JOHAN EMIL VIKTOR BJORSELL 3/24/2017
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
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` APPLE INC.
`
` )
`
` Petitioner, )
`
` v.
`
` ) CASE NO.: IPR2016-01198
`
` VoIP-PAL.COM, INC.
`
` ) Patent 9,179,005
`
` Patent Owner. )
`
` _______________________ )
`
` The discovery deposition of JOHAN EMIL VIKTOR
`
`BJORSELL, taken in the above-entitled cause, before Alyssa
`
`Fontaine, official reporter, on the 24th of March, 2017,
`
`1055 W Georgia St, Vancouver, BC V6C 2L1
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
`
`IPR2016-01201
`Apple EX1012 Page 1
`
`
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
` APPLE INC.
`
` )
`
` Petitioner, )
`
` v.
`
` ) CASE NO.: IPR2016-01198
`
` VoIP-PAL.COM, INC.
`
` ) Patent 9,179,005
`
` Patent Owner. )
`
` _______________________ )
`
` The discovery deposition of JOHAN EMIL VIKTOR
`
`BJORSELL, taken in the above-entitled cause, before Alyssa
`
`Fontaine, official reporter, on the 24th of March, 2017,
`
`1055 W Georgia St, Vancouver, BC V6C 2L1
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
`
`IPR2016-01201
`Apple EX1012 Page 1
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`JOHAN EMIL VIKTOR BJORSELL 3/24/2017
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`Page 2
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`APPEARANCES:
`
` ERISE IP
`
` 5600 Greenwood Plaza Blvd.
`
` Suite 200
`
` Greenwood Village, CO 80111
`
` (720) 689-5441
`
` BY: MR. PAUL HART
`
` On behalf of the Petitioner;
`
` KNOBBE, MARTENS, OLSEN & BEAR, LLP
`
` 2040 Main Street, 14th Floor
`
` Irvine, CA 92614
`
` (858) 707-4000
`
` BY: MR. KERRY TAYLOR (by phone)
`
` On behalf of the Patent Owner.
`
`ALSO PRESENT:
`
` David Gileff
`
` Adam Seitz (by phone)
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`Fax: 314.644.1334
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`IPR2016-01201
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`JOHAN EMIL VIKTOR BJORSELL 3/24/2017
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` I N D E X
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`Page 3
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`INDEX OF EXAMINATIONS
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`EXAMINATION PAGE
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` By Mr. Hart 4
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` By Mr. Taylor 148
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` By Mr. Hart 165
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` E X H I B I T S
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`NUMBER DESCRIPTION PAGE
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`Exhibit 1001: United States Patent 17
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`Exhibit 2017: System architecture diagram 33
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`Exhibit 2014: Source code for the RBR server 43
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`Exhibit 2015: SVN log messages 45
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`Exhibit 2012: Declaration of Mr. Bjorsell (005) 51
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`Exhibit 2016: Declaration of Mr. Mangione-Smith 149
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`Exhibit 2012: Declaration of Mr. Bjorsell (815) 151
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`Exhibit 011/1007: Handwritten note by Mr. Bjorsell 173
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`Fax: 314.644.1334
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`IPR2016-01201
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`JOHAN EMIL VIKTOR BJORSELL 3/24/2017
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`Page 4
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` VANCOUVER, BRITISH COLUMBIA, CANADA
`
` MARCH 29, 2017
`
` *****
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` JOHAN EMIL VIKTOR BJORSELL,
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`called as a witness, having been first affirmed, was
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`examined and testified as follows:
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` EXAMINATION
`
`BY MR. HART:
`
` Q. Good morning. Can you please state your full
`
`name for the record.
`
` A. My full name is Johan Emil Viktor Bjorsell.
`
` Q. Okay. Have you been disposed before?
`
` A. No.
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` Q. Let me go over some ground rules. My job today
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`is to ask good questions. If for any reason you don't
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`understand part of my question, please let me know. If
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`you answer my question, I'm going to assume that you
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`understood it; is that fair?
`
` A. Yes.
`
` Q. Okay. The two most important rules today are for
`
`the court reporter. Number one is we can't talk over each
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`other. She can only take down one person at a time. I'll
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`do my best to not speak over you but just keep that in
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`mind as we are going through. Second, audible answers,
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`Fax: 314.644.1334
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`JOHAN EMIL VIKTOR BJORSELL 3/24/2017
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`Page 5
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`yeses and nos, no head nods or shakes.
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` A. Okay.
