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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` CISCO SYSTEMS, INC. AND DISH ) CASE IPR
` NETWORK, LLC ) 2016-01466
` ) Patent No.
` Petitioner, ) 8,611,404
` )
` vs. ) CASE IPR
` ) 2016-01760
` TQ DELTA, LLC, ) Patent No.
` ) 9,094,268
` Patent Owner. )
` )
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` DEPOSITION OF DR. SAYFE KIAEI
`
`
` Phoenix, Arizona
` March 28, 2017
` 8:35 a.m.
`
` *2ND REVISED*
`
`REPORTED BY: Kristy A. Ceton, RPR
`JOB NO: 121017
`
`TSG Reporting - Worldwide - 877-702-9580
`
`TQ Delta Exhibit 2004
`
`Cisco Systems, Inc. v. TQ Delta, LLC
`
`
`IPR2016-01466
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` CISCO SYSTEMS, INC. AND DISH ) CASE IPR
` NETWORK, LLC ) 2016-01466
` ) Patent No.
` Petitioner, ) 8,611,404
` )
` vs. ) CASE IPR
` ) 2016-01760
` TQ DELTA, LLC, ) Patent No.
` ) 9,094,268
` Patent Owner. )
` )
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` )
` DEPOSITION OF DR. SAYFE KIAEI
`
`
` Phoenix, Arizona
` March 28, 2017
` 8:35 a.m.
`
` *2ND REVISED*
`
`REPORTED BY: Kristy A. Ceton, RPR
`JOB NO: 121017
`
`TSG Reporting - Worldwide - 877-702-9580
`
`TQ Delta Exhibit 2004
`
`Cisco Systems, Inc. v. TQ Delta, LLC
`
`
`IPR2016-01466
`
` 1
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`
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`Page 2
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` DR. SAYFE KIAEI
` DEPOSITION OF DR. SAYFE KIAEI
` commenced at 8:35 a.m., on March 28, 2017, at Snell &
` Wilmer, LLP, One Arizona Center, 400 East Van Buren,
` Suite 1900, Phoenix, Arizona, before Kristy A. Ceton,
` RPR, Arizona Certified Court Reporter No. 50200.
`
` * * *
`
` APPEARANCES:
` For the Petitioner:
` HAYNES AND BOONE
` By: John Emerson, Esq.
` David McCombs, Esq.
` Theodore Foster, Esq.
` Michael Parsons, Esq.
` 2323 Victory Avenue
` Dallas, TX 75219
` For the Patent Owner:
` MCANDREWS HELD & MALLOY
` By: Thomas Wimbiscus, Esq.
` Raj Chiplunkar, Esq.
` 500 West Madison Street
` Chicago, IL 60661
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` DR. SAYFE KIAEI
` I N D E X
`
` EXAMINATION BY PAGE
`
` Mr. Wimbiscus............................... 4
`
` EXHIBITS DESCRIPTION PAGE
` Exhibit 2001 U.S. Patent 6,075,814 132
` Figure 4
` Exhibit 2002 U.S. Patent 6,075,814 171
` Figure 4
` Exhibit 2003 CPE Receiver 400/CO 180
` Transmitter document
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` DR. SAYFE KIAEI
` Phoenix, Arizona
` March 28, 2017
` 8:35 a.m.
`
`Page 4
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` SAYFE KIAEI,
` called as a witness herein, having been first duly
` sworn, was examined and testified as follows:
`
` EXAMINATION
` By MR. WIMBISCUS:
` Q. Good morning, Dr. Kiaei.
` A. Yes.
` Q. Would you please state and spell your
` name for the record?
` A. Sayfe, S-a-y-f-e; Kiaei, K-i-a-e-i.
` Q. What is your residence address?
` A. 13325 North Manzanita Lane, Fountain
` Hills, Arizona 85268.
` Q. What is your age?
` A. 57.
` Q. Do you understand that you're here to
` testify with respect to two different IPR
` proceedings; namely, IPR 2016-01466 involving the
` '404 patent, U.S. patent No. 8611404 and IPR
` 2016-014- -- I'm sorry -- IPR 2016-01760 involving
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` U.S. patent No. 9094268?
` A. Yes, I am.
` Q. And if I refer to those patents as the
` '404 patent and the '268 patents, respectively,
` you'll understand what I'm referring to?
