`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD.,
` Petitioner, Case IPR2016-00908
` Patent No. 5,796,183
` vs.
`UUSI, LLC d/b/a NARTRON,
` Patent Owner.
`_______________________________
`
` DEPOSITION OF VIVEK SUBRAMANIAN, Ph.D.
` San Francisco, California
` Friday, February 3, 2017
`
`REPORTED BY:
`CYNTHIA MANNING, CSR No. 7645, CLR, CCRR
`JOB NO. 118712
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` February 3, 2017
` 9:24 a.m.
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` Deposition of VIVEK SUBRAMANIAN, Ph.D.,
`held at Paul Hastings LLP, 55 Second Street, 24th
`Floor, San Francisco, California, before Cynthia
`Manning, Certified Shorthand Reporter No. 7645,
`Certified LiveNote Reporter, California Certified
`Realtime Reporter.
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`EXHIBIT 2009
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`A P P E A R A N C E S:
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`Page 3
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` PAUL HASTINGS
` Attorneys for Petitioner
` 875 15th Street, NW
` Washington, DC 20005
` BY: CHETAN BANSAL, ESQ.
` JOSEPH PALYS, ESQ.
`
` DiMURO GINSBERG
` Attorneys for Patent Owner
` 1101 King Street
` Alexandria, VA 22314
` BY: TERESA SUMMERS, ESQ.
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` SAN FRANCISCO, CALIFORNIA;
` FRIDAY, FEBRUARY 3, 2017; 9:24 A.M.
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` VIVEK SUBRAMANIAN, Ph.D.,
` having first been duly sworn, testified as
` follows:
`
` EXAMINATION
`BY MS. SUMMERS:
` Q. Good morning. My name is Teresa Summers,
`and I'm the attorney for UUSI, Incorporated, doing
`business as Nartron.
` A. Good morning.
` Q. You understand that you are under oath and
`you must answer accurately and truthfully like in
`court?
` A. Yes, I understand that.
` Q. And have you been deposed before?
` A. I have.
` Q. Roughly how many times?
` A. Several tens of times.
` Q. Okay. So you're very familiar with the
`depo basis?
` A. Yes.
` Q. So basically, we'll have to talk one at a
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`Page 5
`time, and counsel may object, but you still have to
`provide an answer.
` Can you testify accurately today?
` A. I believe so.
` Q. Are you on any medication?
` A. I'm not.
` Q. Is there anything that would impair your
`ability to testify fully and accurately today?
` A. No, not that I'm aware of.
` Q. And please tell me if you do not understand
`a question. I will try to clarify.
` A. I'll do that.
` Q. And we can try to take a break about every
`hour and a half or so, but if you need to take a
`break, just let me know.
` A. I'll do that.
` MS. SUMMERS: Could you please mark this as
`2007.
` (UUSI Exhibit 2007 was marked for
` identification)
`BY MS. SUMMERS:
` Q. We've just handed you a document that's
`been marked Exhibit 2007.
` Have you seen this document before?
` A. I don't think so.
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` Q. This is your notice of deposition that was
`filed in the case.
` Do you understand that you are here to
`testify in the matter that's captioned on page 1 of
`Exhibit 2007?
` A. Yes.
` Q. Okay. How have you prepared for your
`deposition?
` A. In preparation for my deposition, I
`reviewed several materials, including my declaration
`that I provided in this matter, and all the
`materials that I listed as materials considered
`while preparing for that, and I had a couple of
`meetings with counsel.
` Q. And roughly how many hours did you spend
`preparing for your deposition?
` A. Overall, probably less than 30 hours over
`the course of the last week or so.
` Q. You mentioned you met with your attorneys.
`Did you meet with anyone else in preparation for
`your deposition?
` A. No.
` Q. Did anyone assist you in creating your
`expert declaration that you stated that you
`reviewed?
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` MR. BANSAL: Objection; form.
` THE WITNESS: Could you clarify what you
`mean by that?
`BY MS. SUMMERS:
` Q. Did anyone assist you in creating the
`expert declaration that you submitted in this case?
` A. If you're asking me besides having
`discussion with counsel, the answer is no.
` Q. How much time, roughly, did you spend in
`total preparing your expert declaration that you
`submitted in some case?
` A. I'm afraid I don't remember.
` Q. Please briefly describe your educational
`background?
