(cid:55)(cid:85)(cid:68)(cid:81)(cid:86)(cid:70)(cid:85)(cid:76)(cid:83)(cid:87)(cid:3)(cid:82)(cid:73)(cid:3)(cid:40)(cid:85)(cid:76)(cid:70)(cid:3)(cid:45)(cid:17)(cid:3)(cid:42)(cid:82)(cid:88)(cid:79)(cid:71)(cid:3)(cid:37)(cid:72)(cid:68)(cid:85)
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`(cid:39)(cid:68)(cid:87)(cid:72)(cid:29)(cid:3)(cid:48)(cid:68)(cid:92)(cid:3)(cid:20)(cid:26)(cid:15)(cid:3)(cid:21)(cid:19)(cid:20)(cid:26)
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`(cid:38)(cid:68)(cid:86)(cid:72)(cid:29)(cid:3)(cid:54)(cid:82)(cid:81)(cid:92)(cid:3)(cid:38)(cid:82)(cid:85)(cid:83)(cid:82)(cid:85)(cid:68)(cid:87)(cid:76)(cid:82)(cid:81)(cid:15)(cid:3)(cid:72)(cid:87)(cid:3)(cid:68)(cid:79)(cid:17)(cid:3)(cid:16)(cid:89)(cid:16)(cid:3)(cid:38)(cid:85)(cid:72)(cid:68)(cid:87)(cid:76)(cid:89)(cid:72)(cid:3)(cid:55)(cid:72)(cid:70)(cid:75)(cid:81)(cid:82)(cid:79)(cid:82)(cid:74)(cid:92)(cid:3)(cid:47)(cid:76)(cid:80)(cid:76)(cid:87)(cid:72)(cid:71)(cid:3)(cid:11)(cid:51)(cid:55)(cid:36)(cid:37)(cid:12)
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`(cid:51)(cid:79)(cid:68)(cid:81)(cid:72)(cid:87)(cid:3)(cid:39)(cid:72)(cid:83)(cid:82)(cid:86)
`(cid:51)(cid:75)(cid:82)(cid:81)(cid:72)(cid:29)(cid:3)(cid:27)(cid:27)(cid:27)(cid:16)(cid:23)(cid:22)(cid:22)(cid:16)(cid:22)(cid:26)(cid:25)(cid:26)
`(cid:41)(cid:68)(cid:91)(cid:29)(cid:3)(cid:27)(cid:27)(cid:27)(cid:16)(cid:24)(cid:19)(cid:22)(cid:16)(cid:22)(cid:26)(cid:25)(cid:26)
`(cid:40)(cid:80)(cid:68)(cid:76)(cid:79)(cid:29)(cid:3)(cid:87)(cid:85)(cid:68)(cid:81)(cid:86)(cid:70)(cid:85)(cid:76)(cid:83)(cid:87)(cid:86)(cid:35)(cid:83)(cid:79)(cid:68)(cid:81)(cid:72)(cid:87)(cid:71)(cid:72)(cid:83)(cid:82)(cid:86)(cid:17)(cid:70)(cid:82)(cid:80)
`(cid:44)(cid:81)(cid:87)(cid:72)(cid:85)(cid:81)(cid:72)(cid:87)(cid:29)(cid:3)(cid:90)(cid:90)(cid:90)(cid:17)(cid:83)(cid:79)(cid:68)(cid:81)(cid:72)(cid:87)(cid:71)(cid:72)(cid:83)(cid:82)(cid:86)(cid:17)(cid:70)(cid:82)(cid:80)
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`(cid:58)(cid:82)(cid:85)(cid:79)(cid:71)(cid:90)(cid:76)(cid:71)(cid:72)(cid:3)(cid:38)(cid:82)(cid:88)(cid:85)(cid:87)(cid:3)(cid:53)(cid:72)(cid:83)(cid:82)(cid:85)(cid:87)(cid:76)(cid:81)(cid:74)(cid:3)(cid:95)(cid:3)(cid:44)(cid:81)(cid:87)(cid:72)(cid:85)(cid:83)(cid:85)(cid:72)(cid:87)(cid:68)(cid:87)(cid:76)(cid:82)(cid:81)(cid:3)(cid:95)(cid:3)(cid:55)(cid:85)(cid:76)(cid:68)(cid:79)(cid:3)(cid:54)(cid:72)(cid:85)(cid:89)(cid:76)(cid:70)(cid:72)(cid:86)
`SONY Exhibit 1021
`SONY v. Creative
`IPR2016-01407
`
`

`

` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`1
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`SONY CORPORATION, SONY §
`
`MOBILE COMMUNICATIONS §
`
`(USA) INC., SONY MOBILE §
`
`COMMUNICATIONS AB & SONY § Case Number
`
`MOBILE COMMUNICATIONS INC. § IPR2016-01407
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` Petitioners, §
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`VS. § Patent No. 6,928,433
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` §
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`CREATIVE TECHNOLOGY §
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`LIMITED §
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` Patent Owner.