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` Q. All right. Very good. Let's get rolling here.
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`Can you describe your post high school education for me?
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` A. Yeah, I'm self taught. So after high school in
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`Ireland, I went into the industry. I worked at several
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`startups so my education is mostly practical, on the job
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`and self taught.
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` Q. Okay. Any degrees or certifications since high
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`school?
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` A. No.
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` Q. Can you walk me through your work history after
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`high school when you joined the industry.
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` A. Yes, so -- well, during high school, I had some
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`programmer jobs and system administration jobs dealing
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`with, sort of, system engineering and servers and such.
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`And then when I graduated high school, some of that turned
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`into a startup in London. And then I moved back to
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`Ireland, worked a few different consultancy jobs, again in
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`software development and systems engineering.
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` Q. Can I break in here. When did you graduate high
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`school?
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` A. So I think that would have been 2009 [sic].
`
` Q. Okay. And did you go to London to join the --
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` A. Sorry, not 2009. I'm off by a decade. So I
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`JOHAN EMIL VIKTOR BJORSELL 3/24/2017
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`would have graduated in 1999, I believe.
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` Q. Okay. And did you move to London to begin
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`working with the startup you mentioned in 1999?
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` A. I think that would have been in -- probably in
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`Page 6
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`2000 or 2001.
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` Q. Okay.
`
` A. I couldn't remember precisely.
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` Q. What was the name of that startup in London?
`
` A. Caint, C-a-i-n-t.
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` Q. What was your title -- sorry, could you spell the
`
`name of the company one more time?
`
` A. C-a-i-n-t.
`
` Q. Caint?
`
` A. Yes, it's some Irish meaning.
`
` Q. What was your title at Caint?
`
` A. I believe it was IT manager, I think.
`
` Q. What were your responsibilities as an IT manager
`
`at Caint?
`
` A. Well, the operational aspects of our servers, so
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`server provisioning, patch management, configuration
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`management, and also testing, especially in relation to
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`some of our client projects such as testing fuctionality
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`of the systems our team developed.
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` Q. Okay. What kind of systems did your team develop
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`at Caint?
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`Fax: 314.644.1334
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`JOHAN EMIL VIKTOR BJORSELL 3/24/2017
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`Page 7
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` A. There is a -- one example would be an online
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`portal for repatriating for British citizens repatriating
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`back to the UK. So sort of helping them set up, get a
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`cellphone, temporary accomodation, nanny care, for all of
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`that type of stuff to make it easier for them to move
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`back.
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` Q. I see. Any other examples that you can recall?
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` A. Yeah, there was also a project for a recruitment
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`website so it was a recruitment database. A lot to do
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`with matching and skills and things like that.
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` Q. I see. Any telephony-related projects at Caint?
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` A. No, not there.
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` Q. Okay. Did you write any functional source code
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`for any of the projects at Caint?
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` A. Yes, I would have.
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` Q. Okay. And what types of functional source code
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`did you write there?
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` A. There was some -- there would have been -- so
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`source code relating to help manage deployments and
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`configuration management and there would also have been
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`source code written for functions related to the
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`recruitment database that I mentioned and also I wrote
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`code for the messaging system that we had on the
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`repatriation part.
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` Q. Okay.
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`www.midwestlitigation.com
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`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`JOHAN EMIL VIKTOR BJORSELL 3/24/2017
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`Page 8
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` A. Yes.
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` Q. And when did you leave Caint?
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` A. I couldn't think of the date right now but it was
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`probably '02 or '03 I moved back to Ireland. I continued
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`working with them on a consulting basis for quite some
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`time after, and on and off a little bit as well, but I
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`moved back to Ireland in '02 or '03.
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` Q. And what was your next employment after Caint?
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` A. I worked for a manufacturing company in Ireland.
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` Q. What was the name of that company?
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` A. It was Ship Co. Sorry, it was Ship Company
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`Limited.
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` Q. And if you recall, when did you start working for
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`Ship Co.?
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` A. I worked for that company in my high school years
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`and then when I moved back, I did more work for them as
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`well.
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` Q. Were you ever full-time at Ship Co.?
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` A. Yes.
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` Q. And after Caint, when did you begin working for
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`Ship Co. Full-time?
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` A. Sorry, after Caint, I would have been working as
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`a contractor, so it was one of my jobs. I wasn't working
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`full-time with them at that time, but it was a steady
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`contract.
