Outside Counsel's Eyes Only
`
` IN THE UNITED STATES DISTRICT COURT
` EASTERN DISTRICT OF TEXAS ~ MARSHALL DIVISION
`
`Page 1
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` MOBILE TELECOMMUNICATIONS
`
` Plaintiff,
`
` Vs. 2:12-cv-832-JRG-RSP
` (Lead Case)
` SPRINT NEXTEL CORPORATION,
`
` Defendants.
` __________________________
` MOBILE TELECOMMUNICATIONS
`
` Plaintiff,
` Vs. 2:13-cv-258-JRG-RSP
` APPLE,
` Defendant.
` __________________________
` MOBILE TELECOMMUNICATIONS
`
` Plaintiff,
`
` Vs. 2:13-cv-259-JRG-RSP
`
` SAMSUNG TELECOMMUNICATIONS
`
` Defendant.
` __________________________
`
` ~ OUTSIDE COUNSEL'S EYES ONLY ~
` VIDEOTAPED DEPOSITION OF RADE PETROVIC, PH.D.
` San Diego, California
` Thursday, May 1, 2014
`
`JOB NO. 72513
`
`TSG Reporting - Worldwide - 877-702-9580
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`MTel., Exhibit 2007, ARRIS v. MTel., Page 1, IPR2016-00766
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`

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`Outside Counsel's Eyes Only
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` A P P E A R A N C E S:
`
` WEIL, GOTSHAL & MANGES
` Attorneys for Apple, Inc.
` 1300 Eye Street, NW,
` Washington, DC 20005
` BY: CHRISTOPHER PEPE, ESQ.
` RYAN FERGUSON, ESQ.
`
` GREENBERG TRAURIG
` Attorneys for Samsung Electronics America
` 3161 Michelson Drive,
` Irvine, California 92612
` BY: J. RICK TACHE, ESQ.
` ERIC SQUIRE, ESQ.
`
` REED & SCARDINO
` Attorneys for Mobile Telecommunications
` 301 Congress Avenue
` Austin, Texas 78701
` BY: CHAD ENNIS, ESQ.
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` May 1, 2014
` 8:39 a.m.
`
` Videotaped deposition of RADE PETROVIC, PH.D.
` held at the Regus, 402 West Broadway,
` Suite 400, San Diego, California, before
` Jeanese Johnson, CSR No. 11635, Certified
` LiveNote Reporter, of the State of California.
`
`Page 4
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` - o0o -
`
` THE VIDEOGRAPHER: This is the start
` of tape labeled number one in the videotaped
` deposition of Rade Petrovic in the matter of
` Mobile Telecommunications Technologies, LLC
` versus Sprint Nextel Corporation, Case No.
` 2:12-CV-832-JRG-RSP; Mobile Telecommunications
` Technologies, LLC versus Apple, Inc., Case No.
` 2:13-CV-258-JRG-RSP; Mobile Telecommunications
` Technologies, LLC versus Samsung
` Telecommunications America, LLC, Case No.
` 2:13-CV-259-JRG-RSP, in the United States
` District Court for the Eastern District of Texas,
` Marshall Division.
` This deposition is being held at 402
` West Broadway, San Diego, California 92101 on
` May 1st, 2014, at approximately 8:39 a.m.
` My name is Mike Duarte from TSG
` Reporting, Inc., and I am the legal video
` specialist. The court reporter is Jeanese
` Johnson in association with TSG Reporting.
` Will counsel please introduce
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` Also Present:
` Mike Duarte, Videographer
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`TSG Reporting - Worldwide - 877-702-9580
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`MTel., Exhibit 2007, ARRIS v. MTel., Page 2, IPR2016-00766
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`

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`Outside Counsel's Eyes Only
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` yourself.
` MR. PEPE: Chris Pepe for defendant
` Apple.
` MR. FERGUSON: Ryan Ferguson with
` Weil, Gotchal & Manges for Apple.