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` Deposition of
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` ERIC J. GOULD BEAR
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` Georgetown, Texas
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` Wednesday, May 17, 2017
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` 9:06 a.m.
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`Job No.: 142381
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`Pages: 1 - 140
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`Reported by: Micheal A. Johnson, RDR, CRR
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`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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` Deposition of ERIC J. GOULD BEAR, held at
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`the location of:
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` Farney Daniels PC
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` 800 South Austin Avenue, Suite 200
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` Georgetown, Texas 78626
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` (512) 582-2828
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` Pursuant to Notice, before Micheal A.
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`Johnson, Registered Diplomate Reporter and Certified
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`Realtime Reporter.
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`PLANET DEPOS
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`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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`3
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` A P P E A R A N C E S
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` FOR PETITIONERS:
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` Andrew J. Tibbetts
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` Gerald B. Hrycyszyn
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` WOLF, GREENFIELD & SACKS, P.C.
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` 600 Atlantic Avenue
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` Boston, Massachusetts 02210-2206
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` (617) 646-8000
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` atibbetts@wolfgreenfield.com
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` ghrycyszyn@wolfgreenfield.com
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` ON BEHALF OF PATENT OWNER:
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` Michael Saunders
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` FARNEY DANIELS PC
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` 800 South Austin Avenue, Suite 200
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` Georgetown, Texas 78626
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` (512) 582-2828
`
` msaunders@farneydaniels.com
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`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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`4
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` INDEX
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` ERIC J. GOULD BEAR
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` May 17, 2017
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`APPEARANCES 3
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`PROCEEDINGS 5
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` EXAMINATION OF ERIC J. GOULD BEAR:
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` BY MR. TIBBETTS 6
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`CERTIFICATE OF SHORTHAND REPORTER 138
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`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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`5
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` PREVIOUSLY MARKED EXHIBITS
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`NUMBER DESCRIPTION PAGE
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`Exhibit 1001 ......................... 114
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`Exhibit 1013 ......................... 72
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`Exhibit 1014 ......................... 101
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`Exhibit 2007 ......................... 115
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`Exhibit 2014 ......................... 8
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`Deposition of Eric J. Gould Bear
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` PROCEEDINGS
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` ERIC J. GOULD BEAR,
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` having been first duly sworn,
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` testified as follows:
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` EXAMINATION
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` BY MR. TIBBETTS:
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` Q. Morning, Mr. Bear.
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` A. Good morning.
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` Q. Could you please spell your full name for
`
` the record, please?
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` A. E-r-i-c, J-u-s-t-i-n, G-o-u-l-d, B-e-a-r.
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` Q. What's your address?
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` A. 809 Jewell Street, Austin, Texas 78704.
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` Q. You understand we're here to discuss the
`
` inter partes review identified as IPR2016-014707 --
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` sorry, 01407 related to US patent number 6,928,433?
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` A. '433 is in my mind, but the name of the
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` case -- the number of the case is not.
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` Q. If I, today, refer to US patent number
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` 6,928,433 as "the '433 patent," will that be clear
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` to you?
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` A. Yes, it would.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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` Q. I just wanted to go over some ground rules
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` for today's deposition. You understand you're under
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`7
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` oath, correct?
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` A. Yes, I do.
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` Q. You understand that this is a
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` question-and-answer process where your answers have
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` to be audible, correct?
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` A. Yes.
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` Q. You understand that even if your counsel
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` objects to a question, you must answer the question
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` unless your counsel instructs you not to answer?
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` A. Yes.
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` Q. If at any point today I ask you a question
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` and it is not clear to you, please let me know and I
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` will clarify. Okay?