` A. Certainly. I have a Ph.D. I received my
`bachelor's of science in electrical engineering from
`Louisiana State University in 1974. I received my
`master's of science, also in electrical engineering,
`from Stanford University in 1996, and I received my
`Ph.D., also in electrical engineering, from Stanford
`University in 1998.
` Subsequent to that, I was a visiting
`research engineer, which is sort of like a postdoc,
`at University of California Berkeley up through
`2000, also in electrical engineering.
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` Q. Did you go directly -- in between your
`bachelor's degree and your Ph.D., did you have any
`work experience in between that?
` A. I did, but while being enrolled as a
`student.
` Q. And what was that work experience?
` A. I had several jobs through the course -- so
`between my bachelor's and my Ph.D. First, I was a
`research assistant at Stanford University. A
`research assistant is a job at Stanford that is
`essentially focused on performing scientific
`research.
` Q. And what were you researching?
` A. I was researching various aspects of
`electronics technology, including topics that I have
`listed in my declaration related to the technology
`underlying this matter.
` I was also, for at least one period, a
`teaching assistant, where I was an instructor for a
`lab class, and then I was also employed as an
`engineer at Motorola.
` Q. And what did you do in your job at
`Motorola?
` A. At Motorola I worked on advanced transistor
`technologies.
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`Page 9
` (Samsung Exhibit 1001 previously marked for
` identification and referenced herein)
`BY MS. SUMMERS:
` Q. I'm handing you what's already been marked
`as Exhibit 1001.
` A. Thank you.
` Q. Have you seen this document before?
` A. Yes.
` Q. What is it?
` A. This is U.S. Patent 5,796,183 to Byron
`Hourmand.
` Q. Is this the patent that is the subject of
`the IPR?
` A. Yes.
` Q. What is your understanding as to the
`priority date of this patent?
` A. I understand that the priority date is the
`filing date, which is January 31st, 1996.
` Q. Are you familiar with the term "person of
`ordinary skill in the art"?
` A. Yes.
` Q. What is your understanding as to that term?
` A. My understanding is that a person of
`ordinary skill in the art is a term that is used to
`describe the qualifications of someone who would be
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`in a position to have the necessary experience and
`expertise to evaluate, for example, the technical
`content of the patent specification.
` Q. And are you aware that the term "person of
`ordinary skill in the art" is sometimes a brief it
`as POSA or POSITA? Are you familiar with those
`acronyms?
` A. Yes.
` Q. So during this deposition if we use an
`acronym, you'll understand that I mean person of
`ordinary skill in the art?
` A. I'll do my best. If I have a question,
`I'll also attempt to ask for clarification.
` Q. Are you aware that an obviousness
`determination must be made based on what would have
`been obvious to one of ordinary skill in the art at
`the time the invention was made?
` MR. BANSAL: Objection; form.
` Objection; outside the scope of the
`witness' direct testimony.
` THE WITNESS: Given that I have worked on
`other cases, I have seen that certainly in those.
`BY MS. SUMMERS:
` Q. What is your opinion as to the level of
`ordinary skill in the relevant art at the time of
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`the invention underlying the '183 patent?
` A. As I stated in my report, with respect to
`the '183 patent, it's my opinion that a person of
`ordinary skill in the art would have had at least a
`bachelor's of science degree in electrical
`engineering, or equivalent, and at least two to
`three years of experience in the relevant field,
`which would include touch systems technology.
` Q. In your opinion, how does the invention
`described in the '183 patent sense touch?
` MR. BANSAL: Objection; form.
` THE WITNESS: Could you clarify what you
`mean by the question? I'm afraid I don't understand
`the question.
`BY MS. SUMMERS:
` Q. The invention relates to a capacitive
`response electronic switching circuit. Does this
`circuitry sense a user's touch?
` A. With respect to the disclosure of the '183
`patent, that is indeed correct. What is disclosed
`is a system intended to detect a user's touch.
` Q. And could you describe -- one moment.
` We'll get into the -- more of the
`low-level, deep, technical details a little bit
`later in your deposition, but could you give me a
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`high-level summary of how the invention of the '183
`patent detects touch?
` A. Sure. At a high level, the '183 patent
`detects touch based on the effect of the capacitive
`nature of human touch and specific interactions of
`that capacitance with the circuitry disclosed in the
`'183 patent are sensed.
` Q. Would you agree that the '183 patent
`discloses several different configurations?
` MR. BANSAL: Objection; outside the scope
`of the witness' direct testimony.