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`JOHAN EMIL VIKTOR BJORSELL 3/24/2017
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`Page 9
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` Q. Okay. And approximately what time period after
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`you moved back to Ireland after Caint were you working as
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`a contractor for Ship Co.?
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` A. Again, the dates are a bit fuzzy, but between '02
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`and '04.
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` Q. Was your -- what were your responsibilities at
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`Ship Co.?
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` A. I was their IT manager.
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` Q. And what types of things did you do as an
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`IT manager at Ship Co.?
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` A. I upgraded their network to an IP based network.
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`So that was one of the first projects. And then on the
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`back of that, we had an old PBX system that was out of
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`maintenance, so I set up a voice over IP system to replace
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`the aging telephony system there.
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` Q. Was any part of the whole PBX system used with
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`the VOIP system that you set up?
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` A. No, they were separate.
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` Q. And did you take down the PBX system while you
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`were working on VoIP or were they up in parallel at some
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`point?
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` A. Well, when I developed, set up, and went through
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`testing of the new system, I did it completely separate to
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`the PBX. And then when it came time to switch over, after
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`there was some acceptance testing and so on, we did a
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`MIDWEST LITIGATION SERVICES
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`Fax: 314.644.1334
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`clean switch over on weekends.
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` Q. Did you develop from scratch the VoIP system at
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`Ship Co. Or was there infrastructure provided by a third
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`party?
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` A. There was open source components that I used.
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`And there was some hardware PSTN components I also used so
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`that voice over repeat calls on that network could access
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`the PSTN and then come back again.
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` Q. So you set up your own PSTN media gateways at
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`Ship Co.?
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` A. The media gateway itself was a hardware product
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`that I purchased and I installed and set that up.
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` Q. I see. Where was the PSTN gateway located in the
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`VoIP system you set up at Ship Co.?
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` A. It was located on their premises.
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` Q. Okay. So you were not doing any IP transport for
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`calls that would ultimately get dumped off to the PSTN.
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`Any PSTN destined call would go straight to the PSTN on
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`premises through the gateway; is that correct?
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` A. Well, the call would be initiated from a voice
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`over handset and it would traverse the local network as an
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`IP call and then it would egress out through the PSTN
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`gateway.
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` Q. On premises?
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` A. Yes.
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`JOHAN EMIL VIKTOR BJORSELL 3/24/2017
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` Q. Okay. How long did it take you to develop and
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`deploy the VoIP system at Ship Co.?
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` A. Probably I was working on it for, like, nine, ten
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`Page 11
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`months.
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` Q. Did you have any prior VoIP experience before
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`Ship Co.?
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` A. Not in a professional capacity but as a -- how
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`would you say -- a personal interest. I found it
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`fascinating.
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` Q. Okay. But Ship Co. was your first enterprise
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`VoIP system that you ever worked on; is that correct?
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` A. That would be fair to say, yes.
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` Q. Okay. Of those nine to ten months that you
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`worked deploying a VoIP system at Ship Co., how much of
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`that time period did it take to get an operational system
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`in place, if you recall?
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` A. In terms of -- it was a long time ago. It's
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`definitely hard to say.
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` Q. Sure.
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` A. I would have gotten, like, calls between two
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`handsets, a very basic setup, probably like a couple of
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`weeks or so. But the devil is always in the detail, so
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`getting -- you know, getting all the various cases working
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`correctly to time.
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` Q. Okay. Once you had the hardware for the PSTN
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`MIDWEST LITIGATION SERVICES
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`Fax: 314.644.1334
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`Page 12
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`gateway, if you recall, how long did it take you to place
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`an IP handset to PSTN telephone call?
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` A. It took a while because the PSTN hardware was
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`pretty mediocre. It didn't work and it took a lot of --
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`yeah, it took a lot of encouragement to get it to behave
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`the way I wanted it to. So it took a while, yeah.
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` Q. In your experience, had there not been problems
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`with the PSTN gateway hardware you received, would that
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`have been a fairly easy process to get IP to PSTN
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`telephone calls up and running on that system?
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` A. If it works the way I would expect it to work out
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`of the box, then probably would have been easier. Mind
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`you, because of the challenges, it forced me to do a lot
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`of debugging and a lot of exploring like the, you know,
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`the SIP standards and the H.323 standards and how all that
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`sort of stuff works in painful detail. Something I'd
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`never have gone into in that sort of depth.
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` So, you know, it sucked at the time that it
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`didn't work, but it led me down a rabbit hole and I
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`learned a lot about all that stuff, so ...