` A. Yes, I do, Counsel.
` Q. Thank you.
` A. Thank you.
` Q. Okay. So you've had your deposition
` taken a number of times, I trust?
` A. Yes, Counsel.
` Q. Okay. And I'll just go over the ground
` rules just to make them fresh for you.
` You understand that the court reporter is
` here and you have to answer audibly?
` A. Yes, I do.
` Q. And if you don't understand a question,
` just ask me to repeat it or clarify it and I'll do my
` best to clarify. Okay?
` A. Thank you.
` Q. If you answer the question, I'll assume
` you understood the question. Fair enough?
` A. Okay.
` Q. And I'll try to take periodic breaks,
`
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` DR. SAYFE KIAEI
` maybe every hour or so. If you need a break sooner
` or at some point, let me know. It's not an endurance
` test. All right?
` A. I appreciate it.
` Q. I only ask that you don't take a break
` during the middle of a question. All right?
` A. Understood.
` Q. And do you understand that you cannot
` speak to your counsel during the course of my --
` about the substance of the testimony during the
` course of my cross-examination?
` A. Yes, I do.
` Q. Is there any reason that you couldn't
` testify fully, completely, and accurately today?
` A. No.
` Q. And you're not under any medications or
` anything that would be -- have any impact on that,
` right?
` A. No.
` Q. Okay. Who is paying for your fees?
` A. I get the checks from Haynes and Boone.
` So I don't know exactly. Cisco, I presume.
` Q. Okay. You have submitted a CV, Exhibit
` 1004, in connection with your declarations; is that
`
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` right?
` A. Yes, sir.
` Q. I'll hand you a copy. Is that a copy of
` your current CV?
` A. It's a copy of my CV. It may have been
` updated in the past few months, a few things, but
` nothing major changes.
` Q. Okay. Your CV accurately reflects your
` employment and educational experience?
` A. That is correct.
` Q. Okay. Have you had any work experience
` with multichannel modems or transceivers in a low
` power mode?
` A. Yes, I have.
` Q. Okay. Could you tell me the nature of
` that work?
` A. I was involved with a DSL development at
` Motorola. And part of that involvement was also
` looking at the power and low power implementation of
` the DSL system.
` Q. Okay. And what were the low power mode
` attributes of the system that you were working on
` while at Motorola?
` A. Many aspects of it, including the aspects
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` DR. SAYFE KIAEI
` of looking at a transceiver low power, looking at the
` receiver and transmitter power issues. Any time you
` design, we always are concerned about low power
` issues. Make sure that we address these issues.
` Q. What was the time frame?
` A. The time frame specifically was in the
` late '90s. '97 to -- on the copper bowl, it was '97
` to 2000, I believe.
` Q. Okay.
` A. And also, I was involved with a G.lite,
` which is a low power DSL, specifically to make sure
` the system is in the lowest power implementation in
` the -- I was involved in the committee for that.
` Q. Was that transceiver -- was that a
` transceiver that entered into low power mode in
` connection with that project?
` A. G.lite was a specific DSL that was
` designed to -- to look at issues of power, cost, and
` implementation for the DSL. So it was a subcommittee
` within the T1.14.
` Q. Did the -- in connection with that work
` at Motorola, did the transceiver enter into a low
` power mode?
` A. Which transceiver?
`
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` Q. The -- I'll call it the remote --
` let's -- Withdrawn.
` The -- Is there a CPE transceiver
` involved?
` A. I assume by "CPE," you mean on the
` customer premises?
` Q. Yes.
` A. The modems we designed were both for the
` customer side of the modem as well as for the central
` office, yes.
` Q. And did both of those transceivers enter
` into a low power mode in connection with the work you
` did at Motorola?
` A. That's a very broad question. Can you be
` more specific?
` Q. Did either of the transceivers, the CPE
` or the CO transceiver, enter into a low power mode in
` connection with the work you did at Motorola?
` A. Various components of the CPE and the
` central office side would potentially have moments
` where it could be in low power mode. Yes.
` Q. Was that work commercialized?
` A. To the best of my knowledge, yes.
` Q. In what product?
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` A. I can't divulge the source of where the
` chips were sold. It was Motorola confidential
` information, but they were sold to a number of
` manufacturers that put the copper gold chips inside
` of their products.