` Objection; form.
` THE WITNESS: If by that you mean the '183
`patent has several embodiments and variations
`thereof, I think the answer is yes.
`BY MS. SUMMERS:
` Q. Would you please look at the embodiment
`depicted in Figure 11.
` A. I see that.
` Q. Does this depict the circuitry for the
`multiple touch-pad configuration?
` MR. BANSAL: Objection; form.
` THE WITNESS: If by "multiple touch pad"
`you mean each of the structures labeled 900,
`starting at 900-1 through 900nm, are intended to be
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`a touch circuit and that therefore there are
`multiple instances of those, the answer is yes.
`BY MS. SUMMERS:
` Q. And please turn your attention to Figure 4
`of the '183 patent.
` A. I see that.
` Q. What configuration is described in Figure 4
`of the '183 patent?
` A. Figure 4 is specifically described as being
`a block diagram of a capacitive response electronic
`switching circuit constructed in accordance with the
`first embodiment of the present invention. The
`specific region for touch is shown in Figure 4 to
`the right side of it.
` Q. And in Figure 4, the touch pad, is that
`Number 450?
` A. Yes. With respect to what's shown in
`Figure 4, that's correct.
` Q. And there is only one touch pad depicted in
`Figure 4; correct?
` A. There is only one touch pad identified as
`450 in Figure 4.
` Q. Are there any other touch pads, in your
`opinion, in Figure 4 other than 450?
` A. With respect to what's shown in Figure 4,
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`no; it's just the single 450.
` Q. I'd like to turn your attention to column
`11, lines -- starting at around line 6 in the '183
`patent.
` It says:
` "This allows the detection threshold for
` the touched pad to be set well below that
` of an adjacent pad resulting in a much
` lower incidence of inadvertent actuation of
` adjacent touch pads to that of the touched
` pad."
` Do you see that?
` A. Yes, I see that language.
` Q. And what does this mean, in your opinion?
` MR. BANSAL: Objection; outside the scope
`of the witness' direct testimony.
` Objection; form.
` THE WITNESS: I believe this section is
`related to describing the implications of an
`impedance calculation that is shown in column 11.
`That is, if we look at the previous line to the line
`you identified, starting at line 4, it says:
` "In fact, the impedence ratio make exceed
` 10 to 1 as illustrated in the calculation
` below."
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` So this relates to that. And what it goes
`on to say is:
` "This allows the detection threshold for
` the touch pad to be set well below that of
` an adjacent pad resulting in a much lower
` incidence of inadvertent actuation of
` adjacent pads to that of the touched pad."
` So specifically, a consequence of the
`impedence relationships is that it allows the
`detection threshold to be set for that benefit.
`BY MS. SUMMERS:
` Q. I'd like to draw your attention to column
`18. I'm going to read starting at approximately
`line 27, where it says:
` "This allows discrimination between the pad
` that is touched and adjacent pads that
` might be pulled towards ground via the
` connective [sic] path to the touch formed
` by a contaminating film."
` Do you see that?
` A. I think you read that incorrectly. I
`believe you said "connective." It says
`"conductive."
` Q. You're correct. "...conductive path to the
`touch formed by a contaminating film."
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` What does that phrase mean, in your
`opinion?
` MR. BANSAL: Objection; form.
` Objection; outside the scope of the
`witness' direct testimony.
` THE WITNESS: Could you clarify what phrase
`you're referring to since you reread it?
`BY MS. SUMMERS:
` Q. I'm referring to column 18, lines 27 to 33.
` A. So the entire sentence?
` Q. Correct. Yes.
` A. I understand.
` This is in fact referring back to a
`consequence of the previous sentence. Here the
`previous sentence, starting roughly at line 23,
`says:
` "The enhanced sensitivity offered by the
` omissions of any capacitor between the base
` and emitter of the detection transistor 410
` allows the threshold of detection to be set
` much closer to ground than would be the
` case otherwise."
` In other words, it allows you to set a
`lower threshold. And a consequence of that is the
`sentence that you pointed to, in other words, this
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`allows discrimination between the pad that is
`touched and any adjacent pads that might be pulled
`towards ground because of contaminating species.
` MS. SUMMERS: Off the record for a moment.
` (Discussion off the record)
` MS. SUMMERS: Back on the record.
` (UUSI Exhibit 2008 was marked for
` identification)
`BY MS. SUMMERS:
` Q. I'm handing you what's been marked as
`Exhibit 2008.
