10/22/2015
`Page 3
` INDEX TO EXAMINATION
`WITNESS: RADE PETROVIC
`
`EXAMINATION PAGE
`BY MS. SANGALLI 7
`BY MR. WYSS
`
`Page 4
`
` INDEX TO EXHIBITS
`EXHIBITS DESCRIPTION MARKED
`Exhibit 1 Deposition subpoena 12
`Exhibit 2 US Patent Number 5,590,403 17
`Exhibit 3 Proposal to MTel, Inc., by the 30
` Center for Telecommunications at
` The University of Mississippi,
` dated August 1991
`
`Exhibit 4 Proposal to MTel, Inc., by the 43
` Center for Telecommunications at
` The University of Mississippi,
` dated May 1992
`Exhibit 5 Proposal to MTel, Inc., by the 61
` Center for Telecommunications at
` The University of Mississippi,
` dated May 1993
`
`Exhibit 6 Proposal cover sheet, and 68
` Proposal to MTel, Inc., by the
` Center for Telecommunications at
` The University of Mississippi,
` dated February 1993
`
`Exhibit 7 Proposal cover sheet, and 69
` Proposal to MTel, Inc. By the
` Center for Telecommunications at
` The University of Mississippi,
` dated May 1993
`
`Exhibit 8 Proposal cover sheet, and 74
` Proposal to MTel, Inc., by the
` Center for Telecommunications at
` The University of Mississippi,
` for project period August 15,
` 1994 to May 15, 1995
`Exhibit 9 Assignment 81
`Exhibit 10 Petition for Rulemaking 82
`Exhibit 11 Technical Feasibility 86
` Demonstration
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`RADE PETROVIC
`
` UNITED STATES DISTRICT COURT
` FOR THE EASTERN DISTRICT OF TEXAS
`
`Page 1
`
`MOBILE TELECOMMUNICATIONS
`TECHNOLOGIES, LCC,
`
` Plaintiff,
`
` vs. CASE NO. 2:14-cv-
` 00897-RSP
`AT&T MOBILITY & AT&T INC.,
`
` Defendants.
`
`~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
`
` HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY
`
` VIDEOTAPED DEPOSITION OF
` RADE PETROVIC
`
` October 22, 2015
` 9:06 a.m.
`
` 750 B Street
` Suite 2900
` San Diego, California
`
` Renee Kelch, RPR, CLR, CSR No. 5063
`
`Page 2
` APPEARANCES OF COUNSEL
` For the Plaintiff and the Deponent:
` REED & SCARDINO LLP
` NICHOLAS WYSS, ESQ.
` Suite 1250
` 301 Congress Avenue
` Austin, Texas 78701
` 512.474.2449
` 512.474.2622 Fax
` nwyss@reedscardino.com
`
` For the Defendants:
` DUANE MORRIS LLP
` DIANA M. SANGALLI, P.C., ESQ.
` Suite 800
` 1330 Post Oak Boulevard
` Houston, Texas 77056
` 713.402.3915
` 713.583.2836 Fax
` dmsangalli@duanemorris.com
`
` Also Present:
` Isaac Orihuela, videographer
` Thomas W. Sankey, Esq. (Telephonically)
` Duane Morris LLP
`
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`Draft Copy
`
`1 (Pages 1 to 4)
`DIVERSIFIED REPORTING SERVICES
`(202) 467-9200
`
`MTel., Exhibit 2009, Aruba v. MTel., Page 1, IPR2016-00768
`
`

`
`RADE PETROVIC
`
`Page 5
` INDEX TO EXHIBITS (Continued)
`EXHIBITS DESCRIPTION MARKED
`Exhibit 12 US Patent Number 5,590,403 87
`Exhibit 13 US Patent Number 5,915,210 100
`Exhibit 14 Petition Under 37 CFR Section 113
` 148(b)
`
`Exhibit 15 US Patent Number 5,659,891 120
`
`Exhibit 16 Document titled, "Permutation 125
` Modulation for Advanced Radio
` Paging"
`
`Exhibit 17 Document titled, "Multicarrier
` Permutation Modulation for
` Narrowband PCS"
`
`Exhibit 18 Document titled, "Multicarrier
` Modulation for Narrowband PCS"
`Exhibit 19 Deposition transcript of Rade
` Petrovic, Ph.D., taken on May 1,
` 2014
`Exhibit 20 Deposition transcript of Rade
` Petrovic, taken on April 3, 2015
`
`(Original exhibits attached to original
`transcript)
`
` DEPOSITION OF RADE PETROVIC
` OCTOBER 22, 2015
`
`Page 6
`
` THE VIDEOGRAPHER: Good morning. This is Tape
`Number 1 to the videotaped deposition of Rade Petrovic,
`in the matter of Mobile Technologies, LLC, et al.,
`versus AT&T Mobility, et al., being heard before United
`States District Court, Eastern District of Texas, Case
`File 2:14-cv-00897-RSP.