`
` A. Okay.
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` Q. If at any point you need a break, as long as
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` there's no question pending, we'll find a convenient
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` stopping time and give you an opportunity to break.
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` Okay?
`
` A. Thank you.
`
` Q. Have you ever been convicted of a crime?
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`Deposition of Eric J. Gould Bear
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` A. No.
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` Q. Have you ever been convicted of perjury?
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` A. No.
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` Q. Are you under the influence of any
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` medication or any other substance that would prevent
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` you from giving a full, complete and truthful answer
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` to my questions today?
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` A. No.
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` Q. I'm handing you a copy of a document
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` previously marked Exhibit 2014 entitled,
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` "Declaration of Eric J. Gould Bear in Support of
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` Patent Owner Response Pursuant to 37 C.F.R.
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` Section 42.120," dated March 2nd, 2017. Do you
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` recognize this document?
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` A. Yes, I do.
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` Q. What is this document?
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` A. This is my declaration in support of patent
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` owner response in the IPR.
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` Q. Is that your signature on the last page of
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` the document?
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` A. Yes, it is.
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` Q. Today I'll refer to this document,
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`PLANET DEPOS
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`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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` Exhibit 2014, as "your declaration." Is that clear?
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` A. Yes.
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` Q. How many hours did you spend preparing your
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` declaration?
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` A. I don't recall.
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` Q. How many hours did you spend preparing for
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` today's deposition?
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` A. I don't recall specifically.
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` Q. What did you do to prepare for today's
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` deposition?
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` A. I reviewed my declaration -- well, let me
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` back up. Everything I've done in this case has been
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` in preparation for this deposition.
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` Q. What have you done over the past couple of
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` days to prepare for this deposition?
`
` A. I have reviewed my declaration. I have
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` reviewed the '433 patent. I have reviewed select
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` cited prior art, portions of other documents. I've
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` met with counsel.
`
` Q. Who did you meet with to prepare?
`
` A. Michael Saunders.
`
` Q. Great. Did you meet with anyone else?
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`Deposition of Eric J. Gould Bear
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` A. No, I didn't.
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` Q. When you said you "reviewed select cited
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` prior art," which prior art documents were those?
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` A. The Birrell, the Seidensticker and the
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` Proehl.
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` Q. Approximately how many hours did you spend,
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` over the past few days or over the past week,
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` preparing for today's deposition?
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` A. About 20 hours.
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` Q. And your declaration, approximately how many
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` hours did you spend preparing that declaration
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` before its filing on March 2nd?
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` A. I don't recall.
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` Q. Paragraph 2 of your declaration says you
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` were compensated at $480 per hour for your work
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` connected to the declaration; is that correct?
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` A. That's correct.
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` Q. Are you being compensated at $480 for your
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` work -- per hour, sorry, for your work related to
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` today's deposition?
`
` A. Yes, I am.
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` Q. Is $480 per hour your typical rate for work
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`PLANET DEPOS
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`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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` as an expert witness?
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` A. It is.
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` Q. Please turn to paragraph 32 of your
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` declaration. Today when I refer to a "person having
`
` ordinary skill in the art," I'll be referring to
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` this definition at paragraph 32 in your declaration.
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` Okay?
`
` A. Okay.
`
` Q. In your declaration, you use the acronym
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` "POSITA," P-O-S-I-T-A, to refer to this definition
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` in paragraph 32 of your declaration, correct?
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` A. Well, to be clear, I define the acronym in
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` relation to a phrase, "a person of ordinary skill in
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` the art." In the first sentence when I'm talking
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` about Bederson's definition, my definition differs
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` from his. So just because the definition of the
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` term occurs at the first sentence, which is
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` Bederson's, I wouldn't want to be limited to his
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` definition.
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` Q. Okay. Do you use the term "POSITA"
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` elsewhere in your declaration?
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` A. I believe I reference the use of the term.
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`Deposition of Eric J. Gould Bear
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` Q. And when you use it later in your
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` definition, are you using that with the
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` understanding that it refers to the declaration --
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` the definition that you laid out in paragraph 32?
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` A. That was my intent.
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` Q. If I happen to instead use the acronym
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` "POSA," P-O-S-A, today, will you understand that to
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` refer to the definition you used in paragraph 32 of
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` your declaration?
