it, but obviously -- at least on the
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` bottom of the first page, which I didn't create,
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` okay, I mean, I did everything but this footer, one
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` of them is 1985 and one -- the other one is 1984,
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` but I think I only did one.
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` Q. Okay. Well, I think, then --
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` MR. HELGE: Nick, do you agree that we can
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` say for the record that this is the same document
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` that was filed in both cases?
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` MR. BROWN: Yes.
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`Conducted on October 25, 2016
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` BY MR. HELGE:
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` Q. Okay. So, Dr. Rhyne, if we talk about
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` either one of these, we're going to be talking about
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` your testimony that applies to both cases; is that
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` right?
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` A. All right. I gather that to be the case.
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` Q. Okay. Dr. Rhyne, if you were to take a look
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` at page 2, which you can see on that cover sheet of
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` the one you're looking at, paragraph 3, you mention,
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` "In preparing this rebuttal declaration, I have
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` considered the following materials" -- and then you
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` go on to list a variety of documents that you looked
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` at in preparing your declaration. Do you see that?
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` A. Yes.
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` Q. Did you review all of these documents again
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` in preparation for this deposition?
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` A. You mean like in the last day or two?
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` Q. Yes, sir.
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` A. I believe I did. Let me just run down the
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` list to be sure.
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` Q. Of course.
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` (Witness reviews document.)
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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` A. I did not review the patent owner's response
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` regarding the '476 patent in the last few days.
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` (Witness reviews document.)
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` A. I did not review the deposition of
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` Mr. Denning -- or Dr. Denning.
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` (Witness reviews document.)
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` A. Otherwise, I did review them all. And I'm
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` speaking only about the last few days. I have
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` reviewed them in the past.
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` BY MR. HELGE:
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` Q. Understood. Dr. Rhyne, I'm going to hand
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` you what's been marked as Exhibit 1010. Dr. Rhyne,
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` do you remember reviewing this reference?
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` A. Yes. I actually have it in color in a PDF,
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` but I do remember it.
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` Q. When did you first see this document?
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` A. I don't remember exactly. Somewhere during
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` the preparation of the rebuttal declaration.
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` Q. Okay. And how did you obtain this document?
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` A. It was provided to me by the attorneys
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` representing LG.
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` Q. Have you seen this document before the
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`Conducted on October 25, 2016
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` attorneys representing LG gave it to you?
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` A. I used to subscribe to Popular Science, so
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` maybe I had or maybe I hadn't. But I don't have any
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` clear recollection of seeing this particular one.
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` Q. So you don't remember reading this
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` particular issue of Popular Science back in 1999?
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` A. I do not.
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` Q. Dr. Rhyne, I'm going to hand you what's been
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` marked as Exhibit 1011. Dr. Rhyne, do you recognize
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` this document?
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` A. I do. It's one of the two user guides for
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` the Ericsson R380 smartphone that I have.
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` Q. When did you first see Exhibit 1011?
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` A. I probably saw it back when I was doing my
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` original declaration in this case. I remember that
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` there were two of them. So I think it's that far
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` back.
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` Q. So when you were preparing your original
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` declaration, was that in the year 2015?
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` A. I believe it was last year, yes, sir.
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` Q. Had you seen a copy of this document prior
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` to 2015?
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`Conducted on October 25, 2016
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` A. Before 2015?
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` Q. Yes, sir.
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` A. Like in 2014?
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` Q. Or earlier, yes.
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` A. I don't have any recollection of seeing it
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` that far back, no.
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` Q. And how did you acquire this document?
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` A. I think, again, it was provided to me; maybe
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` I was only provided the URL where it could be found
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` on the Internet. I don't remember precisely. But I
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` did not search it out. I think it was provided in
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` one way or another by the attorneys representing LG.
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` Q. Dr. Rhyne, is it your testimony that this
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` document is available on the Internet?
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` A. I don't have a clear recollection of whether
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` it is or not. I just noticed a URL here. I don't
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` know for sure.
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` Q. Okay. So you don't know if this copy of
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` Exhibit 1011 was downloaded from the Internet; is
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` that right?
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` A. I don't understand the difference between
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` the two questions. I don't know. It may be that
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`Conducted on October 25, 2016
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` this thing -- this document was available on the
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` Internet, but I don't know for sure where it
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` originally came into this case.
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` Q. And you don't know because this copy was
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` provided to you by counsel, correct?
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` A. The original -- the PDF for this user
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` guide -- I actually was provided two user guides and
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` both of them were provided to me by counsel.
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` Q. You can set that aside as well, Dr. Rhyne.
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` A. Okay.
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` Q. Dr. Rhyne, I'm going to hand you what's been
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` marked as LG Exhibit 1012. Dr. Rhyne, do you
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` recognize this document?
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` A. I do.