` MR. TACHE: Rick Tache from Greenberg
` Traurig for Samsung.
` MR. SQUIRE: Eric Squire from
` Greenberg Traurig on behalf of Samsung
` MR. ENNIS: Chad Ennis with Reed &
` Scardino on behalf of the plaintiff and the
` witness.
` THE VIDEOGRAPHER: Will the court
` reporter please swear in the witness.
` THE COURT REPORTER: Please raise
` your right hand.
` Do you solemnly state the testimony
` you will give during this deposition proceeding
` will be the truth, the whole truth, and nothing
` but the truth?
` THE WITNESS: I do.
` THE COURT REPORTER: Thank you.
` ///
` ///
` ///
`
`Page 8
`
` that we are currently using.
` Q. What company was that for?
` A. My company is Verance, and the
` technology is digital watermarking, and plaintiff
` was Blue Spike.
` Q. And is that case currently pending?
` A. No. They dismissed the case while
` reserving rights to reopen, something like this,
` but it's not currently active case. That's my
` understanding.
` Q. Have you ever testified in court
` before, either for that matter or another?
` A. On that matter, I was deposed yes,
` yes.
` Q. Okay.
` A. All --
` Q. Okay. But have you testified in
` court before?
` A. No.
` Q. No?
` A. No.
` Q. So given that you've been deposed
` before, you understand that I'll be asking you
` questions today, and you're here to answer them?
` A. Yes.
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` EXAMINATION BY
` MR. PEPE:
` Q. Good morning, Dr. Petrovic.
` A. Good morning.
` Q. Can you please state your name and
` spell it for the record.
` A. Rade Petrovic. R-a-d-e, first name,
` P-e-t-r-o-v-i-c, last name.
` Q. What's your current address?
` A. Home address?
` Q. Yes.
` A. Is 11416 Cypress Woods Drive, San
` Diego, California 92131.
` Q. And is that your only residential
` address?
` A. It's my residential address. Yes, I
` have another home, second home, in Bay Area, but
` I live here. My wife lives there.
` Q. Have you ever been deposed before?
` A. Yes.
` Q. What was the nature of that
` deposition?
` A. It was deposition where my company
` was accused of infringing patents of another
` company, and I was deposed regarding technology
`
`Page 9
`
` Q. And if you don't understand a
` question, you'll tell me, and I'll try to ask you
` a better question. Does that sound good?
` A. Okay. Yeah, sure.
` Q. Is there anything that would keep you
` from testifying truthfully and accurately today?
` A. No.
` Q. You're not taking any medication that
` would compromise your memory?
` A. No.
` Q. You understand that currently you're
` being video recorded, we have an audio recording,
` and everything is also being transcribed?
` A. I do.
` Q. So because of that, it's important
` that, you know, we give audible responses, yeses
` and nos when appropriate.
` A. Okay.
` Q. And it's also important that if I'm
` asking a question, you'll let me finish before
` you start answering.
` A. Sure.
` Q. And while you're answering, I will,
` you know, try not to cut you off to make the job
` easier for the court reporter.
`
`TSG Reporting - Worldwide - 877-702-9580
`
`3
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`MTel., Exhibit 2007, ARRIS v. MTel., Page 3, IPR2016-00766
`
`

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`Outside Counsel's Eyes Only
`Page 10
` We'll take breaks periodically today.
` So if you need to stretch your legs or anything
` like that, let me know, and I'll try to find a
` convenient time for us to stop.
` A. Okay.
` Q. And your counsel may object at
` certain points throughout the day, but unless he
` instructs you not to answer the question, you
` should still respond.
` A. Okay.
` Q. So is it your understanding that
` you're here today because you're a named inventor
` on several patents that are currently owned by an
` entity called MTEL, LLC?
` A. Yes, I understand.
` Q. You understand that when I refer to
` MTEL, LLC that I'm referring to Mobile
` Telecommunications Technologies, LLC?
` A. Yes, I do.
` Q. How did you first hear about this
` lawsuit?