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` A. That will be fine.
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` Q. Has your counsel explained to you, that
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` prior art references should be understood from the
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` perspective of a POSA as of the priority date of the
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` patents?
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` A. Yes.
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` Q. Has your counsel explained to you that a
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` POSA is a hypothetical person?
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` A. Yes.
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` Q. And has your counsel explained to you that a
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` POSA is presumed to be aware of all prior art
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` existing as of the patent's priority date?
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` A. Yes.
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`PLANET DEPOS
`888.433.3767 | WWW.PLANETDEPOS.COM
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`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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` Q. On page 12 of your declaration, you indicate
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` in a footnote that you understand that a
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` reexamination examiner found the priority date for
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` the '433 patent to be December 14th, 1999, right?
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` A. Yes.
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` Q. How long have you been designing user
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` interfaces?
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` A. Since the mid 1980s.
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` Q. Have you designed any interfaces for
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` portable devices?
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` A. Yes, I have.
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` Q. Can you give me an example of a user
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` interface you have designed for a portable device?
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` A. I have designed user interfaces for mobile
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` phones, for example.
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` Q. What does a "portable device" mean to you?
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` MR. SAUNDERS: Objection, form.
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` A. Are you referring to the context of the
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` '433 patent?
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` BY MR. TIBBETTS:
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` Q. The term "portable device," have you heard
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` that term before?
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`PLANET DEPOS
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`Deposition of Eric J. Gould Bear
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` A. I have.
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` Q. What does that mean to you in your
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` experience designing user interfaces?
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` MR. SAUNDERS: Objection, form, foundation.
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` A. It would be helpful to have some context for
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` your question.
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` BY MR. TIBBETTS:
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` Q. You said you've been designing user
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` interfaces since the mid 1980s; is that correct?
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` A. Yes, it is.
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` Q. And you mentioned earlier that you have
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` designed user interfaces for mobile phones, correct?
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` A. Yes.
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` Q. Do you consider a mobile phone to be a
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` portable device?
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` A. Yes, I do.
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` Q. Why do you consider a mobile phone to be a
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` portable device?
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` A. I'm going to come back to the same question.
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` In what context? Because terms, as I understand it,
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` need to be construed in the context of a particular
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` patent and I want to make sure I'm answering
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` accurately.
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` Are you referring to the use of the term
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` "portable" in the context of the '433 patent?
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` Q. I'm referring to the term "portable" in your
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` experience as a user interface designer.
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` MR. SAUNDERS: Objection, form.
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` BY MR. TIBBETTS:
`
` Q. You mentioned a few minutes ago that you
`
` have designed an interface for a mobile phone,
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` correct?
`
` A. Yes.
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` Q. Can you explain that user interface that you
`
` have designed for a mobile phone?
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` MR. SAUNDERS: Objection, form.
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` A. I have designed many different user
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` interfaces for mobile phones.
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` BY MR. TIBBETTS:
`
` Q. When I asked you a moment ago whether you
`
` had designed -- sorry, strike the question.
`
` You mentioned a few minutes ago that you
`
` have designed interface for a mobile phone, correct?
`
` A. Yes.
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` Q. Did you have an example of a user interface
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` for a mobile phone in mind when you answered that
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` question?
`
` A. I actually didn't have a specific one in
`
` mind because there are multiple and I assumed if you
`
` wanted to drill down, we could pick one.
`
` Q. Did you design interface for a mobile phone
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` in the 1990s?
`
` A. I designed user interfaces for hand-held
`
` portable devices in the 1990s. I don't recall
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` specifically mobile phone user interfaces in the
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` 1990s that I was involved with.
`
` Q. So you designed user interfaces for
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` hand-held devices in the 1990s, correct?
`
` A. Yes.
`
` Q. Can you think of an example of a user
`
` interface for a hand-held device that you designed
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` in the 1990s?
`
` A. Yes, I can.
`
` Q. Can you describe the user interface of that
`
` example that you're thinking of?
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` MR. SAUNDERS: Objection, form.
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` A. Yes, I can.
`
` BY MR. TIBBETTS:
`
` Q. Will you please explain that user interface
`
` to us, please.
`
` MR. SAUNDERS: Objection, form.
`
` A. I'm sorry, the one that I'm thinking of
`
` is -- was never released to the public and I'm not
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` at liberty to discuss.
