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`DR. THOMAS F. LA PORTA
` UNITED STATES PATENT AND TRADEMARK OFFICE
`- - - - -
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`- - - - -
`BRIGHT HOUSE NETWORKS, LLC
`WIDEOPENWEST FINANCE, LLC
`KNOLOGY OF FLORIDA, INC.
`BIRCH COMMUNICATIONS, INC.,
`Petitioners
`v.
`FOCAL IP, LLC,
`Patent Owner
`- - - - -
`Case IPR2016-01259
`Patent Number: 8,155,298
`Case IPR2016-01261
`Patent Number: 8,457,113
`Case IPR2016-01262
`Patent Number: 7,764,777
`Case IPR2016-01263
`Patent Number: 8,155,298
`- - - - -
`VIDEOTAPED DEPOSITION OF DR. THOMAS F. LA PORTA
`VOLUME I
`February 23, 2017
`State College, PA
`Reported by: Michelle L. Hall
`Job No. 119416
`
`TSG Reporting - Worldwide 877-702-9580
`
`BHN, et al. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2020 - 1
`La Porta Deposition Transcript Vol. I
`IPR2016-01262
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`DR. THOMAS F. LA PORTA
` UNITED STATES PATENT AND TRADEMARK OFFICE
`- - - - -
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`- - - - -
`BRIGHT HOUSE NETWORKS, LLC
`WIDEOPENWEST FINANCE, LLC
`KNOLOGY OF FLORIDA, INC.
`BIRCH COMMUNICATIONS, INC.,
`Petitioners
`v.
`FOCAL IP, LLC,
`Patent Owner
`- - - - -
`Case IPR2016-01259
`Patent Number: 8,155,298
`Case IPR2016-01261
`Patent Number: 8,457,113
`Case IPR2016-01262
`Patent Number: 7,764,777
`Case IPR2016-01263
`Patent Number: 8,155,298
`- - - - -
`VIDEOTAPED DEPOSITION OF DR. THOMAS F. LA PORTA
`VOLUME I
`February 23, 2017
`State College, PA
`Reported by: Michelle L. Hall
`Job No. 119416
`
`TSG Reporting - Worldwide 877-702-9580
`
`BHN, et al. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2020 - 1
`La Porta Deposition Transcript Vol. I
`IPR2016-01262
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`Page 2
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` DR. THOMAS F. LA PORTA
`VIDEOTAPED DEPOSITION OF DR. THOMAS F. LA PORTA
`a witness herein, called by Patent Owner for
`examination, by and before Michelle L. Hall, a
`Registered Merit Reporter and Notary Public in
`and for the Commonwealth of Pennsylvania, at
`the Ramada State College Hotel & Conference
`Center, 1450 South Atherton Street, State
`College, PA, on Thursday, February 23, 2017, at
`9:45 a.m.
` - - - - -
`COUNSEL PRESENT:
`For the Petitioners:
` Christopher Tyson, Esquire
` Patrick McPherson, Esquire
` Duane Morris
` 505 9th Street, N.W.
` Washington, DC 20004
` Sarah Guske, Esquire
` Baker Botts
` 101 California Street
` San Francisco, CA 94111
` Jaspal Hare, Esquire
` Spencer Fane
` 10100 North Central Expressway
` Dallas, TX 75231
` (via teleconference)
` And
` Gardiner Davis, Esquire
` Spencer Fane
` 1000 Walnut Street
` Kansas city, MO 64106
` (via teleconference)
`
`TSG Reporting - Worldwide 877-702-9580
`
`BHN, et al. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2020 - 2
`La Porta Deposition Transcript Vol. I
`IPR2016-01262
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`Page 3
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` DR. THOMAS F. LA PORTA
`COUNSEL PRESENT (CONT.):
`For the Patent Owner:
` John Murphy, Esquire
` Nelson Bumgardner
` 3131 West 7th Street
` Fort Worth, TX 76107
`
` Hanna Madbak, Esquire
` SiberLaw
` 28 W. 44th Street
` New York, NY 10036
`ALSO PRESENT:
`Regis J. (Bud) Bates
`Victoria Ferrandino, Legal Video Specialist
`
`TSG Reporting - Worldwide 877-702-9580
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`BHN, et al. v. FOCAL IP, LLC
`FOCAL IP, LLC EX2020 - 3
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`IPR2016-01262
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` DR. THOMAS F. LA PORTA
` I N D E X
` - - - - -
` WITNESS: DR. THOMAS F. LA PORTA
`
`E X A M I N A T I O N: PAGE
`
`BY MR. MURPHY 7
`