` A. I think I heard first from
` defendants, from Apple lawyers, and I forgot
` names that contacted me and said that the
` subpoena is pending, and then I received
`
`Page 11
` subpoena. That's how I knew that I needed to
` testify, yes.
` Q. Do you know how long ago that contact
` took place?
` A. Not quite sure, but between a month
` and two months, something like this.
` Q. So you were never contacted by MTEL,
` LLC prior to Apple contacting you?
` A. No.
` Q. And you were not contacted by a law
` firm called Reed & Scardino before that?
` A. Before that, no.
` Q. And today your understanding is that
` you're being represented by Reed & Scardino in
` this deposition; correct?
` A. Yes.
` Q. When did this representation start?
` A. After I had some exchange with the
` Apple lawyers, I was contacted by e-mail by Bill
` Hayes, who is one of the inventors, and in this
` exchange I mentioned that there is subpoena, and
` after that I was contacted by lawyers for the
` plaintiff. Yeah, plaintiff, yeah, correct.
` Q. Did you sign any sort of engagement
` letter with either MTEL, LLC or Reed & Scardino?
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` A. I don't remember that I signed
` engagement letter, but maybe. I'm not sure.
` Q. Okay. So it's possible that you're
` -- their representation is based solely on a
` verbal agreement?
` A. It is possible, but I'm not sure.
` Q. Now, do you currently have or have
` you ever had any relationship with MTEL, LLC?
` A. Currently, I don't have. When I was
` working at University of Mississippi, they were
` sponsoring a project that I was leading at
` University of Mississippi, yes.
` Q. So the entity you were working with
` at University of Mississippi was MTEL, LLC?
` A. MTEL. I don't know LLC. What does
` it mean?
` Q. Okay. So you don't -- you don't know
` whether the -- the plaintiff in this matter is
` related to that entity you worked with at the
` University of Mississippi; is that right?
` A. But the name is MTEL. So, yes, it is
` the same company.
` Q. So based on the name being the
` same --
` A. Yeah, yeah.
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` Q. -- you presume that there is a
` relationship between the two?
` A. Um-hmm.
` Q. Are you currently working as a
` consultant for MTEL, LLC?
` A. No.
` Q. Have you ever been retained as an
` expert witness or a consultant in litigation
` before?
` A. No.
` Q. And so currently in this matter,
` you're not -- you have haven't been retained as
` an expert --
` A. No.
` Q. -- or a consultant witness?
` MR. PEPE: I would like this marked
` as Exhibit 48.
` (Exhibit 48 is marked)
` Q. So, Dr. Petrovic, I've just handed
` you what's been marked as Exhibit 48, which is a
` subpoena to testify at a deposition in a civil
` action that was issued to Rade Petrovic.
` A. Um-hmm.
` Q. Do you recognize this document.
` A. Yes. I think this is the subpoena
`
`TSG Reporting - Worldwide - 877-702-9580
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`MTel., Exhibit 2007, ARRIS v. MTel., Page 4, IPR2016-00766
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`

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`Outside Counsel's Eyes Only
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` that I received. Yes.
` Q. So when you received it, you read
` through it?
` A. Yes.
` Q. And did you read the document
` requests that are in Exhibit A of --
` A. Yes.
` Q. -- Exhibit 48?
` A. Yes.
` Q. So when you -- after you read those
` requests, did you search for any documents?
` A. Yes.
` Q. Did you find any documents?
` A. No.
` Q. Where did you search?
` A. I searched my home, the file cabinets
` where I keep documents, I searched my home
` computer, and that's about it, yes.
` Q. So after that search, you determined
` that there were no documents responsive to what
` Exhibit 48 was asking for?
` A. Correct.
` Q. Do you think there was ever a time
` when there were documents in your possession that
` would have been responsive to Exhibit 48?
`
`Page 16
`
` know details of the patents.
` Q. Okay. Other than the Apple lawyers
` that you spoke to, did you speak with anyone else
` in preparation for today's deposition?