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` Q. And when did you first see this document?
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` A. I would think during the preparation of my
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` rebuttal declaration.
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` Q. And when you say that, you mean maybe
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` September of this year, of 2016?
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` A. Sometime in the last several months.
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` Q. Had you seen this document before you were
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` preparing your rebuttal declaration for this case?
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` A. I don't think so.
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` Q. And how did you get a copy of this document?
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` A. I know for a fact that this one is available
`
` on the Internet because, among other things, I
`
` looked for it yesterday using my own computer. So I
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` don't remember -- I think some -- it was just
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` provided to me as a PDF document by the attorneys
`
` representing LG as a way of proving up the dating on
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` the Ericsson R380 smartphone -- phone, let's just
`
` call it.
`
` Q. Okay, Dr. Rhyne, we can set this one aside
`
` as well. I'm going to hand you a copy now of what's
`
` been marked as LG Exhibit 1013. And, Dr. Rhyne, do
`
` you recognize this document?
`
` A. I do.
`
` Q. And when was the first time you saw this
`
` document?
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` A. During the pendency of my writing the
`
` rebuttal declaration.
`
` Q. And so the first time you saw this document
`
` was within the last three or four months; is that
`
` right?
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`Conducted on October 25, 2016
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` A. That's correct.
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` Q. Had you seen the document before then?
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` A. I have no recollection of seeing it before.
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` Q. And how did you obtain a copy of this
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` document?
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` A. It was provided to me as a PDF electronic
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` version by the attorneys representing LG.
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` Q. You can set that one aside as well.
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` Dr. Rhyne, I'm going to hand you also now what's
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` been marked as LG Exhibit 1014. And do you
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` recognize this document?
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` A. I do.
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` Q. When was the first time you saw this
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` document, Dr. Rhyne?
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` A. Do you mean the specific pages or the
`
` general document?
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` Q. Let's go with the specific pages first.
`
` When was the first time you saw the specific pages?
`
` A. I probably had looked at some of the
`
` definitions in other cases where issues such as
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` system software or something had come up. I don't
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` know for sure that I had looked up in the -- my
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`Conducted on October 25, 2016
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` personal copy of this dictionary all of the
`
` definitions that are represented on this subset of
`
` pages.
`
` Q. So, Dr. Rhyne, you said a moment ago that
`
` you have a personal copy of this dictionary; is that
`
` correct?
`
` A. Yes. I copied all these pages for my
`
` personal copy.
`
` Q. Okay. So this document you generated; is
`
` that right?
`
` A. This subset, yes, I did.
`
` Q. Okay. So, Dr. Rhyne, if we look at page 2,
`
` there is a copyright date of 2000. Do you see that?
`
` A. I do.
`
` Q. And so this is the version of the IEEE
`
` dictionary that you own?
`
` A. I own about ten different versions of it.
`
` I've been on the standards committee for the IEEE
`
` for a number of years and one of the perks for that
`
` is that they -- at least they used to send me copies
`
` of each issue of this particular standard
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` dictionary.
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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` Q. Sure. So, Dr. Rhyne, let's take a look at
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`18
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` page 3.
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` A. All right.
`
` Q. Do you see the definition there for
`
` "application"?
`
` A. I see a number of definitions for
`
` application.
`
` Q. Okay. How many definitions do you see?
`
` A. Five, I think, for that one word by itself.
`
` Q. Let's take a look at the end of each
`
` definition. Do you see that there are a series of
`
` numbers and letters appearing at the end of each
`
` definition for application?
`
` A. I do.
`
` Q. And what do those numbers and letters
`
` represent?
`
` A. Every definition that's found in the IEEE
`
` Authoritative Dictionary of IEEE Standards Terms is
`
` taken from IEEE, or in some cases ANSI, from a
`
` variety of standards. And those identify the
`
` specific standards, or standards in some cases,
`
` which -- from which the particular definition of a
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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` term was taken, and the letters tell you the
`
` technical domain that the standard addresses.
`
` Q. So can you tell me what the letter "C"
`
` represents at the end of definition No. 1?
`
` A. Yes. It's computers.
`
` Q. And what does "C-PA" represent at the end of
`
` definition 2?
`
` A. I think it means it's computers, but more
`
` specifically, portable apparatus.
`
` Q. And then what about "PE/SUB"?
`
` A. That's one I probably wouldn't consider to
`
` be relevant to this case because that's power
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` engineering/substations.
`
` Q. So, Dr. Rhyne, take a look at the numbers at
`
` the end of definition 5. Do you see that there?
`
` A. Still on page 3?
`
` Q. Yes, sir.
`
` A. I do.
`
` Q. Do you see it looks like a "C" in
`
` parentheses, and you said that stands for
`
` "computers," correct?