`E X H I B I T S (First Referenced):
`
`EXHIBIT 1001 Patent No. US 8,457,113 B2 37
`June 4, 2013
`EXHIBIT 1002 Declaration of Thomas F. 12
`La Porta in Support of Petition for Inter
`Partes Review of U.S. Patent No. 8,457,113
`EXHIBIT 1004 Patent No. 5,958,016 297
`September 28, 1999
`
`EXHIBIT 1006 Patent No. US 7,764,777 37
`July 27, 2010
`EXHIBIT 1007 Patent No. US 8,155,298 B2 37
`April 10, 2012
`
`EXHIBIT 1010 Notice Regarding Change of 211
`Power of Attorney. Date Mailed:
`09/25/2014. Pages 1 through 88 and
`Pages 1567 through 1569
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` DR. THOMAS F. LA PORTA
`E X H I B I T S (Marked):
`
`EXHIBIT 2010 Patent No. US 6,574,328 B1 214
`June 3, 2003
`EXHIBIT 2011 Exhibit B - Opening 215
`Claim Construction Expert Declaration of
`Dr. Eric Burger
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` DR. THOMAS F. LA PORTA
` P R O C E E D I N G S
` - - - - -
` THE VIDEOGRAPHER: This is the
`start of tape labeled number one of the
`videotaped deposition of Dr. Thomas La Porta in
`the matter of Bright House Networks, LLC, et
`al., versus FOCAL IP, LLC, in the United States
`Patent and Trademark Office before the Patent
`and Trial Appeal Board.
` This deposition is being held at
`1450 South Atherton Street, State College,
`Pennsylvania, on February 23, 2017, at
`approximately 9:45 a.m. My name is Victoria
`Ferrandino from TSG Reporting, and I'm the
`Legal Video Specialist. The court reporter
`today is Michelle Hall in association with TSG
`Reporting.
` The Case numbers are IPR2016-01259,
`IPR2016-01261, IPR2016-01262, and
`IPR2016-01263.
` Will counsel please introduce
`yourself.
` MR. MURPHY: This is John
`Murphy representing the Patent Owner from
`
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`FOCAL IP, LLC EX2020 - 6
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`IPR2016-01262
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`Page 7
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` DR. THOMAS F. LA PORTA
`Nelson Bumgardner. With me, I have Bud Bates,
`who is a consultant for the Patent Owner.
` MR. MADBAK: And Hanna Madbak
`with Siber Law.
` MR. TYSON: This is Chris
`Tyson with Duane Morris for the Petitioners.
` MR. McPHERSON: Pat McPherson,
`Duane Morris, Petitioners.
` MS. GUSKE: Sarah Guske from
`Baker Botts for the Petitioners.
` THE VIDEOGRAPHER: Will the
`court reporter please swear in the witness.
` THE COURT REPORTER: Will you
`raise your right hand, please.
` DR. THOMAS F. LA PORTA
`a witness herein, having been first duly sworn,
`was examined and testified as follows:
` - - - - -
` EXAMINATION
`BY MR. MURPHY:
` Q. Good morning, Dr. La Porta.
` A. Good morning.
` Q. It's lovely to be here on your
`campus of Penn State.
`
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`Page 8
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` DR. THOMAS F. LA PORTA
` A. Almost on my campus.
` Q. I was a Pitt Law School Alumni, so I
`have a little bit of history with Penn State.
` So you understand today that you're
`here to testify regarding the expert reports
`you submitted in these four IPR proceedings?
` A. Yes, I do.
` Q. Just for the record, I just want to
`make sure we're on the same page where I know
`they just introduced it for the court reporter,
`but on behalf of the 85 -- sorry, strike
`that -- 8,457,113 patent, there's IPR2016-01261
`proceeding. You filed an expert report in that
`case; correct?
` A. I don't know the numbers. But, yes,
`for that patent I did file an expert report.
` Q. Right. And there's -- we'll refer
`to that as the '113 patent.
` A. That's fine.
` Q. And then for the 8,155,298 patent,
`you filed two -- you filed one expert report,
`just in two different cases; is that right?
` A. That's correct.
` Q. Because they're identical?