` Q. Do you believe that the work you're
` referring to was implemented in the Motorola copper
` gold chips?
` A. The chip itself was called copper gold.
` Q. Right.
` A. And the chip has the system and then it
` would be implemented in a box. Various companies
` purchased it. I don't remember the details of it,
` and even if I did, that's internal Motorola
` confidential information.
` Q. Did copper gold Motorola chip --
` Withdrawn.
` Did the Motorola copper gold chip have a
` low power mode?
` A. I think I already answered that. There
` were moments that various components of the systems
` would be shut down and they would go into low power
` mode.
` Q. That's your recollection?
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` A. That's the best I can remember 20 years
` ago.
` Q. Now, you've testified at deposition a
` number of times?
` A. At least five, six times, yes. Yes, sir.
` Q. Okay. Have you testified in connection
` with various litigation proceedings?
` A. Yes, I have, Counsel.
` Q. And would those be District Court
` litigations?
` A. Yes. I believe one of them was District
` Court and one of them -- one of them was District
` Court. At least one of them was District. It may
` have been more. I don't remember.
` Q. Okay. Have you testified on behalf of
` Cisco Systems prior to your involvement in these
` inter partes review proceedings?
` A. I had a deposition a few weeks ago in
` Dallas with regard to other patents, but in the same
` -- I presume it's in the same case, right?
` Q. Involving the TQ Delta patent portfolio?
` A. Yes. Yes, I have. Raj was there.
` Q. Okay. Have you testified in
` connection -- Withdrawn.
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` Other than that proceeding and the two
` proceedings that you're here today, have you been
` involved in any other testimony on behalf of Cisco
` Systems with respect to any DSL technologies?
` A. No.
` Q. Okay. Have you testified -- Withdrawn.
` Other than the proceedings that you
` identified, have you testified in connection with any
` DSL technologies in any other matter?
` A. Specifically testified, no.
` Q. Had you been retained to testify or serve
` as an expert witness in connection with any other DSL
` matter?
` A. I vaguely recollect at least 10, 12 years
` ago -- I don't remember the details of it -- there
` was a firm that I went there and interviewed them for
` a DSL case. That's all I remember.
` Q. Okay. And what percentage of time do you
` devote to testifying as an expert witness over the
` past five years?
` A. Percentage of my time in terms of my
` overall workload?
` Q. Yes.
` A. Depends. On average -- depends --
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` depends on cases come and go. Sometimes, it could be
` 10, 20 percent. Sometimes it's zero percent.
` Q. Have you analyzed any documents or spoken
` to any individuals about other proceedings involving
` the '404 patent or the '268 patent?
` A. To the best of my recollection, no. This
` is the only case I've been involved with.
` Q. Did you -- Withdrawn.
` Is it correct that you didn't review the
` declaration of Mr. McNally in connection with another
` inter partes review proceeding involving the '404
` patent.
` A. And who is Mr. McNally? I'm sorry. I
` don't remember.
` Q. An expert witness.
` A. Is working on this case?
` Q. He's working in a collateral case.
` A. I don't remember, off the top of my head.
` Q. Okay. So let me briefly ask you about
` your preparation for your deposition today.
` What, if anything, did you do to prepare
` for your deposition?
` A. I -- it is in my declaration. I looked
` at the documents that are in my declaration. I
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` reviewed those, prepared with those.
` Q. That was in preparation for your --
` rendering your opinions that are reflected in your
` declaration, right?
` A. That's correct.
` Q. Now, to prepare for your deposition for
` today, did you rereview those documents?
` A. Yes, I did.
` Q. Okay. And did you review any other
` documents?
` A. Not to the best of my recollection. No,
` I did not.
` Q. Did you meet with anyone to prepare for
` your deposition for today?
` A. Yes, I did. I met with the counsel Boone
` and Haynes.
` Q. And the counsel with Haynes and Boone?
` A. Yes. Haynes and Boone.
` Q. And can you identify the counsel?
` A. I met with Russ. I met with Mark. And
` also Theo.
` Q. Theo. Okay.
` When was that?
` A. That was yesterday.
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` Q. For how long a period of time?
` A. On and off most of the day I was there.
` On and off, these gentlemen were in the room.
` Q. Okay. Did you speak with them prior to
` yesterday in connection with preparing for your
` deposition?