` A. No.
` Q. So you had mentioned previously that
` you had exchanged e-mails with William Hayes.
` Did you have any conversations with him?
` A. Just e-mails. Didn't have any
` conversation. And it was not about patents and
` about -- yeah, I just mentioned subpoena because
` -- and I asked him whether he got similar
` subpoena as well, and after that I got contacted
` from the plaintiff lawyers.
` Q. Did you --
` A. Apparently, he conveyed this message,
` I guess.
` Q. Did you meet with plaintiff's lawyers
` at all prior to the deposition?
` MR. ENNIS: Before you answer, I just
` want to -- you can say whether we met or not, but
` don't reveal any of our conversations.
` THE WITNESS: Excuse me?
` MR. ENNIS: You can say whether we
` met or not, but please do not reveal any
`
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` A. I am not sure.
` Q. What did you do in order to prepare
` for today's deposition?
` A. When I was contacted by Apple
` lawyers, they first sent me those patents that
` were the subject of this litigation, and I looked
` through claims only, didn't read the disclosure,
` and my response at that time was that I don't
` have good recollection of the events that led to
` these claims.
` But then patent lawyers asked me to
` look at some paper that was published that I was
` coauthor. I looked at this paper, remembered
` research that led to publishing this paper, and
` then we had some phone interview where I was
` asked questions about research that led to
` publishing this paper, and that's about it. I
` didn't go back to read the disclosure or to read
` other papers or anything else.
` Q. And so did the paper that you read
` refresh your recollection of the patents you had
` looked at?
` A. I can say that it refreshed
` recollection about work, but actually I didn't
` read the patents themselves. So I don't really
`
`Page 17
`
` attorney-client conversations.
` THE WITNESS: Yes. I met last night
` and this morning.
` Q. Okay. How long would you say you met
` for?
` A. We had a dinner. It was about two
` hours.
` Q. And you didn't review any documents
` during that meeting?
` A. No, we didn't review documents.
` Q. Can you please briefly summarize your
` education background.
` A. I am electrical engineer, and I
` graduated at University of Nis, undergrad. I got
` master's degree from Columbia University in New
` York, and I got Ph.D. from University of Nis in
` Serbia.
` Q. Did you attend those universities
` consecutively or did you work in between?
` A. No, it was consecutive.
` Q. So how long did it take you from
` start to finish through your undergrad through
` your Ph.D.?
` A. Undergrad was five years. Yes. I
` had military service that was back in Serbia
`
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`MTel., Exhibit 2007, ARRIS v. MTel., Page 5, IPR2016-00766
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`Outside Counsel's Eyes Only
`Page 18
` before I continued grad school, and then grad
` school was about three years. I mean one year of
` the University of Columbia and two years for
` Ph.D.
` Q. Did you do any sort of research while
` you were at Columbia or for your Ph.D.?
` A. Yes. And this was in optical fiber
` field. Actually, in Columbia, it was
` electromagnetics, and then optical fiber was my
` Ph.D. dissertation.
` Q. And after you finished your Ph.D.,
` what did you do after that?
` A. I worked as professor at University
` of Nis School of Electrical Engineering, and then
` I came to University of Mississippi.
` Q. So what year did you start at
` University of Nis?
` A. At University of Nis, I started 1977,
` I think.
` Q. And do you remember when you left?
` A. Yes, I do. It was 1989.
` Q. What sorts of courses did you teach
` while you were there?
` A. I taught telecommunication courses,
` digital signal processing courses. Yes. It was
`
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` department. I was actually chair of the
` department of telecommunications for a period of
` time.
` Q. And did your research focus on
` telecommunications?
` A. Yes.
` Q. And so you then went to the
` University of Mississippi in 1989?
` A. That's correct.
` Q. And how long were you there?
` A. Until January 1997.
` Q. And did you teach the same sorts of
` courses there that you taught at Nis?
` A. Yes.