`
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`Page 9
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` DR. THOMAS F. LA PORTA
` A. That's correct.
` Q. And those cases are the 01259 case
`and the 01263 case. And then last, for the
`Patent No. 7,764,777, you filed an expert
`declaration in that 01262 case; correct?
` A. That's correct.
` Q. How did -- when did you originally
`get retained for this case?
` A. I think it was the spring of 2016.
`I forget exactly when, but I think it was the
`spring of 2016. The spring of last year.
` Q. Was this for the IPRs only, or was
`it for another related matter?
` A. It was --
` MR. TYSON: Object to outside
`the scope of his declaration.
` A. It was for the IPRs only.
` Q. Who reached out to you initially?
` A. I don't recall. I mean, I don't
`have 100 percent recall, but I believe it was
`Mr. Tyson.
` Q. So, who are you engaged by in these
`proceedings?
` A. Duane Morris I think is who I signed
`
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` DR. THOMAS F. LA PORTA
`my agreement with.
` Q. You signed one agreement?
` A. That I recollect, yes.
` Q. Do you recall, like, what entities
`you represent?
` A. I represent the -- the Petitioners.
`I'm not sure the relationship with all of them,
`but I -- I represent the Petitioners. I don't
`represent them, but I'm retained by the
`Petitioners.
` Q. Are you retained by anyone else
`besides, like, the named Petitioners?
` MR. TYSON: Object to the
`form.
` A. Not that I know of.
` Q. So, what type of work did you do in
`preparation for preparing your declaration?
` A. I did a lot of reading. I read
`the -- the patents at issue, I read prior art.
`I looked for prior art and read it.
` Q. Did you do any prior art searches
`yourself?
` A. I don't know if I searched. I -- I
`knew of prior art. I knew of -- of documents
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` DR. THOMAS F. LA PORTA
`and papers from the time frame. So in that
`sense, I searched.
` Q. So, you have roughly about 51
`exhibits per IPR. Were all of those exhibits
`presented to you, or did you come up with any
`of those on your own?
` A. If I saw the list, I could give a
`better answer. But my -- my recollection is
`that some of them I came up with on my own.
` Q. So out of everything that you were
`sent and everything that you did in your own
`capacity of trying to find prior art yourself,
`were Archer and Chang the two best references
`you could come up with?
` MR. TYSON: Object to the
`form.
` A. Well, Archer and Chang are the two I
`relied upon the most heavily. So, to that
`extent, they were what I considered to be the
`best for the purposes of the points I was
`trying to make.
` Q. Okay. And for all these exhibits in
`your declarations, did you review every page of
`every exhibit?
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` DR. THOMAS F. LA PORTA
` A. Probably not every page of every
`exhibit.
` Q. Did you review the entire file
`history of the '113 patent?
` A. I probably flipped through it all,
`but I did not study it all or -- or read the
`details of the entire file history.
` Q. What about the file history of the
`'298 patent?
` A. This is probably the same answer.
`This was a while ago. I haven't looked at that
`recently.
` Q. And the same answer for the '777
`patent?
` A. There was one I looked at in more
`detail. Again, in my report, I cite to that
`file history. The file history I cited I
`looked at more in detail. Again, if I had my
`report, I can give you a better answer. I
`don't remember.
` Q. Okay. We will go ahead and
`introduce your report. This is a document
`already in the record. It's Exhibit 1002 in
`Case No. 2016-01261. This is your expert
`
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` DR. THOMAS F. LA PORTA
`report for the '113 patent.
` A. Thank you.
` MR. TYSON: Thanks.
` Q. Does that look like your declaration
`for this proceeding?
` A. This does.
` Q. So, if you go to Pages 9 and 10,
`that's where the exhibit numbers are with a
`description of each exhibit. Do you recall
`which of these that you found on your own?
` A. Yeah, I can tell you which I
`definitely found on my own.
` Q. Okay.
` A. There may be a couple more that I
`don't remember who -- how I came upon them.
` Q. Okay.
` A. But 1016 definitely was my own.
`1018 through at least 1027 were all my own.
`1030 I believe was my own. 1034, 1035, 1036,
`1037, I believe 1038 through 1045, 1048, 1049,
`1053, and there may have been others on this
`page that were my own. Some of the other ones
`on this page were my own. I don't remember
`which ones.
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` DR. THOMAS F. LA PORTA
` Q. Okay. And if you look at Page 2,
`it's an overview of who's retained you. Are
`those the only Petitioners that -- are those
`the only entities that have retained you in
`this case?
