UNITED STATES DISTRICT COURT
` FOR THE EASTERN DISTRICT OF TEXAS
`
`Page 1
`
` CHRIMAR SYSTEMS, INC.,
` et al.,
`
` Plaintiffs,
`
` v. Civil Action No.
` 6:15-cv-00163
` ALCATEL-LUCENT, S.A., et al.,
` Defendants.
`_______________________________
`
` DEPOSITION OF RICH SEIFERT
` Menlo Park, California
` Friday, June 10, 2016
` Volume I
`
`REPORTED BY:
`TAVIA MANNING, CSR No. 13294, CLR, CCRR
`JOB NO. 108691
`
`TSG Reporting - Worldwide 877-702-9580
`
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`Chrimar Systems, Inc.
`Exhibit 2031-1
`IPR2016-00983 USPN 8,155,012
`
`
` FOR THE EASTERN DISTRICT OF TEXAS
`
`Page 1
`
` CHRIMAR SYSTEMS, INC.,
` et al.,
`
` Plaintiffs,
`
` v. Civil Action No.
` 6:15-cv-00163
` ALCATEL-LUCENT, S.A., et al.,
` Defendants.
`_______________________________
`
` DEPOSITION OF RICH SEIFERT
` Menlo Park, California
` Friday, June 10, 2016
` Volume I
`
`REPORTED BY:
`TAVIA MANNING, CSR No. 13294, CLR, CCRR
`JOB NO. 108691
`
`TSG Reporting - Worldwide 877-702-9580
`
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`Chrimar Systems, Inc.
`Exhibit 2031-1
`IPR2016-00983 USPN 8,155,012
`
`
`
`Page 4
`
` MENLO PARK, CALIFORNIA;
` FRIDAY, JUNE 10, 2016; 9:06 A.M.
`
` (Deposition Exhibits 1 through 19 were
` premarked for identification.)
`
` RICH SEIFERT,
` having been first duly sworn by the court reporter,
` testified as follows:
`
` EXAMINATION
`BY MR. COHEN:
` Q. Good morning, Mr. Seifert.
` A. Good morning.
` Q. My name is Justin Cohen. I am representing the
`plaintiffs in this case, ChriMar Systems, Inc. and
`ChriMar Holding Company.
` Are you are familiar with them?
` A. I am.
` Q. Now, you've been deposed numerous times before;
`correct?
` A. Yes.
` Q. Do you know about how many?
` A. Between 10 and 20.
` Q. So you generally understand the process and the
`
`TSG Reporting - Worldwide 877-702-9580
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`Chrimar Systems, Inc.
`Exhibit 2031-2
`IPR2016-00983 USPN 8,155,012
`
`
`
`Page 212
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` Q. In the AUI.
` And where does it have distinguishing
`information associated to impedance?
` A. Well, what distinguish -- the 78 ohms
`distinguishes it from, let's say, a 10BASE-T device,
`which would be 100 ohms.
` Q. But 10BASE-T plugs in with an RJ45 connector;
`right?
` A. Yeah.
` Q. And this plugs in with an AUI cable; correct?
` A. Yeah.
` Q. The 15 pin?
` A. But I don't know that at the other end of the
`cable, for example.
` Q. At the other end of which cable?
` A. Either cable. If I am presented -- if I am
`presented with a cable with -- with pairs of wires, I
`can distinguish among -- among 10BASE-T device --
`between 10BASE-T devices and AUI devices by measuring
`the impedance across selected contacts.
` Q. Can you distinguish 10BASE-T devices from other
`10BASE-T devices using the characteristic impedance?
` A. I don't think that's required by the claims.
` Q. Can you answer my question?
` A. Can I -- ask the question again?
`
`TSG Reporting - Worldwide 877-702-9580
`
`Chrimar Systems, Inc.
`Exhibit 2031-3
`IPR2016-00983 USPN 8,155,012
`
`
`
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`Page 213
` Q. Can you distinguish one 10BASE-T device from
`another 10BASE-T device using characteristic impedance?
` A. Using just the characteristic impedance?
` Q. Yes.
` A. I don't think so.