` A. Thank you.
` Q. Have you seen this document before?
` A. I don't believe so.
` Q. Were you aware that the Board issued a
`determination regarding the institution of the IPR?
` A. Yes, I have heard that.
` Q. From whom did you hear that?
` A. Counsel mentioned it to me.
` Q. Are you aware that the Board's
`determination was, in fact, to institute the IPR on
`certain of the claims?
` A. Yes.
` Q. Are you aware that the Board construed
`certain of the claims?
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` A. I'm not aware of any details related to
`that. In general, I know that when the Board
`institutes a decision they typically do construe the
`claims, but I don't have any specifics in relation
`to this decision.
` Q. I'd like to draw your attention to page 15
`of the Institution Decision. There is a section
`beginning on page 15 that is Section B1. It's
`talking about the obviousness of claims 37 to 39.
` Are you aware that the board did not
`institute the IPR on those claims?
` MR. BANSAL: Objection; form.
` THE WITNESS: I believe that had been
`mentioned to me by counsel.
`BY MS. SUMMERS:
` Q. I'd like you to take a moment and look at
`page 15 and let me know your understanding of how
`the board construed the supply voltage limitation of
`claim 37.
` MR. BANSAL: Objection; form.
` Objection; outside the scope of the
`witness' direct testimony.
` THE WITNESS: (Witness reviewing document.)
` I assume you're referring to the last
`complete section of page 15, which reads:
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` "As discussed above, one of ordinary skill
` in the art would understand the term
` 'supply voltage' in claim 37, read in the
` context of the entire claim, refers to the
` supply voltage of the oscillator."
`BY MS. SUMMERS:
` Q. Are you familiar with the term "guard
`rings" or "guardrails" as used in describing touch
`pads?
` MR. BANSAL: Objection; form.
` THE WITNESS: It would depend on the
`context. I have heard it in certain contexts, but
`without more context, I don't know what you're
`specifically referring to.
`BY MS. SUMMERS:
` Q. Are guard rings or guardrails sometimes
`used to surround a touch pad?
` MR. BANSAL: Objection; form.
` Objection; outside the scope of the
`witness' direct testimony.
` THE WITNESS: I have seen implementations
`where that is done, yes.
`BY MS. SUMMERS:
` Q. And what is the purpose or function of
`those guard rings?
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` MR. BANSAL: Objection; form.
` Objection; outside the scope of the
`witness' direct testimony.
` THE WITNESS: It would depend on the
`context. I can only answer in the context to which
`I have seen them. In those contexts in which I have
`seen them, they are used to improve isolation of the
`sensing pads.
`BY MS. SUMMERS:
` Q. I'd like you to look back at Figure 11 of
`the '183 patent.
` A. I see that.
` Q. Would you agree that there are no guard
`rings depicted in Figure 11 of the '183 patent?
` MR. BANSAL: Objection; outside the scope
`of the witness' direct testimony.
` Objection; form.
` THE WITNESS: (Witness reviewing document.)
` With respect to the description of Figure
`11, all Figure 11 says is that it's a block diagram.
`So to that extent, in a block diagram there is no
`indication one way or another as to the level of
`specificity of that block diagram.
`BY MS. SUMMERS:
` Q. But you would agree that in Figure 11 there
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`are no guard rings depicted in Figure 11?
` MR. BANSAL: Objection; form.
` Objection; outside the scope of the
`witness' direct testimony.
` THE WITNESS: Again, it would depend on the
`level of specificity of that block diagram. I could
`not say. I haven't opined on the level of
`specificity related to that. It does not effect my
`opinions.
` If I choose to draw a block diagram with a
`certain level of specificity, I could indeed draw a
`block diagram without showing guard rings and still
`allow for the presence of guard rings in that
`diagram.
`BY MS. SUMMERS:
` Q. And could you please look back to Figure 4
`of the '183 patent.
` A. I see that.
` Q. Is this also a block diagram?
` A. Yes, Figure 4 is called out as a block
`diagram as well.
` Q. And what is Number 460 in Figure 4?
` A. Figure 4 -- in the description of Figure 4,
`at column 15 number 460 is called out in the section
`at column 15 starting approximately at line 52 as:
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` "Also, positioned on the substrate is a
` guard band, generally shown as 460. Guard
` band 460 is a grid of conductor segments
` extending between adjacent pairs of plate
` members."