` A. Yes. To my knowledge, yes. I mean,
`that's what I remember.
` Q. At the time when your expert report
`was filed, how many hours had you put into the
`total hours you put into all four of the
`declarations?
` A. This is an estimate. I would say
`order of 50, probably less than 100. Between
`there.
` Q. Between 50 to 100 hours?
` A. That would be my best estimate. I
`really don't remember. It was a while ago.
`But that's my -- thinking back, that's what I
`remember, between 50 and a hundred.
` Q. And since that time until when you
`filed a supplemental declaration; correct?
` MR. TYSON: Object to the
`form. His supplemental expert declaration has
`been expunged from the record, so it's not part
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`of these proceedings.
` A. So, I wrote some rebuttal
`declarations, yes. I don't know if they
`were -- I forget your exact question, if it was
`filed or whatever, but --
` Q. Yeah. How many hours did you spend
`from, like, to prepare that round of expert
`declarations?
` A. On the order of 20 to 30. Again, I
`don't remember exactly.
` Q. What were you asked to do --
` MR. TYSON: Object to --
` Q. -- in preparing those expert
`declarations?
` MR. TYSON: Object to the
`extent it's calling for privileged information.
` A. So, first, which expert declarations
`are we referring to?
` Q. The second filed ones. The
`supplemental ones that you prepared.
` A. I was -- I can tell you what I did.
`I -- I -- I don't remember exactly what I was
`asked to do. I read a rebuttal report of -- of
`Mr. Yates and probably some other documents,
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`and then I just made some -- some points that I
`thought needed clarification.
` Q. Why did you think they needed
`clarification?
` MR. TYSON: Again, I'm going
`to object. This has been expunged from the
`record, so it's outside the scope of his direct
`testimony.
` A. Just that I thought something was
`misunderstood. I -- I tried to provide some
`clarity.
` Q. So it sounds like, if I understand
`correctly, some of the material you prepared in
`your supplemental report you wish you would
`have included in your original report?
` MR. TYSON: Object to the
`form. It calls for speculation.
` A. That's not true. I thought my
`original report was clear and sufficient.
` Q. So why did you need to prepare
`clarifying statements?
` A. If I felt the rebuttal report
`misinterpreted things I wrote, then I tried to
`clarify them. So that's in response to
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` DR. THOMAS F. LA PORTA
`something that happened, not in response to how
`I felt my report was.
` Q. So, in preparing for this
`deposition, how many hours did you spend?
` A. So, just in deposition preparation,
`probably around 30, I would say. Ballpark of
`30.
` Q. Did you look at any other documents
`outside of any exhibits that you filed with
`your declaration in preparing for this
`deposition?
` A. Yes. I re-read Mr. Yates' report,
`and I think that's all I can remember outside
`of what I had prepared.
` Q. Okay. And who did you meet with in
`preparing for this deposition?
` A. I met with the three attorneys here
`(indicating).
` Q. How many days did you spend with
`them?
` A. I spent part of yesterday with them,
`and we had some phone calls.
` Q. When you wrote this report, did you
`have any assistance in writing it?
`
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` DR. THOMAS F. LA PORTA
` A. Yes. There was collaboration with
`the attorneys.
` Q. And which portions did you write and
`which portions did you rely on your attorneys?
` A. Well, I would say I wrote the whole
`thing because I -- every -- everything in here
`is my opinion. Where I got the most help was
`on the legal sections, explaining obviousness
`and -- and things like that is really what I
`relied upon the attorneys to provide the
`material for.
` But everything else I wrote. And I
`wrote -- like I said, I consider myself writing
`the whole thing because I read the whole thing
`and approved everything. But that's the main
`section where they -- they provided guidance
`was the legal section.
` Q. Did you communicate with any other
`of the expert declarants in any of the other
`related proceedings?
` A. No.
` Q. So tell me about your time at Bell
`Labs. When did you start there?
` A. So, I'm going to turn to my resumé.
`
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` DR. THOMAS F. LA PORTA
` Q. Okay.
` A. Is it in here? I don't think it's
`in here.
` MR. TYSON: It's an exhibit;
`so --
` A. I might have it in my text. I can
`look. I mean, it depends --
` Q. Yeah, I think you do have some
`overview of it in here somewhere.
` A. It depends on how precise you want.