` Q. And so while you were at the
` University of Mississippi, what -- what was the
` focus of your research?
` A. I, again, started with optical fiber
` communications, and then I don't exactly recall
` when, I found that there is opportunity to start
` a project on wireless radio frequency
` transmission because there was already some
` cooperation with company MTEL. So I proposed a
` project, they accepted, and they sponsored this
` project.
`
`Page 20
` We opened a wireless communication
` lab at University of Mississippi that was
` equipped by MTEL. So equipment was purchased by
` MTEL. And it lasted until, I think, 1995,
` something like this.
` Q. So what was the subject matter of
` your proposal to MTEL?
` A. It was improvements in their paging
` network, improvements towards increasing
` throughput because their network was saturated
` already with traffic, increasing throughput while
` maintaining low-cost devices, mobile devices.
` So, initially, we just increased the
` speed of transmission on one-way paging, but then
` we decided to move forward with two-way paging,
` which would offer further improvements in
` efficiency of spectrum utilization.
` Q. And so did you personally reach an
` agreement with MTEL?
` A. I forgot the details. It was through
` university. I mean, the project was official.
` It was not my personal project, but it was
` through university. I certainly wrote proposals,
` but the agreement was between companies.
` Q. Were you ever employed by MTEL?
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` A. No.
` Q. So the scope of the agreement was
` limited to them funding research that you were
` doing; is that correct?
` A. Correct.
` Q. And when did your collaboration with
` MTEL begin?
` A. I don't remember exactly but close to
` the beginning of my stay at the university, my
` employment at the university.
` Q. And did it last until the end of your
` stay at the university?
` A. Not really until the end. A little
` bit shorter.
` Q. Did you work on any commercial
` implementations of the research you were doing
` with MTEL?
` A. I did research, but the objective was
` commercial implementation, yes. But I didn't do
` commercial implementation; I did research.
` Q. Okay. So you were focused more on
` the research?
` A. Definitely.
` Q. And then in terms of commercial
` implementation, the company would do that work;
`
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`MTel., Exhibit 2007, ARRIS v. MTel., Page 6, IPR2016-00766
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` correct?
` A. Correct.
` Q. Did you have a good understanding of
` how the MTEL paging network worked?
` A. I guess. I mean, good as -- I didn't
` know all the details, but I did understand
` portions that were subject of my research, yes.
` Q. Do you remember which individuals
` from MTEL you worked with?
` A. Yeah. I did work with Dennis
` Cameron, with Bill Hayes. I worked with other
` people from MTEL. I think Cornel Atano was also
` working there in MTEL. They were all, I think,
` consultant of MTEL, not employee of MTEL, but as
` a consultant. And many others. I don't remember
` all the names.
` Q. Was there an individual at MTEL that
` you reported to in terms of your research?
` A. I think that Dennis Cameron was the
` manager of the project, and we reported to him,
` yeah.
` Q. Okay. Now, have you heard of -- I'm
` going to list out some entities, and let me know
` if you've heard of these.
` A. Um-hmm.
`
`Page 24
`
` Holdings?
` A. Never heard of them either.
` Q. How many patents are you a named
` inventor on?
` A. I don't know exact number, but
` dozens.
` Q. So more or less than 20?
` A. More.
` Q. More. Okay. Would you think it's
` more or less than 30?
` A. More.
` Q. And do these all relate to
` telecommunications?
` A. No. I mean, it -- it's not clear
` distinction, but most of recent patents are in
` digital watermarking, which can be treated as
` telecommunications, but it's not. It's classical
` telecommunications.
` Q. So I believe you testified earlier
` that there was already a relationship between
` MTEL and the University of Mississippi prior to
` your arrival there.
` A. That's correct.
` Q. Do you know how that relationship
` started?
`
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` Q. Have you heard of or ever worked with
` Sky Telecommunications, Inc.?
` A. Yeah, I've heard the name Sky
` Telecommunications, and I don't really remember
` details.