` A. Yes, I have.
` Q. Okay. When was that?
` A. Sunday afternoon, I met with Mr. Pierson
` (sic) and we had a couple conference calls before
` that.
` MR. EMERSON: Just so the record's clear,
` it's Parsons.
` THE WITNESS: Parsons. I'm sorry.
` MR. EMERSON: That's fine.
` THE WITNESS: My apologies.
` Q. BY MR. WIMBISCUS: Were the conference
` calls prior to Sunday?
` A. Yes, they were.
` Q. And about when were those calls?
` A. Probably in the last two or three weeks.
` Q. Okay. Did you review documents in
` connection with those meetings or conference calls?
` A. Yes.
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` Q. Were the -- did you review any documents
` other than the references that you rely upon and the
` patents at issue?
` A. No.
` Q. Was anyone else present, other than you
` and your lawyers, in connection with those meetings
` and conference calls?
` A. No.
` Q. About how much time have you put in in
` your -- preparing your declaration in connection with
` the '404 patent?
` A. Boy, that was a while ago. I'm going to
` give you a -- I mean, I can guess. The best of my --
` best guess is probably somewhere in the range of 30
` to 50, plus, minus. I don't remember the exact
` details.
` Q. What about your analysis and declaration
` involving the '268 patent?
` A. I would say both of them are about the
` same. 30 to 60 hours, plus, minus.
` Q. Collectively?
` A. Collectively, yeah.
` Q. Okay. What is your hourly rate?
` A. $400.
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` Q. Do you know about how much you billed in
` connection with your work on these two proceedings?
` A. No. Sorry. I don't remember.
` Q. Do you know if it's more than $12,000?
` A. Probably, yeah.
` Q. About 12,000, maybe?
` A. Probably, yeah.
` Q. All right. Did you ever read Cisco's
` petition in connection with the IPR involving the
` '404 patent?
` A. I believe I looked at that, yeah.
` Q. Okay. Did you observe any mistakes?
` A. On the Cisco's petition?
` Q. Yes.
` A. That was written by Cisco?
` Q. Yes.
` A. Top of my head, I don't remember right
` now. I'm sorry.
` Q. Okay. And would that -- your answer be
` the same with respect to Cisco's petition involving
` the '268 patent?
` A. I don't remember any mistakes that I came
` up with.
` Q. Okay. I want to show you what has been
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` marked as Exhibit 1003, which is a copy of your
` declaration in connection with the IPR filed by Cisco
` involving the '404 patent.
` A. Thank you.
` Q. Thank you.
` If you could just take a quick look at
` that and I'll have a couple quick foundational
` questions.
` And you studied this over the past few
` days?
` A. Yes, Counsel.
` Q. And it appears to be a copy of your
` declaration submitted in connection with the '404
` patent proceeding, right?
` A. Yes, sir.
` Q. And that's your signature on page 79?
` A. Yes, it is, Counsel.
` Q. And you signed the declaration on
` July 19th, 2016, right?
` A. Yes, Counsel.
` Q. Okay. Did you review the petition
` entirely before you signed it?
` A. You mean my declaration?
` Q. I'm sorry. Thank you.
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` Did you review your declaration entirely
` before you signed it?
` A. Absolutely.
` Q. Okay. And you didn't see any mistakes,
` right?
` A. On '404 declaration, I did not see any
` mistakes.
` Q. All right. And having reviewed it the
` past few days, you're comfortable that there -- it is
` accurate and -- accurately reflects your opinions; is
` that right?
` A. That is correct. There was -- Give me
` one second, if you don't mind.
` There was something I found in '268. I
` want to make sure it's also not a mistake here. So I
` want to look at that.
` Q. Okay.
` A. I don't believe that's the case, but I
` want to just make sure. That mistake is there, we
` may have to go -- when we go through '268, I may have
` to come back and say that. It's a pretty obvious
` mistake.
` Q. Okay.
` A. I found it. On page 29, the top two
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` DR. SAYFE KIAEI
` lines, it says, "The transmit and the receive
` circuitry are shut down and the link between modems
` is actively transmitting or receiving data." There
` should be a -- on the second line after "modem is,"
` there should be a "not." Modem is not actively
` transmitting or receiving data.
` Q. Okay. Anything else?
` A. No.