` Q. Your career starting on Page 4 it
`looks like.
` A. When I started in 1986, if I
`remember correctly -- yes, I started in 1986 --
`and I left there in 2002.
` Q. What made you leave?
` A. I just came to Penn State. I wanted
`to do something different.
` Q. So, walk me through, kind of, what
`some of your roles were from '86 to 2002 as you
`advanced in your career there and what type of
`technology you were working on.
` A. Sure. So, in 1986, when I started,
`I was still going for my Master's degree at
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` DR. THOMAS F. LA PORTA
`Cooper Union, but I was working at Bell Labs
`full time. And I was working on data
`networking and testing how other vendors'
`equipment worked with the AT&T network, making
`sure they worked correctly, had the proper
`performance; did some support for customers
`that -- that had equipment that didn't belong
`to AT&T that were having problems. You know, I
`helped them configure it.
` At some point I -- probably 1990 --
`I started to do my Ph.D. at Columbia
`University, and I went into Bell Labs research
`at that point. And at that point, I was
`working on high-speed protocols for multimedia
`communication. That was what my thesis was on.
` In '93 is when I really started
`working very heavily on telecommunications
`networks in terms of voice networks and
`integrated networks, broadband networks. And I
`focused very heavily on signaling and control
`of these networks.
` Probably around the '94-'95 time
`frame, I started working on mobile networks and
`wireless networks with the same type of
`
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` DR. THOMAS F. LA PORTA
`technology. At that point, I led many
`different projects.
` In -- in '97, I became a director of
`the mobile networking research department.
`This department really, generally speaking,
`focused on two different areas. One was pure
`mobile data, mobile data networking. The other
`was more cellular communications, more
`telephony based and integrated telephony data
`based, working a lot on cellular.
` Q. When you say you were working on
`signaling and cellular, what do you mean? Were
`you programming, or were you working on the
`switches?
` A. We were working on everything from
`the control that would occur in the devices
`through the control of many of the different
`elements inside the cellular networks and
`telecommunications networks and data networks,
`broadband networks.
` So we looked at different
`architectures for the networks, we looked at
`how to deploy or implement different
`architectures in the context of existing
`
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` DR. THOMAS F. LA PORTA
`networks. We looked at new architectures, new
`protocols, new algorithms for emerging
`networks; looked at migration paths from
`existing technology to the new technology.
` We looked at new software
`architectures for building network elements
`that would increase flexibility. We looked at
`messaging technologies and other different
`applications in broadband, digital, wired
`networks, and cellular communication networks.
` And if you look at my report, it
`just says a couple of the highlights. We
`worked on the home location register, or
`technology around that. It became Lucent
`Technologies' home location register that they
`ended up selling.
` Some of our technology got put into
`the third-generation network access
`controllers. Some of our technology got put
`into what they called soft switches at the
`time, which were, sort of, Internet telephony
`servers.
` So we worked really end to end. I
`mean, I had people that were programming cell
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` DR. THOMAS F. LA PORTA
`phones for prototypes, to people that were
`programming, you know, the large network
`equipment prototypes.
` Q. Did you ever work on the tandem
`switch?
` MR. TYSON: Object to the
`form.
` A. I understand tandem switch has a
`meaning inside this -- these proceedings. So I
`would have to ask you, you know, in what
`context you mean.
` Q. In the context of not looking at any
`of these -- not looking at the patents-in-suit,
`only understanding what a POSA, person of
`ordinary skill in the art, you know, throughout
`your time frame there would understand a tandem
`switch.
` MR. TYSON: Object. It's
`outside the scope of his declaration.
` A. So what I would like to do is, I
`guess to answer that, I believe I give an
`understanding of what I say a tandem switch is
`somewhere here in my report. Yeah.
` So, basically, you know, my
`
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` DR. THOMAS F. LA PORTA
`understanding of a tandem switch in general
`is -- is really it's a switch that's used to
`connect edge switches or other switches to each
`other. Okay? So it's -- it's -- that --
`that's basically what I consider a tandem
`switch. And, yes, I did work on switches like
`that when I was at Bell Labs.
` Q. Did you work on edge switches?
` MR. TYSON: Object to the
`form.
` A. So, again, I define edge switches
`here because I understand edge switches also
`has a meaning within the patents. But in my
`technology tutorial, I believe I talk about
`edge switches in the context of the PSTN. Yes.