`
` A. That means that the standard that this came
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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` from, in the front of each standard it usually
`
` defines the technical domain for the standard, but
`
` it said that it was dealing with computer issues.
`
` Q. Okay. And what does 1003.5-1999 mean?
`
` A. That's the name of the standard. In fact,
`
` if you look into the back of the dictionary, there's
`
` a glossary of all of the standards and it usually
`
` has a little paragraph taken out of the standard
`
` that explains what this standard was about, but
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` that's -- I believe that's an IEEE standard 1003.5
`
` and that it was promulgated in 1999 by the group of
`
` people who were working on that standard.
`
` Q. And do you know what 1003.5, the standard --
`
` I'll rephrase that question.
`
` Do you know if there's a specific topic that
`
` the standard 1003.5 deals with?
`
` A. There will be a name for the standard.
`
` Without having the dictionary here and looking to
`
` the back, I don't remember. I don't know. I just
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` know that it is a relevant standard and that it
`
` deals with computers.
`
` Q. Did you ever look up the name of the
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`Conducted on October 25, 2016
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` standard referred to here as 1003.5 technical --
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` A. I think I did. I just don't remember it.
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` Q. Did you mention it in your declaration?
`
` A. I don't think I did. The main thing I was
`
` interested in was the dating. Given that I had the
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` C, which places it as something relevant to
`
` computer, and the 1999 means that it was an
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` appropriate time frame.
`
` Q. Dr. Rhyne, if we stay on page 3 --
`
` A. Okay.
`
` Q. -- if you look to the bottom right corner --
`
` A. I see it.
`
` Q. -- there is a definition -- actually, two
`
` definitions on the bottom right corner for
`
` "application software." Do you see that?
`
` A. Yes, I do.
`
` Q. Okay. And I'm going to ask you this: Do
`
` you see the letter "C" at the end of the first
`
` definition?
`
` A. Yes.
`
` Q. Okay. And do you see number 610.12-1990?
`
` A. Yes.
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`Conducted on October 25, 2016
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` Q. Do you know the name of the standard
`
` associated with the 610.12-1990?
`
` A. I do in general. I know that the 610
`
` standards were all essentially glossaries. They
`
` were collections of terms and the definitions of
`
` those terms in particular fields related to
`
` computers, but I don't remember the exact name of
`
` the 610.12 standard. Again, it's there in the
`
` dictionary at the back of it. I think it would
`
` be -- the title would begin something like standard
`
` glossary of terms for some aspect of computing.
`
` Q. And do you know what aspect of computing
`
` that would be?
`
` A. I don't remember what the dot 12 is for.
`
` Q. Well, when you -- that's not exactly my
`
` question. My question was, do you know what aspect
`
` of computing the 610.12 standard would be relevant
`
` to?
`
` A. I thought -- I don't understand the
`
` difference between that and what I just answered. I
`
` don't remember what the particular focus of 610.12
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` is. I know that it's -- it's a standard glossary of
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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` terms relating to computers in some area. Some
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` subarea, I guess is the right way to phrase it. If
`
` you look up a little bit to see like "application
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` program" on that same page, you will see that's
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` 610.5. The whole family of 610 standards -- and I
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` worked on a number of them -- further up there's a
`
` 610.7, they each have a focus within the general
`
` domain of computing.
`
` Q. Did you look up standard 610.12-1990 while
`
` preparing your rebuttal declaration?
`
` A. I did. I just don't remember the details of
`
` it. I went -- I always do that if I'm going to cite
`
` to a dictionary definition or a standard definition,
`
` I want to make sure that I think it's appropriate in
`
` the context of what I'm -- what I'm citing it for,
`
` so I did.
`
` Q. So in this case, you felt that 610.12-1990
`
` was appropriate for these cases; is that right?
`
` A. I did.
`
` Q. And you also felt that under the definition
`
` of application, 1003.5-1999 was appropriate for this
`
` application -- or for this case?
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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` A. I did. It's in the domain of computers.
`
` That's what the "C" means. And the date is 1999.
`
` Q. You told me a moment ago that the fourth
`
` definition for application is not relevant to this
`
` case; is that right?
`
` A. I wouldn't say that, necessarily, but I'm
`
` just saying because it deals with power engineering
`
` and substations -- I'm not saying it's wrong. I
`
` just -- it's not a standard -- it's okay. Looking
`
` at the actual wording of the definition is fine.
`
` It's just, power engineering substations, I think,
`
` is not as applicable as computers or portable
`
` apparatus or microprocessors and microcomputers,
`
` things like that. It's not to say that it's wrong,
`
` however.
`
` Q. Do you believe that the topic of power
`
` engineering substations is applicable to this case?
`
` A. Not directly, but that's not to say that a
`
` group of engineers working on a power engineering
`
` standard would not be able to come up with an
`
` appropriate definition of what an application is. I
`
` think they did here. It's just fine.