` This deposition is being held at Duane Morris
`LLP, located at 750 B Street, Suite 2900, in San Diego,
`California, 92101, on the date of October 22nd, 2015, at
`the time of 9:06 a.m.
` My name is Isaac Orihuela. I'm the
`videographer. The court reporter is Renee Kelch.
` Counsel, will you please introduce yourselves
`and affiliations, and then the witness will be sworn.
` MS. SANGALLI: Diana Sangalli, with Duane
`Morris, on behalf of the Defendant AT&T. And with me by
`telephone is Tom Sankey, also with Duane Morris.
` MR. WYSS: Nicholas Wyss on behalf of the
`Plaintiff Mobile Telecommunications Technologies LLC,
`and representing the witness.
` THE VIDEOGRAPHER: Thank you. The court
`reporter can now administer the oath.
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`2 (Pages 5 to 8)
`DIVERSIFIED REPORTING SERVICES
`(202) 467-9200
`
`10/22/2015
`Page 7
`
` RADE PETROVIC,
` having been first duly sworn, testifies as follows:
`
` EXAMINATION
`BY MS. SANGALLI:
` Q. Good morning.
` A. Good morning.
` Q. Could you please state your full name for the
`record?
` A. Rade Petrovic. Do you want spelling?
` Q. Okay. And you live here in San Diego; right?
` A. Yes.
` Q. And you work here in San Diego --
` A. Yes.
` Q. -- now?
` And one thing I'm noticing a little bit here
`already before we're getting into it is that we're
`having a little bit of tendency to talk over each other.
`So just, you know, make sure that you let me ask my
`question, and then you can provide your response, so the
`court reporter stays happy and can get everything down.
` A. Okay.
` Q. You've been deposed before; correct?
` A. Correct.
` Q. And I know it's been probably several times
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`Page 8
`that you've been deposed, but could you tell me when the
`last time you were deposed?
` A. Last time was in spring. I don't know the --
`forgot dates.
` Q. And was that in connection with a patent
`litigation involving the plaintiff in this lawsuit,
`MTel?
` A. Yes.
` Q. And was that also involving Cricket, perhaps;
`do you recall?
` A. No.
` Q. Okay. So you don't know who the defendant in
`that lawsuit --
` A. No.
` Q. -- was?
` And before -- so the spring of this year, you
`think it was?
` A. Uh-huh.
` Q. And before the spring of this year, when was
`the last time you were deposed?
` A. Fall last year.
` Q. Okay. And do you recall what matter that was?
` A. It was same plaintiff, but I don't remember
`exactly what -- who was the defendant.
` Q. Okay. And I assume before then you were
`
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`Draft Copy
`
`MTel., Exhibit 2009, Aruba v. MTel., Page 2, IPR2016-00768
`
`

`
`10/22/2015
`Page 11
`
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` A. No.
` Q. -- that would prevent you?
` A. No.
` Q. Just a couple other ground rules I'll just go
`over to make sure that we're on the same page. We've
`already talked about trying not to talk over each other.
` I also would ask that your answers always be
`verbal. No shaking the head yes or no. Because again,
`the court reporter can't record shakes of the heads. Is
`that okay?
` A. Okay.
` Q. Okay. And if you don't understand a question
`I'm asking, if you could let me know, I'd appreciate
`that. Is that fine?
` A. Okay.
` Q. And if you don't, otherwise I'm going to assume
`that you understood what I asked. Okay?
` A. Okay.
` Q. Okay. If you need a break, let me know. I'll
`try to break probably about every hour or so. If -- you
`know, I know that you have a time constraint today. I
`don't think that's going to be an issue. But as long as
`you're willing to keep going without a break, that's
`fine with me too. So just let me know if there comes an
`occasion when you need a break.