` Q. Okay. With respect to your declaration,
` Exhibit 1003 submitted in connection with the '268
` patent proceeding, you noted that same type of
` graphical mistake; is that right?
` A. Yeah. There were a couple additional I
` found too.
` Q. Are there any others you want to point
` out?
` A. On '268?
` Q. Yes.
` On '404 --
` A. On '404, there wasn't any, so we could --
` Q. Okay. I'll show you a copy of your
` exhibit, which has been marked 1003 in connection
` with the '268 patent proceeding.
` A. Thank you, Counsel.
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` DR. SAYFE KIAEI
` Q. You're welcome.
` A. All right.
` Q. Yes. Could you tell us any errors that
` you've identified?
` A. Same error again on page 29, line 2.
` After "modem is," there should be a "not." And on
` page 30 and 31, somehow, when I converted this to
` pdf, the text in the lower boxes did not come out, as
` you can see. Those are same as -- in the both cases
` are the same. Same as the petition as well.
` Q. Okay. Anything else?
` A. Not that I recall.
` Q. Okay. Thank you.
` I'm going to show you a copy of what's
` been marked as Cisco Exhibit 1005 in connection with
` the '404 patent proceeding, which is a copy of U.S.
` patent No. 5956323.
` A. Thank you, sir.
` Q. And I'm going to direct your attention,
` please, to figure 2. You're familiar with this
` figure, correct?
` A. Yes, Counsel.
` Q. Okay. And CPE unit 242, that represents
` customer premise equipment?
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` DR. SAYFE KIAEI
` A. That's correct. On the right-hand side
` in the box, yes.
` Q. Okay. And what is a CPE in the context
` of the '404 patent and the '268 patent?
` A. It is a customer premise modem that sits
` in the customer's end.
` Q. Okay. And you see where it says "COT
` unit 232" in figure 2?
` A. Yes, Counsel.
` Q. All right. And that represents central
` office terminal, correct?
` A. That is correct. That's the central
` office terminal.
` Q. Can you tell us what that means in the
` context of the '404 -- I'm sorry -- what that means
` in the context of the '404 and '268 patents?
` A. That is the central office terminal,
` central office modem that sits in the central office.
` Q. All right. And the central office
` terminal unit is connected to the CPE unit by way of
` line 220; is that right?
` A. Among other things.
` Q. Okay. And line 220 is a two-wire loop?
` A. We call is a twisted pair loop.
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` DR. SAYFE KIAEI
` Q. Is it also known as a two-wire loop?
` A. I assume so. Technically, I've heard it
` mostly "twisted," but I presume it's the same thing.
` Q. All right. You wouldn't be surprised if
` Bowie refers to line 220 as a two-wire loop?
` A. No. I've seen that.
` Q. All right. Are a two-wire loop or a
` twisted pair typically made up of copper wires?
` A. Typically, depending on the phone lines.
` May be different.
` Q. All right. I'm going to direct your
` attention to paragraph 78 of your declaration,
` Exhibit 1003, submitted in connection with the '404
` patent proceeding.
` MR. EMERSON: Which paragraph again?
` Q. BY MR. WIMBISCUS: 78.
` Now, paragraph 78 references the ANSI TI
` -- or T1.413 standard, right?
` A. Yes.
` Q. Okay. If I refer to that as the 1995
` ADSL standard, you'll know what I'm referring to?
` A. Yes, Counsel.
` Q. Okay. And you write that, "A standard
` provides basic functions for initializing ADSL
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` DR. SAYFE KIAEI
` transceivers," right?
` A. That's correct.
` Q. The second sentence of paragraph 78
` states, "As part of the initialization, the ADSL
` transceivers establish transmission and processing
` characteristics suitable for the channel including a
` number of bits and relative power levels to be used
` on each DMT subcarrier."
` Did I read that correctly?
` A. That's correct.
` Q. What does initialization mean in the
` context of the 1995 ADSL standard?
` A. Can I have a copy of the T1.415, please?
` Q. Sure.
` Okay. I'm going to hand you a copy of
` Cisco's Exhibit 1007, in connection with the '404
` patent proceeding. You may identify that as the 1995
` ADSL standard.