` (Samsung Exhibit 1002 previously marked for
` identification and referenced herein)
`BY MS. SUMMERS:
` Q. I'm handing you what's previously been
`marked as Exhibit 1002.
` A. Thank you.
` Q. What is this document?
` A. I believe this is a copy of the declaration
`that I submitted in this matter.
` Q. In preparation for your deposition today,
`did you take some time to review Exhibit 1002?
` A. Yes.
` Q. And in preparation for your deposition
`today, did you also review the declaration of
`Dr. Cairns that was submitted with the Patent Owner
`Preliminary Response?
` A. I would have to look at it to confirm, but
`I don't believe so.
` Q. Did you review the Patent Owner Preliminary
`Response in preparation for your deposition?
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` A. Again, I would have to review to confirm,
`but I don't believe so.
` Q. I'd like to walk through a few paragraphs
`of your declaration and ask you a few questions for
`clarification.
` Let's start with paragraph 25, please.
` A. I have that.
` Q. In this Claim Construction section, you
`address the proposed construction of several claim
`terms. In making these constructions, what standard
`did you take into account for claim construction?
` MR. BANSAL: Objection; form.
` THE WITNESS: Well, to be clear, I didn't
`make these constructions. I'm reciting
`constructions that were provided to me. So,
`therefore, I did not -- at least as far as these
`constructions are concerned, this is what I started
`with.
`BY MS. SUMMERS:
` Q. And throughout your expert report or expert
`declaration, did you -- in the course of evaluating
`the validity of the claims, did you do some claim
`construction analysis?
` MR. BANSAL: Objection; form.
` THE WITNESS: I don't understand what you
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`mean by that question.
`BY MS. SUMMERS:
` Q. When you were reading what the claims say
`as a person of ordinary skill in the art, you must
`have an understanding as to what the claim terms
`mean; correct?
` MR. BANSAL: Objection; form.
` THE WITNESS: In general, yes.
`BY MS. SUMMERS:
` Q. And are you familiar with the standard
`that's called "broadest reasonable interpretation"?
` A. I have heard of that standard, yes.
` Q. Are you familiar with the Phillips standard
`of claim construction?
` A. Yes.
` Q. What is the difference between those two
`standards?
` MR. BANSAL: Objection; outside the scope
`of the witness' direct testimony.
` THE WITNESS: As I understand, Phillips is
`generally -- is somewhat narrower than the broadest
`reasonable interpretation.
`BY MS. SUMMERS:
` Q. And when you were reading and evaluating
`the '183 patent, which standard were you applying?
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` A. With respect to the terms for which
`constructions were provided to me, I started from
`there, so I used those as is. For any other terms
`or any other claim language for which proposed
`constructions were not identified, I used plain and
`ordinary meaning as one of skill in the art would
`use.
` Q. Before going further in your expert
`declaration, I'd like to refresh your memory on some
`of the prior art references.
` (Samsung Exhibit 1007 previously marked for
` identification and referenced herein)
`BY MS. SUMMERS:
` Q. I'm handing you what's been previously
`marked as Exhibit 1007.
` A. Thank you.
` Q. Are you familiar with this document?
` A. Yes.
` Q. What is this document?
` A. This is U.S. Patent Number 5,087,825 to
`Ingraham.
` Q. And is this one of the references that you
`opined in your expert declaration invalidate certain
`claims of the '183 patent?
` MR. BANSAL: Objection; form.
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` THE WITNESS: This is what I identified as
`Ingraham I, which is one of the references that I
`opined provides at least some of the teachings of
`the claims at issue.
`BY MS. SUMMERS:
` Q. What does the term "prior art" mean to you?
` MR. BANSAL: Objection; outside the scope
`of the witness' direct testimony.
`BY MS. SUMMERS:
` Q. Let me rephrase.
` Do you consider Ingraham I to be prior art
`to the '183 patent?
` MR. BANSAL: Objection; outside the scope
`of the witness' direct testimony.
` THE WITNESS: In general, Ingraham
`certainly predates the '183 patent, and given my
`identification of the subject matter, it is my
`opinion, based on the date and the subject matter,
`that this would be prior art.
`BY MS. SUMMERS:
` Q. In your analysis in your expert
`declaration, did you consider references that were
`other than prior art; in other words, did you
`consider references that postdated the patent?
` MR. BANSAL: Objection; form.
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` THE WITNESS: I'm not sure I understand
`what you mean by that. Could you clarify what you
`mean by in my analysis?