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` Q. I see. Had you been -- now that you know or have
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`familiarity with SIP standards, H.323 standards from that
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`process, do you think it would have been a much easier and
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`quicker process to get that system up and running today
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`using the same hardware you had at your disposal?
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` A. No, that hardware would probably be pretty
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`obsolete by now. And also, you know, when I -- the way I
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`set it up back then, I probably would do it differently
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`now in that particular case. Yeah.
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` Q. Let me ask you this a different way: I asked a
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`question that I did not intend to ask. Putting yourself
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`back in the 2002, 2003 time frame, when you were working
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`on this VoIP project at Ship Co., had you gone into that
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`project with the knowledge you ultimately gained of SIP
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`and H.323 and all the other VoIP-related standards, would
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`that have been an easier and faster process to get it up
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`and running?
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` A. Yeah, with all hindsight learned and -- it would
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`be easier, yes.
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` Q. So would you say that the project generally for
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`somebody who had already had experience in VoIP with those
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`protocols and with PSTN gateways, would you say that
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`project overall would have been simple or, you know,
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`something that would not require significant
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`experimentation to get working?
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` A. Probably not because the -- I mean the landscape
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`and the open source components that I was using at the
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`time were all quite young, the SIP standard was very young
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`at the time as well, so it -- it was still in its infancy
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`to a certain extent. So it was an exciting time. There
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`was very little known about all that stuff. It would have
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`been easier but it wouldn't have been trivial, I would
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`Page 14
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`say.
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` Q. Okay. Where did you go after Ship Co.?
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` A. So while I had the contract with Ship Co., I also
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`had a contract with T-Systems which was a Swiss company, I
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`believe. And it was part of Daimler Chrysler, an enormous
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`corporation.
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` Q. And about what year did you start at T-Systems?
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` A. I don't know if this is relevant, but it was a
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`subcontract, but the ultimate contractor was T-Systems.
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`And when did I start with them? I think it was late --
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`probably in fall of -- again, I can't be 100 percent but
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`approximately fall of 2002.
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` Q. So your work where T-Systems was the ultimate
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`customer overlapped your VoIP work at Ship Co.?
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` A. Yeah, it was two separate contracts that I had in
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`parallel.
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` Q. Okay. Were you working for a contract company or
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`did you have these contracts independently directly with
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`Ship Co. and --
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` A. They're independent. Directly.
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` Q. What was your -- what were your responsibilities
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`on the T-Systems project?
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` A. I was a software developer.
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` Q. What kind of software did you develop?
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` A. It was a credit card -- sorry, credit rating
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`scoring system for the Swiss market.
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` Q. And how long did you work on the credit rating
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`scoring system for T-Systems?
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` A. I think I worked with T-Systems -- with them for
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`about 12 months, give or take. Maybe two months either
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`side.
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` Q. Did you work on anything else for T-Systems other
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`than the credit rating scoring system?
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` A. No, that was the main focus of it, yes.
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` Q. How large a software development team was working
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`on that credit rating scoring system?
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` A. Direct teammate members in my specific group was
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`four, but in the T-Systems organization, there was a large
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`group with them testing and business analysts and all
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`sorts of different roles.
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` Q. Was it just four of you on your team that
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`actually coded the credit rating scoring system?
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` A. The part that we were responsible for, yes.
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` Q. So this credit rating scoring system was part of
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`a larger system; is that correct?
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` A. Well, T-Systems was an enormous corporation and
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`they had different systems, so, you know, in an
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`enterprise, there's a composition of many, many different
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`Page 16
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`systems and we were responsible for the credit card
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`scoring system. And it was also like a credit card
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`application, like, processing thing, but the core or the
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`interesting part of it was the scoring part.
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` Q. I see. So other people were working on other
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`aspects of this overall credit card system and you were
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`responsible -- your team was responsible for the credit
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`rating portion?
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` A. Yes.
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` Q. Okay. Where did you go after your contract with
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`T-Systems?
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` A. So in 2004, I wrapped up all those contracts
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`mostly and I emigrated to Vancouver, Canada, in March
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`2004.
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` Q. What was your first job in Vancouver?
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` A. It was with the Digifonica team and I started
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`with them in June or July 2004, I think.
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` Q. What was your first title at Digifonica in 2004?
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` A. It was IP Centrex developer.
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` Q. What was your responsibilities as an IP Centrex
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`developer at Digifonica?
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` A. So research and development of a voice over
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`IP system which, like, included testing as well.