` A. To answer your question, I'm going to
` refer to first in my declaration for '404, page 53,
` in the elements 6.4.1 of the claim 6. On the second
` row of the table on the right-hand side, the third
` paragraph, I specified that second the ANSI for
` T1.413 teaches that fine gain -- and fine gain and
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` DR. SAYFE KIAEI
` bit allocation are parameters that are determined
` when setting up the communication loop, and it goes
` on in saying that to maximize the throughput and
` reliability of this link, the transceivers shall
` determine certain relevant attributes of the
` connecting channel and establish transmission and
` processing characteristics suitable to the channel.
` The timeline on figure 29 provides an
` overview of this process. In figure 29 each receiver
` can determine the relevant attributes of the channel
` to the transceiver training, and channel analysis
` procedures certain processing and transmission
` characteristics can also be established at each
` receiver during this time frame.
` Even the exchange process each receiver
` shares with this corresponding far end transmitter
` certain transmission setting that it expects to see
` specifically each receiver to its far end transmitter
` -- I'm sorry. Each receiver communicates to its far
` end transmitter the number of bits and relative power
` levels to be used on each DMT subcarrier as well as
` any messages and final data rates.
` So that is also -- there is actually --
` this is the second -- another error I found out here,
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` DR. SAYFE KIAEI
` which is that the paging numbers on this specific
` reference in T1.413 on page 54 on my declaration is
` incorrect. It should be Exhibit 1007, page 103,
` instead of page 105.
` Q. Okay.
` A. So later on I say that "The POSITA will
` understand the relative power levels per DMT
` subcarrier (fine gain) a number of bits (bit
` allocation) are determined in order to initialize the
` communication loop that it will be obvious for Bowie
` ADSL unit to store these parameters in order to
` quickly retain the units when returned to a true
` power level."
` So as outlined by T1.14, and the Bowie is
` also -- is discussing ADSL unit. It is discussing
` the section 12.1 of the ADSL 1995 standards, what
` this initialization and the basic functions of the
` initializations are. And all the procedures and the
` process is defined in that -- in that process.
` Q. Okay. Let me direct your attention to
` the -- the box that you incorporated from page 103 of
` the 1995 ADSL standard Exhibit 1007 into your page 54
` of your declaration, Exhibit 1003. So let's turn to
` page 54, which is where you just were a moment ago in
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` DR. SAYFE KIAEI
` your declaration, please.
` A. Yes, Counsel.
` Q. Okay. So you have a -- a graphic there,
` which is figure 29, overview of initialization that
` you copied from the 1995 ADSL standard at page --
` from page 103 thereof, right?
` A. Yes.
` Q. Okay. So ATU-C, does that stand for
` essentially the customer premises equipment?
` A. Actually, no.
` Q. Okay. Can you explain?
` A. ATU stands for ADSL transceiver unit; C
` stands for central office.
` Q. Very good. Thank you.
` In connection with ATU-R, what does that
` stand for?
` A. ADSL transceiver unit at the remote
` premise, which is -- in this case, it would be the
` customer premise.
` Q. Okay. So I'm going to try to drill down
` a little bit on your answer, which you gave a moment
` ago.
` Let's start with the ATU-R portion of
` figure 29, which has been copied into your
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` DR. SAYFE KIAEI
` declaration Exhibit 1003. Okay?
` A. Uh-huh.
` Q. So in terms of initialization, what takes
` place during each of these boxes, the first box is
` described with the text, activation and
` acknowledgment.
` A. In the T1.413.95, same page, it discusses
` what activation and acknowledgment is in the first
` couple of bullet items, which says that an ATU-C
` after power-up or loss of signal, an optional
` self-test may transmit activation tones and then wait
` for a response from the ATU-R. It shall make no more
` than two attempts.
` If no response is received, it shall wait
` for an activation request from the ATU-R or an
` instruction from the network to be tried.
` So what this means is that the ATU-C,
` when it's turned on, or when the signal is lost
` between the -- the link is lost between the central
` office and the remote office, transmits a tone and it
` waits for the remote side to send the response back.
` So, first, ATU-C sends that tone and
` ATU-R responds back. And if it doesn't respond back,
` it will try it a few times and it will go back and
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` DR. SAYFE KIAEI
` try again or shut it off.
` And the next bullet item says that an
` ATU-R after power-up and an optional self-test may
` repeatedly transmit activate request. If, however,
` the ATU-R receives C tone, it shall remain silent for
` approximately one minute unless it
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