`
`Page 12
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` A. Okay.
` Q. Okay.
` (Exhibit 1 marked)
`BY MS. SANGALLI:
` Q. I'm going to hand you the first exhibit which
`I've marked as Exhibit 1. And we've got a really big
`table here.
` Exhibit 1 is a subpoena to testify. Have you
`seen this document before?
` A. No.
` Q. You have not?
` A. No.
` Q. Were you aware that AT&T had served a subpoena
`asking you to both testify and produce documents in this
`litigation?
` A. Yes.
` Q. And when did you first become aware that
`subpoena had been issued?
` A. I don't remember. It was relatively soon. Two
`weeks ago. Something like this.
` Q. Two weeks ago?
` A. Yes.
` Q. Okay. And was that the first time that you.
` Were aware of this particular lawsuit involving
`AT&T?
`
`Draft Copy
`
`RADE PETROVIC
`
`Page 9
`
`deposed on other occasions too --
` A. Yes.
` Q. -- in advance of fall, 2014?
` Do you remember when that was?
` A. No. I know that I was deposed -- Apple and
`Samsung were defendants, but I forgot when.
` Q. Okay. Apple, it was?
` A. Uh-huh.
` Q. And Samsung?
` A. Uh-huh.
` Q. Were there any others, depositions that you
`recall in connection with the plaintiff in this lawsuit?
` A. No.
` Q. Okay. Have you been deposed in any other
`matters?
` A. Yes.
` Q. What matters were those?
` A. That was matters concerning my current company,
`Verance.
` Q. Did that have to with a patent lawsuit also?
` A. Yes.
` Q. Do you recall approximately when that
`deposition occurred?
` A. It was 2001 or '2, something like this.
` Q. Okay. And other than that deposition, have
`
`Page 10
`there been any other occasions when you've been deposed?
` A. No.
` Q. Okay. I'm going to be asking you questions
`today mostly regarding your relationship in the 1990s
`with a different MTel company, which was MTel, Inc. I'm
`going to attempt to refer today to that MTel, Inc., as
`MTel. And when I'm referring to the different MTel,
`which is the plaintiff in this lawsuit, I will clarify
`when I'm referring to that MTel as being the plaintiff
`in this lawsuit. Is that okay?
` A. Okay.
` Q. If there's any point where you are unclear
`about which MTel I'm referring to, if you could let me
`know, I would appreciate that. Is that okay?
` A. Okay.
` Q. Now, you understand that you're under oath
`today; right?
` A. Yes.
` Q. And that you should testify today just as if
`you were testifying before a jury and a court; right?
` A. Right.
` Q. Okay. Is there any reason why you cannot give
`full and accurate testimony today?
` A. No.
` Q. No medications or any issues --
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`3 (Pages 9 to 12)
`DIVERSIFIED REPORTING SERVICES
`(202) 467-9200
`
`MTel., Exhibit 2009, Aruba v. MTel., Page 3, IPR2016-00768
`
`

`
`10/22/2015
`Page 15
`agreements between you and MTel related to the two-way
`project?
` A. Yes, I looked for, and I didn't find any.
` Q. Did you look for any reports that you had
`prepared in connection with the two-way paging project?
` A. I looked for, and didn't find any.
` Q. And again, what you searched was your computer;
`right?
` A. Computer and file folders, papers.
` Q. In connection with your deposition today, did
`you do any preparation?
` A. We had a meeting last night, and we went over
`some of the papers, yes.
` Q. Who did you meet with?
` A. Nick. Nick Wyss -- Wyss.
` Q. Anyone else?
` A. No.
` Q. Anybody attend by telephone?
` A. I did talk this morning with Daniel Scardino.
` Q. Okay. And was there anyone else besides Daniel
`on the telephone?
` A. No.
` Q. So you have talked Nick and to Daniel --
` A. Yes.
` Q. -- to prepare?
`
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` And how long did you meet with Nick yesterday?
` A. It was about one hour, or hour and a half.
` Q. Did you review any documents?
` A. Yes.
` Q. What documents did you review?
` A. Mostly was proposals that were related to this
`two-way paging patent that were retrieved from Ole Miss.
` Q. And those would be proposals between MTel and
`Ole Miss?
` A. Yes, I think so.
` Q. Were there any other documents that you
`reviewed besides the proposals?