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` Q. Okay. And what specific aspects were you
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`researching as an IP Centrex developer?
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` A. Early when I started there was research into how
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`to, like, architect the system, the various components
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`like B2BUA and how to do routing.
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` Q. What about testing? What kind of testing were
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`you doing as an IP Centrex developer?
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` A. Well, I was one of the earlier employees, so it
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`was a very small team, so when I developed or when we
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`developed a feature, we had to test it ourselves. We
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`didn't have a test team at that point that early on when I
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`came there.
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` Q. Okay. How large was the team at Digifonica when
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`you joined in June or July of 2004?
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` A. There was five people, I think, when I joined.
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` Q. Do you remember who those people were?
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` A. Yeah, they're -- conveniently enough it's the
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`five people on the 815 patent.
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` MR. HART: I'll go ahead and introduce this as an
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`exhibit. We'll talk about it a little bit later in
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`detail. I'm handing the witness what is marked
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`Exhibit 1001. And that's from the 815 patent proceeding.
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` (Exhibit No. 1001 was marked for
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` identification and is attached hereto)
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` MR. HART:
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` Q. Mr. Bjorsell, do you see the five named inventors
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`on the cover of Exhibit 1001?
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` A. I do.
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` Q. And are those the five original employees of
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`Digifonica who were there when you joined in June or July
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`of 2004?
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` A. Yes.
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` Q. Okay. First --
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` A. And they're team members so I -- some of them
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`might have been founders, but they're part of the team,
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`they're the people I worked with and they're the people
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`that --
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` Q. I see. The first name is Clay Perreault? Am I
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`pronouncing that correctly?
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` A. As far as I know, yes.
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` Q. What was Mr. Perreault's role at Digifonica back
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`when you joined?
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` A. He was CEO and I think he also had title of CTO.
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` Q. Did Mr. Perreault do any software development or
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`coding?
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` A. He had done coding, but on this -- on what we
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`built, no, he didn't do any coding directly.
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` Q. All right. Next name is Steve Nicholson. What
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`was Mr. Nicholson's role on the team?
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` A. I'm not sure what his title was. He was kind of
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`Clay's right-hand man. He was quite technical in his
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`background, but he also worked with, like, sort of human
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`resources aspect, getting people hired, that sort of
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`thing, yeah.
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` Q. Okay. Fair to say Mr. Nicholson did not code any
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`of the Digifonica system?
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` A. Correct.
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` Q. Okay. Rod Thomson. Do you recall what his role
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`was on the team?
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` A. Yeah, Rod was effectively -- I reported to Rod.
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`So I don't know what his official title would have been,
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`but, I mean, I sort of saw him as the development manager.
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` Q. Okay. Did Rod Thomson do any software
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`development or coding at Digifonica?
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` A. He did -- yeah, he did write some code and things
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`like that, to lesser extents than myself and Fuad, for
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`example, but he was hands on in some of those aspects.
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` Q. Okay. Your name is next and then Fuad Arafa. Am
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`I pronouncing that correctly?
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` A. Yes.
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` Q. You mentioned that you and Fuad did more software
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`development than Mr. Thomson. What was Fuad's kind of
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`overall role on the team?
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` A. He was a software developer.
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` Q. Okay. Would you say you or Mr. Arafa did more
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`coding of the Digifonica system?
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` A. In the early months, I would say it was 50/50 and
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`we worked very closely together and collaborated a lot
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`and, yeah, I would say we wrote about the same amount of
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`code. Yeah, so that's early on that's -- it was about
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`50/50.
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` Q. Okay. And at what point did that change?
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` A. In 2005, I took more of a -- like a system
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`architecture role and I think I sort of got the -- I'm not
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`sure when but I had the title of team lead as well. So I
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`was less directly -- like, writing code directly myself,
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`but I worked closely and did code review and all of that
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`stuff with Fuad.
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` Q. Okay. Was that the -- this focus on system
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`architecture, was that your next transition from IP
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`Centrex developer at Digifonica?
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` A. Yeah, my title changed at some point. I don't
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`recall exactly when but it did.
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` Q. Sometime in 2005?
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` A. I think it was yeah, in late, like, in the fall
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`of 2005 maybe.
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` Q. And was your title systems architect at that
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`transition?
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` A. I think so.
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` Q. And can you -- you kind of gave me a brief run
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`down of what you were doing. Can you give me a more
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`detailed sense of what your roles and responsibilities
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`were as a systems architect.