` So the edge switches, again, what
`I'll -- what I'll -- to give context to your --
`my answer is they were the switches that
`connected end-user devices to the network, and
`they connected to either other tandem switches
`or edge switches. And, yes, I did work on
`switches like that as well.
` Q. Did you work on the advanced
`intelligent network?
`
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` DR. THOMAS F. LA PORTA
` A. Yes, I did work on technology
`related to the advanced intelligent network.
` Q. Did AT&T ever roll out the advanced
`intelligent network?
` MR. TYSON: Object to the
`form.
` A. Well, advanced intelligent network
`at some point became a marketing phrase. But,
`yes, AT&T did roll that out and did participate
`actively in its standards, as did Lucent
`Technologies.
` Q. But the advanced intelligent network
`was a failure; wasn't it?
` MR. TYSON: Object to the
`form.
` A. I would not characterize it as a
`failure, but I'm not a marketing or business
`person, so I don't know what their business
`objectives were. But I would not consider it a
`failure, no.
` Q. But the idea of the advanced
`intelligent network never came to fruition, did
`it?
` MR. TYSON: Object to the
`
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` DR. THOMAS F. LA PORTA
`form. Calls for speculation.
` A. I disagree that it didn't come to
`fruition. I think there were -- again, I can
`look at my technology tutorial, and I think I
`talked about some of the motivation of the
`advanced intelligent network, and -- and I
`think it was successful in many ways. Yeah.
` Basically, the goal was to form --
`to formalize the distributor architecture that
`-- that AT&T had been building for a while.
` Q. Where are you reading at right now?
` A. Looking at Paragraph 61 of my
`report. You know, its goal was, as I wrote
`here, to achieve things like rapid and uniform
`implementation of the technology features. The
`goal was really to have a standard of features
`and interfaces and protocols to these different
`features so there could be a multi-vendor
`environment for introducing these new features.
`And to that extent, I think it was -- it was
`successful.
` Q. And you would agree that there are
`definitely parts of the advanced intelligent
`network that were never implemented?
`
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` DR. THOMAS F. LA PORTA
` MR. TYSON: Object to the
`form. Can you repeat the question? I missed
`it.
` A. I actually -- I actually didn't
`understand the first phrase you used. I heard
`the second part of the question, but I didn't
`under -- hear the first phrase you used.
` Q. And would you agree that there are
`definitely parts of the advanced intelligent
`network that were never implemented?
` A. I am not certain of that. There may
`be parts of the IN standard that were not
`implemented. It's very likely. There are
`parts of every standard that don't get
`implemented. But the basic architecture was
`implemented.
` Q. So, if the literature talks about
`the AIN being impossible to implement, would
`that literature be wrong or how would you
`characterize that?
` MR. TYSON: Object to the
`form.
` A. I would have to see the literature
`and see the context in which they said it was
`
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` DR. THOMAS F. LA PORTA
`impossible to implement.
` I know for a fact that that -- some
`of the things that were going into the
`standards were implemented already. That's the
`way standards work. Very often companies have
`things implemented, and they try to get them to
`be part of a standard, so they comply with the
`standard before it's done. So there were
`definitely parts of the AIN that were
`implemented.
` Q. At your time at AT&T or Bell Labs,
`did you ever work on anything of applying call
`features at the tandem level?
` MR. TYSON: Object to the
`form.
` A. I did.
` Q. What was that?
` A. So, we were looking at a couple
`things. We were looking at, just generally,
`the way signaling worked in the tele-
`communications network and then the way it
`worked in the cellular network, and we proposed
`different architectures to allow services to be
`offered from within the network.
`
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` This was one of the goals of AT&T.
`At the time I worked for AT&T, they did not
`have the local companies under their control
`anymore, so they wanted to be offered new
`services from inside the network. So we did
`look at architectures for doing that.
` And then much of the work I did on
`control of these networks was directed at
`control from inside the network at switches
`that were interconnecting switches like tandem
`switches.
` Q. And why didn't you cite to any of
`that literature in your report?
` MR. TYSON: Object to the
`form.
` A. Well, I believe some of my exhibits
`cover some of those patents, actually. I don't
`remember my patents' content perfectly, but I
`do believe some of these patents were on the
`distributed call processing architectures we
`worked on, and in my CV, I list all my papers.
`There were papers where we did discuss some of
`these -- these things.
` So, in my report they may very well
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`IPR2016-01
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