` A. I think there was another document that I
`recall that was, I think, titled "Power of Attorney"
`document that was related to, I believe, submitting the
`patent to patent office.
` Q. Okay. Any others that you can recall?
` A. No.
` Q. Did you review any documents that to your
`knowledge have not been produced in this litigation?
` A. Don't quite understand question.
` Q. Did any -- to your knowledge, have all the
`documents -- were all the documents that you reviewed in
`preparation for your deposition, had those documents
`already been provided to AT&T, to your knowledge?
`
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`
`RADE PETROVIC
`
`Page 13
`
` A. I think so.
` Q. Okay. And if you need a moment to look through
`the subpoena, that's fine. But do you understand that
`the subpoena is asking you to provide both testimony and
`to produce documents?
` A. Yes. I'm aware of this fact from previous
`depositions.
` Q. Okay. But you haven't looked at this
`particular --
` A. No --
` Q. -- subpoena?
` A. -- I haven't.
` Q. Did you bring any documents with you today?
` A. No.
` Q. Did you provide any documents to counsel in
`response to the subpoena?
` A. To this subpoena? No.
` Q. Did you look for any documents?
` A. I did.
` Q. You did look for documents?
` A. For previous depositions.
` Q. Okay.
` A. I searched my files and I didn't find any
`documents related to this case.
` Q. Okay. Did you look for -- and the document
`
`Page 14
`request in this case may be a little bit different than
`what you were asked for in previous cases. Did you
`search your files for any documents related to your
`relationship with the University of Mississippi?
` A. No, I did not.
` Q. Did -- so when you looked for documents before,
`what documents did you look for?
` A. I looked for documents that were related to the
`project, two-way paging project, or whatever it's called
`at that time. And that's what I didn't find.
` Q. Okay. Were you looking for papers that you had
`published?
` A. Papers, yes.
` Q. Okay.
` A. I looked computer drives also.
` Q. Okay.
` A. I looked for papers that I published too, yes.
`And I did look one or two of them.
` Q. You found one or two papers?
` A. Yeah.
` Q. Okay. And you provided those papers to
`counsel?
` A. I probably provided titles, and you know, not
`papers themselves. But publication details.
` Q. Okay. Did you find any -- did you look for any
`
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`4 (Pages 13 to 16)
`DIVERSIFIED REPORTING SERVICES
`(202) 467-9200
`
`MTel., Exhibit 2009, Aruba v. MTel., Page 4, IPR2016-00768
`
`

`
`10/22/2015
`Page 19
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` A. Uh-huh.
` Q. Okay. And you believe that that version of the
`letter was lost; is that correct?
` A. It's -- I don't know what happened. Probably
`is not lost lost, but whoever received it didn't act
`upon it, so.
` Q. And you don't have a copy of that previous --
` A. I think it's the same thing.
` Q. But would have been signed with a date --
` A. Yes.
` Q. -- upon it?
` A. Yes.
` Q. So the same -- you would have a copy of this
`same letter but with your signature as of a different
`date; is that right?
` A. I think so, yes.
` Q. Okay. What's your understanding of what this
`agreement is between you and Reed & Scardino?
` A. Consulting agreement.
` Q. A consulting agreement. Consulting agreement
`with respect to what?
` A. Consulting agreement that they would represent
`me during deposition. And that I'm supposed to show up
`on depositions as required, and that I would be witness
`and report all that I remember about this project, and
`
`Page 20
`to answer truthfully to all questions. That was my
`understanding of this.
` Q. Okay. And just so that I'm clear, do you
`intend to -- other than the services that you just
`described there, showing up at a deposition and
`providing testimony, do you intend to offer any opinions
`in this lawsuit about infringement?
` A. No. My understanding is that I'm here witness
`and not expert.
` Q. Okay.
` A. So I'm not expert in this field anymore. It's
`been 20 years since I moved away from this field, so I
`cannot give opinions as an expert.
` Q. Okay. So likewise -- and I'd asked
`specifically about infringement. But likewise, you
`don't intend to offer any opinions about the validity of
`any of the patents either; is that right?
` A. Right.
` Q. Have you received any compensation as a result
`of this agreement?
` A. Yes, I have.
` Q. How much have you been paid?
` A. I don't remember.
` Q. Do you remember when you first were paid under
`this agreement?