` Q. Okay. So you didn't have a working
` relationship with that entity?
` A. I don't think so.
` Q. What about Destinaire?
` A. Destinaire, my understanding, is the
` name that was coined during this project when we
` decided to develop this two-way paging system
` that was beyond what MTEL was currently doing,
` and then we decided to call this new project ^
` Destinaire. That's my understanding.
` Q. Have you ever worked with or heard of
` a company called Bell Industries?
` A. No.
` Q. How about American Messaging
` Services?
` A. Never heard of this.
` Q. Have you have you ever heard of a
` company called Alasada Wireless?
` A. No.
` Q. What about North American IP
`
`Page 25
`
` A. No, I don't know.
` Q. Have you heard of the Center for
` Wireless Communications?
` A. Yes.
` Q. And so that predated your time at --
` A. No. My understanding is that the
` center was -- when we started the project, this
` center was opened. So this was -- that's my
` recollection. I could be wrong.
` Q. Do you remember what other professors
` were involved in working with MTEL?
` A. I'm not sure. There was big center
` for electromagnetic propagation, but I'm not sure
` that they were involved with it. It may well be.
` Q. So then you wouldn't -- strike that.
` Do you have an understanding as to
` what the terms of the agreement between MTEL and
` the University of Mississippi were?
` A. I forgot the dates of the agreement.
` Q. So you don't know if there were any
` provisions regarding which party would have
` ownership over any technology that was developed?
` A. My assumption while working is that
` the ownership was through MTEL.
` Q. Okay. But you never actually saw an
`
`TSG Reporting - Worldwide - 877-702-9580
`
`7
`
`MTel., Exhibit 2007, ARRIS v. MTel., Page 7, IPR2016-00766
`
`

`
`Outside Counsel's Eyes Only
`Page 26
`
`Page 27
`
` agreement that said that; right?
` A. No.
` Q. And in terms of your agreement that
` you had with the University of Mississippi, were
` you required to give ownership of any technology
` you developed to the university?
` A. I don't remember.
` Q. Did you do any research with any
` other companies while you were at the University
` of Mississippi?
` A. Yes.
` Q. Do you remember any of the names of
` those companies?
` A. I remember Checkpoint, which is
` another company where we did RF Tax research
` project.
` Q. And do you recall what years that
` took place?
` A. It was after cooperation with MTEL.
` That's what I know for sure, but I don't remember
` the year.
` Q. So after you left the University of
` the Mississippi, where did you go to work?
` A. I went to work for a startup company
` in Boston doing digital watermark, and I'm still
`
`Page 28
` THE COURT REPORTER: Do you want to
` do 10 or do you want to do next in order?
` MR. PEPE: I would like to re-mark
` that as 10.
` (Exhibit 10 is marked)
` Q. So, Dr. Petrovic, you've been handed
` what has been previously marked as Exhibit 10,
` which is US Patent Number 5590403, the first page
` of which bears Bates Number MTEL 1201810.
` Can you take a moment to look over
` the front page?
` A. I didn't quite get what you read.
` This number, what is this number?
` Q. Oh, the Bates number?
` A. Bates, what's Bates?
` Q. So the number in the bottom right
` corner of the document --
` A. Oh.
` Q. -- it's just a stamp that's put on --
` A. Um-hmm.
` Q. -- documents that are produced in
` litigation --
` A. Um-hmm.
` Q. -- so that they are easier to track.
` A. Um-hmm.
`
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` working in this field.
` Q. For the same company?
` A. The company that I started working
` merged. It was in Boston. It merged with a
` company in San Diego, and we moved and changed
` the name, but, yes, it is basically the same
` company.
` Q. So that's basically been your sole
` employer --
` A. Yes.
` Q. -- since you left the University --
` A. Correct.
` Q. -- of Mississippi.
` MR. PEPE: So I think I'm going to
` start going into our patents. I don't know if
` you guys want to --
` MR. TACHE: We'll leave you to it.