` Q. Is there another way that you could distinguish
`one 10BASE-T device from another 10BASE-T device based
`on distinguishing information associated to impedance?
` A. Sure.
` Q. How?
` A. I could distinguish a 10BASE-T device that had
`Bob Smith terminations on unused circuits from a
`10BASE-T device that didn't have Bob Smith terminations
`on the unused circuits.
` Q. Is that in your report?
` A. No, but you asked the question and I answered.
` Q. So your opinion is based on the characteristic
`impedance between AUI and 10BASE-T?
` MR. HAWKINS: Objection to form.
` THE WITNESS: I am saying that different
`Ethernet devices can be distinguished by the impedance
`that is used to terminate the lines.
`BY MR. COHEN:
` Q. And when you're talking about different
`Ethernet devices, you're talking about different types
`
`TSG Reporting - Worldwide 877-702-9580
`
`Chrimar Systems, Inc.
`Exhibit 2031-4
`IPR2016-00983 USPN 8,155,012
`
`
`
`Page 214
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`of Ethernet devices; correct?
` A. I am talking about different Ethernet devices.
` Q. But they're different types; correct?
` A. What do you mean by "different types"?
` Q. One is 10BASE-T and one is 10BASE5?
` A. They could both be 10BASE-T.
` Q. But you can't distinguish one 10BASE-T device
`from another 10BASE-T device based on the characteristic
`impedance; correct?
` A. Again, I don't believe that's required by the
`claims. I can distinguish one Ethernet device from
`another Ethernet device based on the impedance.
` Q. This is why I -- I am trying to understand your
`opinions as laid out in C-2.
` And as I read Element 31E, pages 6 and 7 of
`your C-2, what it sounds to me you're saying is that you
`can distinguish a 10BASE5 device from a 10BASE-T device
`based on the characteristic impedance, because a 10BASE5
`device using an AUI cable has a characteristic impedance
`of about 78 ohms, and a 10BASE-T device has a
`characteristic impedance of about 100 ohms; is that
`correct?
` A. Let me read this and make sure that's
`reasonable reading.
` MR. HAWKINS: And before you answer that, I'm
`
`TSG Reporting - Worldwide 877-702-9580
`
`Chrimar Systems, Inc.
`Exhibit 2031-5
`IPR2016-00983 USPN 8,155,012
`
`
`
` DECLARATION UNDER PENALTY OF PERJURY
`
`Page 230
`
` I, RICH SEIFERT, do hereby certify under penalty
`of perjury that I have read the foregoing transcript of
`my deposition taken on June 10, 2016; that I have made
`such corrections as appear noted herein in ink,
`initialed by me; that my testimony as contained herein,
`as corrected, is true and correct.
`
` DATED this day of 2016, at
` , California.
`
` ___________________________
` RICH SEIFERT
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`TSG Reporting - Worldwide 877-702-9580
`
`Chrimar Systems, Inc.
`Exhibit 2031-6
`IPR2016-00983 USPN 8,155,012
`
`
`
`Page 231
`
` REPORTER'S CERTIFICATE
` I, TAVIA MANNING, a Certified Shorthand Reporter
`of the State of California, do hereby certify:
` That the foregoing proceedings were taken before
`me at the time and place herein set forth; that any
`witnesses in the foregoing proceedings, prior to
`testifying, were placed under oath; that a verbatim
`record of the proceedings was made by me using machine
`shorthand which was thereafter transcribed under my
`direction; further, that the foregoing is an accurate
`transcription thereof.
` I further certify that I am neither financially
`interested in the action, nor a relative or employee of
`any attorney of any of the parties.
` Before completion of the deposition, review of
`the transcript [ ] was [X] was not requested. If
`requested, any changes made by the deponent (and
`provided to the reporter) during the period allowed are
`appended hereto.
` In witness whereof, I have subscribed my name
`this 15th day of June, 2016.
`
` ________________________________________
` TAVIA MANNING, CSR No. 13294, CCRR, CLR
`
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`TSG Reporting - Worldwide 877-702-9580
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`Chrimar Systems, Inc.
`Exhibit 2031-7
`IPR2016-00983 USPN 8,155,012
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