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`RADE PETROVIC
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`Page 17
`
` A. I don't --
` MR. WYSS: Objection form.
` THE WITNESS: I don't know.
`BY MS. SANGALLI:
` Q. Okay. Do you have a written agreement with
`Reed & Scardino where they've agreed to represent you in
`this deposition?
` A. I think so.
` (Exhibit 2 marked)
`BY MS. SANGALLI:
` Q. I've handed you what I marked as Exhibit
`Number 2. It is -- it's a document that bears Bates
`Numbers MTEL-ATT 35232 through 233. Do you recognize
`this document?
` A. Yes.
` Q. Is this the agreement that you were referring
`to?
` A. Yes.
` Q. Do you know when you entered into this
`agreement with Reed & Scardino?
` A. I'm not sure. This document was first
`exchanged some time ago but actually not signed until,
`you see, relatively recently. Signed on August 21st,
`2015.
` Q. Okay.
`
`Page 18
` A. But I think I seen this document in the fall
`last year, something like this.
` Q. Okay. And so you're referring to on the second
`page there, 233, that's your signature there --
` A. Yes.
` Q. -- on the bottom, dated August 21st of 2015?
` A. Uh-huh.
` Q. So approximately two months ago?
` A. Yes.
` Q. Okay. On the first page there's a date on the
`top that indicates November 25th, 2014. To your
`recollection, is that when you first received this
`letter?
` A. I think so, yes.
` Q. Okay. Is there a reason why you did not sign
`the letter until August of 2015?
` MR. WYSS: Objection. Form.
` THE WITNESS: I think I've signed it before and
`sent. But it was kind of lost, or something. Didn't
`get any response to this. And then again this was --
`this matter was raised, and then I signed it again.
`Something like this.
`BY MS. SANGALLI:
` Q. Okay. So your recollection is that you've
`signed this agreement before?
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`5 (Pages 17 to 20)
`DIVERSIFIED REPORTING SERVICES
`(202) 467-9200
`
`MTel., Exhibit 2009, Aruba v. MTel., Page 5, IPR2016-00768
`
`

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`10/22/2015
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`and so on. So it's shaping of light impulses,
`basically.
` Q. Is that coding applicable in any way to coding
`in wireless communication networks?
` A. There are some similarities. You always want
`to eliminate DC component, and you always want to enable
`synchronization of the receivers to be the boundaries.
`So those constraints are more general. But there are
`specifics for optical fibers.
` Q. After you received your Ph.D., what did you do?
` A. I was professor at University of Nis.
` Q. Of electrical engineering?
` A. Of electrical engineering.
` Q. Did you teach?
` A. Yes.
` Q. Taught courses in optical fiber communications?
` A. Optical fiber and many other courses.
`Telecommunications generally.
` Q. Cellular networks?
` A. No, I don't think so that I taught cellular
`networks. I taught digital signal processing, I
`remember. I taught general telecommunication courses.
` Q. Did you teach any courses on paging networks?
` A. No.
` Q. How long were you a professor at that
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`university?
` A. Until I moved to Mississippi. So it was 1989,
`August.
` Q. And what were the circumstances that led you to
`move to Mississippi?
` A. I got an offer to be a visiting professor at
`University of Mississippi, which I accepted.
` Q. Is a visiting professor, is that usually for a
`temporary time period?
` A. Yeah. It was for a year. But then during that
`year they opened position, permanent position. I
`applied, and I was elected.
` Q. And the position as a visiting professor, was
`that a teaching position or --
` A. Yes.
` Q. -- research?
` It was a teaching position?
` A. Teaching position.
` Q. Were you teaching classes again regarding
`telecommunications?
` A. Correct.
` Q. You said during that first year a permanent
`position opened up. And was that a similar position as
`to what you were doing as a visiting professor?
` A. Yes.
`
`Draft Copy
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`RADE PETROVIC
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`Page 21
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` A. I think it was over the summer.
` Q. Over --
` A. This --
` Q. -- the summer of this year?
` A. Of this year, yes.
` Q. And that was before you had signed the
`agreement in August of 2015?
` A. I think so.
` Q. Okay. Did you receive a retainer of $5,000?
` A. No.
` Q. No? Do you provide invoices to Reed and
`Scardino --
` A. Yes.
` Q. -- for your time?
` A. Yes.