` MR. PEPE: All right.
` So I'm going to do a little
` housekeeping here. So this is US Patent 5590403,
` which was previously marked as Exhibit 10;
` however, the copy that was marked didn't have
` Bates numbers on it, so I'd like to re-mark this
` as Exhibit 10, which is a Bates-stamped copy of
` that patent.
`
`Page 29
`
` (Document reviewed)
` A. Um-hmm.
` Q. Do you recognize that document?
` A. Yes.
` Q. And what is your understanding of
` what it is?
` A. This is a patent that we produced by
` working on this project, and, yeah, it is about
` operating in -- basically talks about protocol of
` two-way paging network.
` Q. Okay. So if I refer to Exhibit 10 as
` the '403 patent --
` A. Okay.
` Q. -- will you understand what I'm
` talking about?
` A. Sure.
` Q. Just to make things a little easier.
` So the '403 patent, you're a named
` inventor on that; is that correct?
` A. Yes.
` Q. Do you know why you're a named
` inventor on that patent?
` MR. ENNIS: Objection. Form.
` You can answer.
` THE WITNESS: Because I worked on
`
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`TSG Reporting - Worldwide - 877-702-9580
`
`8
`
`MTel., Exhibit 2007, ARRIS v. MTel., Page 8, IPR2016-00766
`
`

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`Outside Counsel's Eyes Only
`Page 30
` this research, so I was part of the team that
` worked on this research.
` Q. Have you reviewed the '403 patent
` recently?
` A. No. As I mentioned before, I just
` looked at the claims, not even to read through
` the body of the patent.
` Q. So having reviewed the claims, what
` would you say is the core invention of the '403
` patent?
` A. The core invention of this patent is
` how to -- as I mentioned, the objective of the
` core research is to improve spectrum utilization
` in the paging networks, and the technique that we
` disclose here is to utilize two-way paging in
` such a way that you first locate the mobile
` device and then divides your nationwide network
` into small sections, segments, so that each of
` those smaller segments of the network would carry
` distinct information, which basically multiplies
` over all throughput to a number of different
` sections, each section carrying different
` information.
` Q. Can you take a moment to look through
` the figures of the '403 patent?
`
`Page 31
` A. Do we need to read all those block
` diagrams?
` Q. No.
` A. (Document reviewed)
` Okay. I surfed through it. Some of
` them ring the bell; some don't, I must say.
` Q. That's fair.
` Do you remember if you contributed to
` making any of those figures?
` A. No, I don't remember.
` Q. Having reviewed them, does that help
` you remember specifically what you contributed to
` the '403 patent?
` A. I don't think that looking at the
` figures helps that, but I know what I worked on,
` so, yeah.
` Q. So what specifically did you work on?
` A. Basically, the most important thing
` that I worked on was modulation technique for
` forward channel, this multi-carrier modulation or
` fiber optic communication multiplex. A prime
` location modulation, I think was the term that we
` used. This is one part.
` The other part was -- I mean, many
` parts I worked on, but the other part that I
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`Page 32
` remember spending a significant amount of time is
` data link layer particles that are in part
` described here, how to organize the exchange of
` information from base stations and mobile units
` to maximize throughput, overall throughput.
` Q. Did you help prepare the patent
` application for the '403 patent?
` A. I think so. I don't remember
` specifically this, but I remember working on
` patents and writing and reading and adding,
` commenting, discussing and so on, yes.
` Q. So then you probably contributed to
` drafting some sections of the '403 patent?
` A. Probably.
` Q. Do you recall any meetings that were
` held with MTEL regarding the '403 patent during
` the application process?
` A. With MTEL, with people that are
` listed here, of course. With MTEL in general.
` Q. Do you recall if you helped draft
` some of the claims of the '403 patent?
` A. I don't recall. I don't think so. I
` don't think that I at that time was, you know,
` enough versed into patent process to draft
` claims.
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`Page 33
`
` Q. Do you --
` A. I think lawyers did it,