`BY MS. SUMMERS:
` Q. So you opined on the validity of the
`patents -- of the claims in the '183 patent;
`correct?
` A. Well, I provide technical bases for finding
`teachings of the claims in certain pieces of art.
` Q. And what determined which pieces of art you
`turned to?
` MR. BANSAL: Objection; form.
` I would caution the witness to not reveal
`any -- the substance of any communications. Please
`answer the question only if you can answer the
`question without revealing any privileged
`information.
` THE WITNESS: Could I have the question
`again, please?
`BY MS. SUMMERS:
` Q. My question was: You opined on the
`validity of certain claims of the '183 patent. And
`how did you make a determination which pieces of art
`you turned to?
` A. With respect to identifying art that I
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`believe teaches various aspects of the asserted
`claims, I looked to art that had the appropriate
`priority date and had the relevant teachings.
` (Samsung Exhibit 1008 previously marked for
` identification and referenced herein)
`BY MS. SUMMERS:
` Q. I'm handing you what has been previously
`marked as Exhibit 1008.
` A. Thank you.
` Q. Have you seen this document before?
` A. Yes.
` Q. What is this document?
` A. This is U.S. Patent Number 4,731,548, also
`to Ingraham.
` Q. Did you rely on this document in forming
`your opinions regarding the validity of certain
`claims of the '183 patent?
` A. This was, indeed, one of the pieces of art
`that I considered in my opinions identifying
`teachings of prior art corresponding to aspects of
`the asserted claims.
` (Samsung Exhibit 1010 previously marked for
` identification and referenced herein)
`BY MS. SUMMERS:
` Q. I'm handing you what's previously been
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`marked as Exhibit 110 [sic].
` A. Thank you.
` Q. Have you seen this document before?
` MR. BANSAL: Teresa, just to clarify the
`record, you meant 1010; right?
` MS. SUMMERS: I'm sorry, 1010, correct.
` THE WITNESS: Yes, I have seen this before.
`BY MS. SUMMERS:
` Q. What is this document?
` A. This is U.S. Patent Number 4,758,735, also
`to Ingraham.
` Q. Is this another piece of art that you
`considered in forming your opinions related to your
`analysis set forth in your declaration?
` A. This was a piece of art that I reviewed as
`part of that analysis.
` Q. With respect to what claim limitations did
`you consider this piece of art?
` MR. BANSAL: Objection; form.
` THE WITNESS: Actually, with respect to the
`'735 Ingraham patent, which I referred to in my
`report as Ingraham III, I merely used it to provide
`further clarification of what I understood to be the
`state of the art. So I didn't specifically use this
`as something I relied on to find a specific
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`limitation of the asserted claims.
` (Samsung Exhibit 1009 previously marked for
` identification and referenced herein)
`BY MS. SUMMERS:
` Q. I'm handing you what's been previously
`marked as Exhibit 1009.
` A. Thank you.
` Q. Have you seen this document before?
` A. Yes.
` Q. What is this document?
` A. Is this U.S. Patent Number 5,594,222 to
`Caldwell.
` Q. Is this another piece of art that you
`relied upon in forming the opinions in your expert
`declaration, Exhibit 1002?
` A. Yes, this is a piece of art that I reviewed
`and relied upon in forming those opinions.
` Q. In your expert report, Exhibit 1002, you
`offered some opinions regarding the motivation to
`combine references.
` Do you recall that?
` A. Could you point me to what you're referring
`to?
` Q. I'll give you one example. We'll go over
`this in more detail later, but I'm just trying to
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`get your understanding of a few things.
` If you could please look at paragraph 46 of
`your expert report.
` A. I see that.
` Q. In this paragraph you opine that "One of
`ordinary skill in the art would have been motivated
`to look to the teachings Caldwell to compliment the
`features described in Ingraham I..."
` That's at the end of paragraph 46. Do you
`see that?
` A. Yes.
` Q. What is -- what is your understanding
`regarding the need for a motivation to combine
`references?
` MR. BANSAL: Objection; form.
` THE WITNESS: As I understand, when one
`looks to combine features disclosed in different
`pieces of art, through the eyes of one of skill in
`the art there should be a motivation for one of
`skill in the art to look to those pieces of art and
`bring them together.
`BY MS. SUMMERS:
` Q. And with respect to the Caldwell-Ingraham
`combination, what is that motivation? What provides
`that motivation?
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