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` BY MR. TIBBETTS:
`
` Q. Have you ever designed any interfaces for
`
` playing music?
`
` A. Yes, I have.
`
` MR. SAUNDERS: Objection, form.
`
` BY MR. TIBBETTS:
`
` Q. Did you design any user interfaces for
`
` playing music in the 1990s?
`
` A. I believe so.
`
` Q. Can you think of an example of a user
`
` interface for playing music that you designed in the
`
` 1990s?
`
` A. Yes, I can.
`
` Q. Can you please explain the user interface of
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` the example you are thinking of?
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` A. I don't recall the specifics of the user
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` interface.
`
` Q. Was the user interface for playing music
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` that you were just thinking of for use with a
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` hand-held device?
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` A. The one I was just thinking of was not.
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` Q. Was it for use -- sorry, strike the
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` question.
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` Was the interface for playing music that you
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` were just thinking of for use with a desktop
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` computer?
`
` A. No, it wasn't.
`
` Q. What type of device was the user interface
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` for playing music that you were just thinking of
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` designed for use with?
`
` A. A set-top box.
`
` Q. Can you please explain what you mean by a
`
` "set-top box"?
`
` A. Generally, a "set-top box," as I'm using
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` that term, refers to a piece of hardware that
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` connects to a visual display such as a television.
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` Q. Did that user interface for use with a
`
` set-top box allow a user to select music to be
`
` played?
`
` MR. SAUNDERS: Objection, form, foundation.
`
` A. Could you repeat the question, please?
`
` BY MR. TIBBETTS:
`
` Q. You mentioned that you designed a user
`
` interface for playing music for use with a set-top
`
` box, correct?
`
` A. Yes.
`
` Q. Did that user interface display music to a
`
` user for selection and playback?
`
` MR. SAUNDERS: Objection, form, foundation.
`
` A. When you use the word "display" music or the
`
` phrase "displaying music," are you referring to the
`
` visual display of information about the music, or
`
` are you referring to the auditory display of the
`
` actual sounds?
`
` BY MR. TIBBETTS:
`
` Q. Did the user interface for use with the
`
` set-top box visually display information to a user?
`
` A. It did.
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`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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` Q. Did the user interface for use with the
`
` set-top box visually display information about songs
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`20
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` to a user?
`
` A. Yes, it did.
`
` Q. Did the user interface for use with a
`
` set-top box allow a user to choose music to be
`
` played?
`
` A. Yes, it did.
`
` Q. Did the user interface for use with a
`
` set-top box allow a user to view a list of music
`
` that the user might choose to play?
`
` MR. SAUNDERS: Objection, form.
`
` A. Could you repeat the question, please?
`
` BY MR. TIBBETTS:
`
` Q. Did the user interface for use with a
`
` set-top box display a list of music?
`
` MR. SAUNDERS: Objection, form.
`
` A. Yes.
`
` BY MR. TIBBETTS:
`
` Q. You mentioned a moment ago, that the user
`
` interface for use with a set-top box allowed a user
`
` to choose music to be played, correct?
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` A. Yes.
`
` Q. How did a user choose music to be played in
`
` that user interface for a set-top box?
`
` A. The work that we're talking about here was
`
` under nondisclosure with a client, and I don't feel
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` comfortable speaking further about the specifics of
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` how it functioned.
`
` Q. Was the user interface for use with a
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` set-top box released to the public?
`
` A. No, it wasn't.
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` Q. Was the user interface for the set-top box
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` released to customers of that client?
`
` A. It was not.
`
` Q. Did you design any user interfaces for
`
` playing music, other than the user interface for use
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` with a set-top box we were just speaking about?
`
` A. Yes.
`
` Q. Can you think of an example of another user
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` interface for playing music, other than the one for
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` use with a set-top box that we were just speaking
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` of?
`
` A. Yes, I can.
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`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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` Q. The example that you're thinking of for --
`
` of a user interface for playing music, was that user
`
`22
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` interface released to the public?
`
` A. I do not know.
`
` Q. The user interface for playing music that
`
` you're thinking of, are you under a nondisclosure
`
` agreement -- sorry, strike the question.
`
` The user interface for playing music that
`
` you are thinking of, are you under any obligation of
`
` nondisclosure not to discuss the details of that
`
` user interface?