` Q. And then they pay you based on how many hours
`that you billed on those invoices; is that right?
` A. Correct.
` Q. Before this summer, had you received any other
`payments from Reed & Scardino in connection with these
`lawsuits?
` A. No.
` Q. Can you tell me a little bit about your
`background, your education?
` A. My education is electrical engineering. I
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`finished undergrad in Yugoslavia. Now it's Serbia. In
`a city called Nis. Then I got master's degree from
`Columbia University, New York. And then I got Ph.D.,
`again at University of Nis, electrical engineering.
` Q. And your master's was in electrical
`engineering?
` A. Electrical engineering, yes.
` Q. What year did you get your master's?
` A. 1977.
` Q. Okay. And do you recall approximately when you
`received your Ph.D.?
` A. 1980. I think.
` Q. For your Ph.D., did you have a particular
`specialty or topic that you were working on?
` A. Yes. I was at that time doing optical fiber
`communications.
` Q. Anything in particular with respect to optical
`fiber communications?
` A. Line codes for optical fibers.
` Q. Line codes?
` A. Line codes.
` Q. What are line codes?
` A. It's coding that helps get successful
`communication over the optical fibers to eliminate DC
`component, to provide synchronization to the receivers,
`
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`6 (Pages 21 to 24)
`DIVERSIFIED REPORTING SERVICES
`(202) 467-9200
`
`MTel., Exhibit 2009, Aruba v. MTel., Page 6, IPR2016-00768
`
`

`
`10/22/2015
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` MR. WYSS: Objection. Form.
` THE WITNESS: That I'm interested in doing
`research for them.
`BY MS. SANGALLI:
` Q. And what was your understanding of what type
`of -- of the technology that MTel was working on at the
`time?
` A. I knew that they were working on paging
`systems. And they did have a pager transmitter that was
`located in the same building where my office was.
` Q. Okay.
` A. And -- I don't remember, you know, conversation
`details.
` Q. Did they have a paging network --
` A. Yes, they did --
` Q. -- at this time?
` A. -- have a paging network, yes.
` Q. It was one-way paging network?
` A. It was one-way paging network.
` Q. So it was not a two-way?
` A. No.
` Q. -- paging network?
` So is it fair to say that you offered your
`services, and MTel accepted?
` A. Uh-huh.
`
`Page 28
` Q. So what was the first project that you worked
`on for MTel?
` A. The first project was to increase bit rate of
`existing nationwide paging service. And I argued that
`bit rate that was currently used, 1200 bits per second
`was unnecessarily limiting; that existing system can
`operate at least twice this bit rate. Maybe even more.
` And they asked, "Can you prove it?"
` And I said, "Let's try."
` And then I worked mostly on modifying pagers.
`And they had provided for transmitters. And I asked
`them to modify their transmitters, and -- transmitter at
`University of Mississippi. And then we did experiments
`and showed that basically twice bit rate provides almost
`the same coverage as original bit rate.
` Q. And you personally worked on the modification
`to the pagers?
` A. Yes.
` Q. And what did that modification involve?
` A. I -- was relatively simple modification. I
`changed the crystal quartz that was used to drive and,
`you know, determine bit rate. I used crystal quartz
`that had double the frequency.
` And then I changed some filter designs to allow
`just a little bit wider spectrum of the data to come
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`Draft Copy
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`RADE PETROVIC
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` Q. Were there any differences in your
`responsibilities as a visiting professor?
` A. No, I don't think so.
` Q. So you were teaching classes?
` A. Yes.
` Q. Performing any research?
` A. Yes.
` Q. What was the research, the areas of your
`research?
` MR. WYSS: Objection. Form.
` THE WITNESS: Initially I was, you know,
`accepted in this position as an expert in optical
`fibers. So I continued working in this field, in
`optical fibers. But during this first year, I realized
`that there is not enough support for the optical fiber
`field in University of Mississippi. But there was this
`company called MTel, which already had ties with the
`University of Mississippi. And they already had some
`sponsorship of research at University of Mississippi.
`And I decided that I can offer them my services as well.
` They accepted. We ran some test projects that
`were successful. And then we decided to go further, and
`that's how this project started, two-way paging system.
` Q. Okay. So how did you first learn of MTel?
` A. There was a meeting at University of
`
`Page 26
`Mississippi, where MTel representatives came, and where
`faculty from electrical engineer were present. I don't
`remember, you know, all the details of that meeting.
