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` JAY KESAN
` UNITED STATES PATENT AND TRADEMARK OFFICE
` ________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ________________________________
` APPLE, INC.,
` PETITIONER,
` v.
` CELLULAR COMMUNICATIONS EQUIPMENT, LLC.,
` PATENT OWNER.
` ________________________________
` CASE IPR2016-01493
` Patent Number 8,457,676
` _________________________________
`
` VIDEOTAPED DEPOSITION OF JAY P. KESAN, Ph.D.
` Thursday, July 20, 2017
` Chicago, Illinois
`
`Reported By:
`TRICIA J. FLASKA, CSR, RPR
`JOB NO. 127412
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` JAY KESAN
` UNITED STATES PATENT AND TRADEMARK OFFICE
` ________________________________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ________________________________
` APPLE, INC.,
` PETITIONER,
` v.
` CELLULAR COMMUNICATIONS EQUIPMENT, LLC.,
` PATENT OWNER.
` ________________________________
` CASE IPR2016-01493
` Patent Number 8,457,676
` _________________________________
`
` VIDEOTAPED DEPOSITION OF JAY P. KESAN, Ph.D.
` Thursday, July 20, 2017
` Chicago, Illinois
`
`Reported By:
`TRICIA J. FLASKA, CSR, RPR
`JOB NO. 127412
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`Page 2
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` Thursday, July 20, 2017
` 9:02 a.m.
`
` VIDEOTAPED DEPOSITION OF JAY P. KESAN,
`Ph.D., held at The Aloft Chicago City Center Hotel,
`515 North Clark Street, Chicago, Illinois, 60654
`before Tricia J. Flaska, CSR, RPR.
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` JAY KESAN
`A P P E A R A N C E S:
`
` BRAGALONE CONROY
` BY: TERRY SAAD, ESQ.
` 2200 Ross Avenue
` Dallas, Texas 75201
` ATTORNEYS FOR PATENT OWNER;
`
` HAYNES AND BOONE
` By: PHILLIP PHILBIN, ESQ.
` CLINT WILKINS, ESQ.
` 2323 Victory Avenue
` Dallas, Texas 75219
` ATTORNEYS FOR PETITIONER.
`
`ALSO PRESENT: Frank Rice, Videographer
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` JAY KESAN
` I N D E X
` WITNESSES
`All Witnesses: Page
`JAY P. KESAN, Ph.D. for Petitioner
` Examination by Mr. Philbin 6
` Examination by Mr. Saad 153
` EXHIBITS
`Exhibit 1 United States Patent Number
` 8,457,676 8
`
`Exhibit 2 Declaration of
` Dr. Jay Kesan 8
`Exhibit 3 Excerpts from the book
` "LTE - The UMTS Long Term
` Evolution" 68
`Exhibit 4 Excerpts from the book
` "Fundamentals of LTE" 71
`
`Exhibit 5 Fong reference 106
`
`Exhibit 6 Tdoc submitted by Ericsson
` to the 3GPP 117
`Exhibit 7 Bark reference 142
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` JAY KESAN
` THE VIDEOGRAPHER: This is the start of
`tape number one, disc number one, of the videotaped
`deposition of Jay Kesan in the matter Apple,
`Incorporated versus Cellular Communication Equipment
`in the Court Case Number IPR2016-01493.
` Deposition is being held at The Aloft Hotel
`in Chicago, Illinois, on Thursday, July 20, 2017,
`approximately 9:02 a.m. Central Daylight Time.
` My name is Frank Rice, the legal video
`specialist from TSG Reporting, headquartered at 747
`Third Avenue, New York, New York. Court reporter,
`Tricia Flaska in association with TSG Reporting.
` Counsel, please introduce yourselves
`starting on my right.
` MR. SAAD: Terry Saad from Bragalone Conroy on
`behalf of the patent owner, Cellular Communications
`Equipment, LLC.