`
` A. I believe so.
`
` Q. Can you think of another user interface for
`
` playing music that -- sorry, strike the question.
`
` We have discussed two user interfaces for
`
` playing music so far this morning, correct? Strike
`
` the question.
`
` We have discussed a user interface for
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` playing music for use with a set-top box this
`
` morning, correct?
`
` A. Yes, we have.
`
` Q. And we have briefly discussed another user
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`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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` interface for playing music that you have just said
`
` that you are under a nondisclosure obligation
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`23
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` regarding, correct?
`
` A. Yes.
`
` Q. Other than those two user interfaces, can
`
` you think of another example of a user interface for
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` playing music that you designed?
`
` A. Off the top of my head, I cannot. If you
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` have a copy of my CV, I could glance through it and
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` see if that jogs my memory.
`
` Q. Do you recall designing a user interface for
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` navigating audio content while you worked for Apple
`
` Computer?
`
` MR. SAUNDERS: Objection, form.
`
` A. Yes, I do.
`
` BY MR. TIBBETTS:
`
` Q. Did you design a user interface for
`
` navigating audio content -- sorry, strike the
`
` question.
`
` Did you work for Apple Computer?
`
` A. Yes, I did.
`
` Q. Did you design any user interfaces while you
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` were working for Apple Computer?
`
` A. Yes, I did.
`
` Q. Those user interfaces -- sorry, strike the
`
` question.
`
` The user interface you designed while
`
` working for Apple Computer, did that permit a user
`
` to navigate audio content?
`
` MR. SAUNDERS: Objection, form.
`
` A. The user interfaces I designed while
`
` employed by Apple involved navigating audio.
`
` BY MR. TIBBETTS:
`
` Q. Was the user interface for navigating audio
`
` content that you designed while working for Apple
`
` released to the public?
`
` A. No, it was not.
`
` Q. Are you under any obligations of
`
` confidentiality regarding user interface for
`
` navigating audio content that you designed at Apple
`
` Computer?
`
` A. Of course I am.
`
` Q. Paragraphs 26 to 31 of your declaration are
`
` titled, "The Science of Human-Computer Interaction,"
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` right?
`
` A. Yes.
`
` Q. Paragraphs 26 to 31 of your declaration
`
` describe a scientific approach to user interface --
`
` I'm sorry, strike the question.
`
` Paragraphs 26 to 31 of your declaration
`
` describe a scientific approach to user experience
`
` design, right?
`
` MR. SAUNDERS: Objection, form.
`
` A. The paragraphs from 26 to 31 include a
`
` description of portions of the science of user
`
` experience design.
`
` BY MR. TIBBETTS:
`
` Q. Do you follow the scientific approach?
`
` MR. SAUNDERS: Objection, form, foundation.
`
` BY MR. TIBBETTS:
`
` Q. So paragraphs 26 to 31 of your declaration
`
` include a description of the science of
`
` human-computer interaction, correct?
`
` A. It includes a description of a portion of
`
` such science.
`
` Q. Do paragraphs 26 to 31 of your
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` declaration -- strike the question.
`
` How does a user experience designer use the
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` science of human-computer interaction -- sorry,
`
` strike the question.
`
` Do paragraphs 26 to 31 of your
`
` declaration -- sorry, strike the question.
`
` Do paragraphs 26 to 31 of your declaration
`
` include -- sorry, strike the question.
`
` Do paragraphs 26 to 31 of your declaration
`
` describe an approach to user experience design that
`
` a user experience designer may follow when designing
`
` a user experience?
`
` MR. SAUNDERS: Objection, form, foundation.
`
` A. Yes.
`
` BY MR. TIBBETTS:
`
` Q. Does paragraph 31 of your declaration
`
` include steps of a process for designing user
`
` experiences?
`
` MR. SAUNDERS: Objection, form.
`
` A. I don't know that I would call these
`
` enumerated activities "steps." More like stages of
`
` overlapping or sometimes sequential activities.
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`Deposition of Eric J. Gould Bear
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` BY MR. TIBBETTS:
`
` Q. Do the stages of the process laid out at
`
` paragraph 31 form a part of your understanding of
`
` the science of human-computer interaction?
`
` A. In my opinion, yes.
`
` Q. When you are designing user experiences, do
`
` you follow the scientific method laid out at
`
` paragraph 31 of your declaration?