`But I know that that's where I met representatives of
`MTel and offered my services.
` Q. Was MTel making a presentation at that meeting?
` A. I don't remember details.
` Q. Okay. Do you recall who you met at that
`meeting that was associated with MTel?
` A. I recall face, but I can't recall the name.
`Sorry about that. I know that this guy was Greek by
`origin. But now I don't remember the name.
` Q. Greek. Okay.
` A. It starts with K, but I can't -- his last name
`starts with K. That's all I remember.
` Q. Okay. So you talked to this gentleman at that
`meeting?
` A. Yes.
` Q. And what did you -- what did you ask him?
` A. I forgot. I don't remember, you know,
`conversation.
` Q. You said you offered your services?
` A. Yes.
` Q. And what did you mean when you said you offered
`your services?
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`7 (Pages 25 to 28)
`DIVERSIFIED REPORTING SERVICES
`(202) 467-9200
`
`MTel., Exhibit 2009, Aruba v. MTel., Page 7, IPR2016-00768
`
`

`
`RADE PETROVIC
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`Page 29
`through to the detection of circuits. And that was
`enough.
` Q. So the crystal parts, that it was an oscillator
`or timing --
` A. Yes.
` Q. Okay. And then you modified the filters?
` A. Yes.
` Q. And then you ran experiments to prove out --
` A. Yes.
` Q. -- your concept?
` How long did that project last?
` A. It was matter of months. I'm not -- don't
`recall exactly.
` Q. Less than six months?
` A. Maybe. I don't know.
` Q. Were you paid by MTel for that project?
` A. I don't remember.
` Q. Do you know whether there was written agreement
`between you and MTel in regards to that project?
` A. Don't remember.
` Q. Okay. After that first project, did you work
`on additional projects with MTel?
` A. Yes. The next project was actually this
`two-way paging project.
` Q. Do you recall what year that was?
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`10/22/2015
`Page 31
`University of Mississippi on Advancements in Paging
`Technology."
` Is this a proposal that the university
`prepared?
` A. I believe that I prepared technical part of
`this proposal, like, you know, project tasks, what is
`supposed to be done in this project.
` I guess that I worked -- I don't recall, that I
`worked also financial parts, how much would money cost
`to do this project. But again, it's -- I don't remember
`for sure.
` Q. Okay. So if we turn to the page that has a 6
`on the bottom of it, which is a Proposal Cover Sheet, it
`has a project period there of August 20th, 1991 to
`May 16th, 1992. Does that match up with your
`recollection of the first project that you worked on for
`the two-way paging system with MTel?
` A. Yeah, roughly matches it. I don't recall the
`dates exactly, but sounds right.
` Q. Who's Dr. Stacy Holmes?
` A. Dr. Stacy Holmes was a director of Center for
`Telecommunications, and he was actually one who called
`me to the visiting professor position first. So he was
`already there. And through him, I actually obtained
`this position.
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` A. Based on those documents that I saw yesterday,
`I can recall. But I was not sure on my own. So
`apparently this project was started in 1991.
` Q. Okay. Let's take a look at some of those
`documents.
` (Exhibit 3 marked)
`BY MS. SANGALLI:
` Q. Okay. I've just handed you a document that has
`some numbers on the bottom of it. And the number on the
`first page is 5, and the number on the last page is 23.
` Is this one of the documents that you were
`referring to that you reviewed yesterday?
` A. Yes.
` Q. And is -- do you recognize this document in
`particular?
` A. I recognize this document because I reviewed it
`yesterday.
` Q. Had you seen -- had you seen this document
`before yesterday?
` A. Apparent -- yesterday -- before yesterday?
` Q. Yes.
` A. Apparently, since I signed it. I recognize my
`signature too.
` Q. So this document is entitled, "A Proposal to
`MTel, Inc., By the Center for Telecommunications at The
`
`Page 32
` Q. Okay. Did MTel contact you directly about this
`project, or did they -- or was it somebody else at the
`University of Mississippi that they were in contact
`with?
` MR. WYSS: Objection. Form.
` THE WITNESS: I don't remember.
`BY MS. SANGALLI:
` Q. Also on -- so it lists Dr. Stacy Holmes as
`project director. What responsibilities did Dr. Holmes
`have as a project director?
` A. I think his specialties a