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` A. So working with the team to understand the -- you
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`know, the various needs of a telephony system and turning
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`those needs or those ideas into an implementation.
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` Q. Were you managing other engineers or developers
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`as part of that systems architect role?
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` A. Well, yeah, as sort of an architect and team
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`lead. So I was managing Fuad, and then there were also
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`other developers and operational -- like, assist admins
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`that I was managing as well.
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` Q. Okay. And at that point when you were managing
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`Fuad and were responsible for the architecture, you
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`were -- is it fair to say you were no longer writing code?
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` A. I was still involved and, yeah, I say I would
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`have written little bits, but it was much less at that
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`point.
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` Q. Okay. How long were you in the systems architect
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`role?
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` A. I don't recall when the titles changed. At some
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`point, like later on, I did change into, like, I think my
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`title changed to director of operations or something. I
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`couldn't tell you exactly when without looking it up.
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` Q. Okay. And what were your new roles and
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`responsibilities as director of operations?
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` A. So roles would have been overseeing testing and
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`deployments.
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` Q. Anything else?
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` A. Also interacting with the development team so it
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`was a close relationship with them as well.
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` Q. Okay. Did you have any other titles at
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`Digifonica?
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` A. I don't think so. There might have been some,
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`like, change at some point but it was -- it didn't really
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`affect me. I was doing my work.
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` Q. Sure.
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` A. I wasn't too fussed about titles.
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` Q. When did you leave Digifonica?
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` A. It was I think 2007. '07 or '08, I think.
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` Q. Okay. Why did you leave Digifonica?
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` A. I was let go. The company basically ran out of
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`money.
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` Q. Do you know whether Digifonica operated for any
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`period of time after you were let go?
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` A. Yes, for a while.
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` Q. Okay. Approximately how long?
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` A. Maybe they lasted six months or something. I'm
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`not sure exactly.
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` Q. And do you know how many employees were still
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`around in that -- through that six-month period after you
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`were let go?
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` A. Maybe -- no, I don't know. Yeah, because I was
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`gone, so I didn't have a head count or anything.
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` Q. Sure. Was it your sense that it was effectively
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`a skeleton crew just trying to stay alive in that time
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`period?
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` A. I think it was a bit more than a skeleton crew.
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`I mean, it was definitely less.
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` Q. Okay. Do you know how many paying customers
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`Digifonica had when you left?
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` A. I don't think any. I think that was the problem.
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` Q. Do you know if it was literally none, or ...?
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` A. I think it might have been literally none.
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` Q. Okay. That is a problem.
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` A. Yeah.
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` Q. Did Digifonica ever have paying customers?
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` A. No, I don't think so, but, again, it wasn't
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`really, like -- that was outside of my purview, so ...
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` Q. But to your knowledge, there was never a paying
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`customer at Digifonica?
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` A. No, I don't think so. It depends as well how you
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`define a paying customer. I mean, I know when we had --
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`when we got credit card billings set up at some point, I
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`signed up and, like, paid for my service, so ...
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` Q. As an employee of Digifonica?
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` A. Yeah. But I did it on my own credit card and
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`stuff, so I pretended to be a customer.
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` Q. If Digifonica was actually charging you for that,
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`would you have stopped them?
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` A. I think I let some charges go through. I don't
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`remember exactly.
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` Q. Okay. Other than employees like yourself, you're
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`not aware of any paying customers for the Digifonica
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`system?
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` A. No, not just like an actual real customer.
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` Q. Are you familiar with the entity of VoIP-PAL.com?
`
` A. Yes.
`
` Q. And do you work for VoIP-PAL?
`
` A. Well, I'm here as part of the deposition and I am
`
`getting paid for my time from VoIP-PAL.
`
` Q. How are you being compensated for your assistance
`
`in this proceeding?
`
` A. Just on an hourly rate.
`
` Q. And what is your hourly rate?
`
` A. It's $120 US per hour.
`
` Q. And are you aware that there is a related patent
`
`infringement lawsuit against Apple?
`
` A. I think that's why we're here, yeah.
`
` Q. Okay. Just for your background, two separate
`
`proceedings right now. There's a lawsuit in federal court
`
`for infringement and then the proceeding we're doing is in
`
`www.midwestlitigation.com
`
`MIDWEST LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2016-01201
`Apple EX1012 Page 24
`
`
`
`JOHAN EMIL VIKTOR BJORSELL 3/24/2017
`
`Page 25
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`the US patent office just in relation to the patents
`
`themselves.
`
` A.
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