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`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
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` Q. Dr. Rhyne, I'm going to hand you a copy of
`
` the '020 patent, and this is marked as LG
`
` Exhibit 1001. This is specific to the 1984 case,
`
` but I think you know the specifications of the -- of
`
` the '020 patent and the '476 patent are pretty
`
` similar, so if you have any questions or want to
`
` compare this with the '476, please let me know.
`
` Dr. Rhyne, let's take a look at column 5.
`
` And I'm going to direct you specifically to lines 20
`
` through 24.
`
` A. Okay.
`
` Q. Dr. Rhyne, that first sentence, do you see
`
` that there, beginning in line 20 going down into
`
` line 21?
`
` A. I do.
`
` Q. It refers to systems which do not have a
`
` concept of separate applications as such. What kind
`
` of systems would those be?
`
` A. I think it's something that maybe Mr. --
`
` excuse me, Dr. Denning referred to as like a
`
` monolithic system. It basically just has one piece
`
` of software in it that serves as the -- implements
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`Conducted on October 25, 2016
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` all of the functionality that the device or the
`
` system would provide without any distinctions as to
`
` here's a modular code or something, that this is an
`
` application system. It's just a collection of
`
` software.
`
` Q. So do you read this sentence to mean that
`
` the present invention of the '020 patent can be used
`
` in a system having no applications?
`
` A. Well, it certainly wouldn't have its
`
` functionality broken out as separate applications.
`
` You might think of the whole thing as one big
`
` application. I really hadn't thought about it much
`
` one way or the other, but I don't -- I think it says
`
` what it says. It wouldn't have a concept of
`
` separate applications that do particular sets of
`
` tasks.
`
` Q. So in a system without a concept of separate
`
` applications, would that include a system having
`
` just one application?
`
` A. Well, I said you could think of the whole
`
` ball of software as an application if -- I guess you
`
` could say that. I probably wouldn't use that term.
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`Conducted on October 25, 2016
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` I would just say that it -- it did -- whoever wrote
`
` the code didn't partition the code with an eye
`
` toward having separate applications that could be
`
` identifiable within the software.
`
` Q. You said a moment ago you could think of the
`
` whole ball of software as an application, and then
`
` you said, "I probably wouldn't use that term." What
`
` term would you use?
`
` A. I'll go with the monolithic or some type
`
` of -- I think we're talking about spaghetti code.
`
` It's just one big chunk of software.
`
` Q. Well, let's come up with a term that we can
`
` both agree on for that type of scheme. Would you
`
` prefer to use spaghetti code or would you prefer to
`
` use monolithic software?
`
` A. Spaghetti code is kind of a pejorative term.
`
` I'm comfortable with monolithic, with the
`
` understanding that it needs to -- whoever wrote the
`
` code, either an individual or a group of
`
` individuals, wrote one big set of code. Monolithic
`
` is fine.
`
` Q. And that monolithic code, would that --
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`Conducted on October 25, 2016
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` would that code be able to perform system functions?
`
` A. It would have to.
`
` Q. Dr. Rhyne, as of, let's say -- well, let's
`
` say as of July 2000, would a person of ordinary
`
` skill in the art have known how to write monolithic
`
` code?
`
` A. I think so. Either a person or a group of
`
` people. And, again, I've managed a lot of software
`
` development and the scope of writing one set of code
`
` to do all of the functionality that, for example, is
`
` described in these two patents, the '020 and the
`
` '476, is significant. I don't know that I would
`
` have assigned it to a single individual, but I
`
` think, sure, they just write code. It's more of a
`
` project planning concept. You wouldn't have
`
` barriers or boundaries between separate
`
` applications; you'd just say here's the -- go write
`
` the code.
`
` Q. What other software schemes were available
`
` or known to a person of ordinary skill in the art as
`
` of July 2000 for implementing functions in a mobile
`
` phone?
`
`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
`
`IPR2015-01984 & IPR2015-01985
`Ex. 2011
`Page 28 of 121
`
`
`
`Deposition of V. Thomas Rhyne, Ph.D.
`Conducted on October 25, 2016
`
`29
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` A. Well, for sure there's the concept of having
`
` an operating system with an application programming
`
` interface, which you then wrote individual
`
` applications to do particular sets of functionality
`
` atop that application programming interface, also
`
` called an API. I think those two concepts, the one
`
` you were asking me about before and what I just
`
` described to you, are specifically identified in --
`
` I don't know how to pronounce it, oh-men, Oommen, in
`
` that reference.
`
` MR. HELGE: That's O-o-m-m-e-n.
`
` BY MR. HELGE:
`
` Q. Dr. Rhyne, let's come up with a term for
`
` that type of programming scheme. How would you
`
` characterize that?
`
` A. I would say you have separate
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