`
` MR. SAUNDERS: Objection, form.
`
` A. Generally, I would be involved directly or
`
` in managing other people who would follow such
`
` steps.
`
` BY MR. TIBBETTS:
`
` Q. How long have you followed this scientific
`
` method when you were designing user experiences?
`
` MR. SAUNDERS: Objection, form.
`
` A. Since the 1990s.
`
` BY MR. TIBBETTS:
`
` Q. Was this scientific method for designing
`
` user experiences, laid out in paragraph 31 of your
`
` declaration, common among user experience designers
`
` when you started using it?
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`Deposition of Eric J. Gould Bear
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` MR. SAUNDERS: Objection, form, foundation.
`
`28
`
` A. Yes.
`
` BY MR. TIBBETTS:
`
` Q. A short time ago, we were discussing user
`
` experiences you had designed in your career,
`
` correct?
`
` A. Yes.
`
` Q. Did you follow the scientific method of
`
` paragraph 31 when you were designing those user
`
` experiences?
`
` MR. SAUNDERS: Objection, form.
`
` A. Generally.
`
` BY MR. TIBBETTS:
`
` Q. Do you believe a POSA would have been
`
` familiar with the scientific method of paragraph 31
`
` of your declaration around the 1990s?
`
` MR. SAUNDERS: Objection, form.
`
` A. Can you rephrase the question, please?
`
` BY MR. TIBBETTS:
`
` Q. When you started using the scientific method
`
` of paragraph 31 of your declaration -- sorry, strike
`
` the question.
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` You said a moment ago that the scientific
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` method in paragraph 31 was in common use when you
`
` were -- when you first started using the scientific
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` method of paragraph 31, correct?
`
` MR. SAUNDERS: Objection, form.
`
` A. I believe so.
`
` BY MR. TIBBETTS:
`
` Q. Do you believe a POSA would've been familiar
`
` with that scientific method when you started using
`
` it?
`
` MR. SAUNDERS: Objection, form.
`
` A. Yes.
`
` BY MR. TIBBETTS:
`
` Q. The scientific method of paragraph 31 forms
`
` a part of your understanding of the science of
`
` human-computer interaction, correct?
`
` A. Yes.
`
` Q. The scientific method of paragraph 31 forms
`
` a part of your understanding of the science of
`
` human-computer interaction as laid out at
`
` paragraphs 26 to 31 of your declaration, right?
`
` MR. SAUNDERS: Objection, form.
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`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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` A. I'm not sure what the difference between
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` those two questions is.
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` BY MR. TIBBETTS:
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` Q. Paragraphs 26 to 31 describe a part of your
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` understanding of the science of human-computer
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` interaction, correct?
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` A. Yes.
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` Q. And paragraph 31 describes a scientific
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` method to designing user experiences, correct?
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` A. Yes.
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` Q. And the scientific method to designing user
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` experiences of paragraph 31 forms a part of your
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` understanding of the science of human-computer
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` interaction as laid out in paragraphs 26 to 31,
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` correct?
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` A. Yes, it does.
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` Q. At paragraph 28 of your declaration, you
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` cite to Don Norman's work; is that correct?
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` A. Yes, I do.
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` Q. And at paragraph 28 of your declaration, you
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` cite to the work of the special interest group on
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` computer-human interaction, correct?
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`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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` A. I cite to the Association for Computing
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` Machinery's hosting of conferences on human factors
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` in computing systems, if that's what you mean by
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` "work."
`
` Q. In paragraph 28 of your declaration, you
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` refer to the special interest group on
`
` computer-human interaction, correct?
`
` A. Yes.
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` Q. And at paragraph 28 of your declaration, you
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` refer to two ISO standards, correct?
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` A. Yes, I do.
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` Q. Do you believe that Don Norman's work is
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` consistent with your understanding of the science of
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` human-computer interaction?
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` A. Yes, I do.
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` Q. Do you believe that Don Norman's work
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` supports your understanding of the science of
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` human-computer interaction?
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` MR. SAUNDERS: Objection, form, foundation.
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` A. Can you rephrase the question, please?
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` BY MR. TIBBETTS:
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` Q. Do you believe that the two ISO standards
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`

`

`Deposition of Eric J. Gould Bear
`Conducted on May 17, 2017
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