` MR. PHILBIN: Phillip Philbin of Haynes & Boone
`on behalf of Petitioner, Apple, Incorporated, and
`with me is Mr. Clink Wilkins.
` J A Y P. K E S A N, Ph. D.,
`called as a witness, having been first duly sworn by
`a Notary Public, was examined and testified as
`follows:
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` THE VIDEOGRAPHER: We are on the record.
` EXAMINATION
`BY MR. PHILBIN:
` Q Good morning, sir.
` A Good morning.
` Q How do you prefer to be addressed?
` A Mr. Kesan, Dr. Kesan, Jay. All fine.
` Q Your choice. Which -- which do you prefer
`to be called?
` A Dr. Kesan, I guess.
` Q Okay.
` THE VIDEOGRAPHER: Excuse me. Counsel Philbin,
`let me check your mic real quick. There's a buzz.
`Of course it didn't start until you touched it.
` THE WITNESS: My -- my phone is on mute.
` THE VIDEOGRAPHER: Go ahead.
` MR. PHILBIN: All right.
`BY MR. PHILBIN:
` Q Dr. Kesan, approximately how many times
`have you been deposed?
` A A few times.
` Q A few dozen times?
` A Yeah, probably.
` Q More than a hundred?
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` A Maybe not.
` Q Somewhere between 12 and a hundred?
` A Maybe -- maybe two or three dozen times.
` Q So somewhere between 24 and 36 times; is
`that correct?
` A Something like that. Yeah. I mean, just
`-- just roughly speaking. It's over several years,
`of course.
` Q And you testify as a technical expert in
`cases; is that correct?
` A I have testified as a technical expert.
`I've also testified as -- in other situations.
` Q And you hold yourself out as a legal expert
`as well, correct?
` A I have testified as a legal expert in
`certain types of proceedings.
` Q And you hold yourself out as a legal expert
`in patent law proceedings, correct?
` A I have if the issues are amenable for
`expert testimony.
` Q Do you hold yourself out as an expert on
`judicial experience and the efficiency and accuracy
`of patent adjudication?
` A I mean -- I think if I remember right, it's
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` JAY KESAN
`like a paper that I've written. I mean, it's -- I
`think you're reading the title of a paper, if I
`remember right.
` Q So do you hold yourself out as an expert in
`that topic?
` A Well, I don't know what you mean by that
`particular topic. It's -- I'm happy to discuss a
`particular paper that I wrote.
` Q In this case, did you use your technical
`expertise as well as your legal expertise in
`rendering your opinions?
` A No. I used my technical expertise.
` (Exhibit 1 marked for identification.)
` Q I'll hand you what's been marked as Exhibit
`No. 1, which, for the record, is United States
`Patent Number 8,457,676.
` You recognize that document, sir?
` A Yes.
` Q That's the patent that you analyzed in
`connection with preparing your Declaration in this
`case, correct?
` A Yes.
` (Exhibit 2 marked for identification.)
` Q Hand you what's been marked as Exhibit 2.
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`Take a minute, look at that, let me know when you're
`finished.
` A Yes.
` Q You recognize Exhibit 2?
` Do you recognize --
` A Yes -- yes, I do.
` Q Okay. And Exhibit 2 is the Declaration
`that you prepared in this case; is that correct?
` A Yes.
` Q Is exhibit true -- strike that.
` Is Exhibit 2 true and accurate?
` A Yes.
` Q Is Exhibit 2 complete?
` A Yes.
` Q Did you author all of Exhibit 2?
` A Yes.
` Q Are there any mistakes in Exhibit 2?
` A You know, there were one or two little
`typos that I saw, but nothing substantive.
` Q Are there any omissions from Exhibit 2?
` A No.
` Q In your opinion, does Exhibit 2 comply with
`the Federal Rules of Civil Procedure for the
`requirements of expert witness disclosure?
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` MR. SAAD: Objection. Form.
` A You know, I haven't looked at the specific
`rules, but I'm relying on counsel to advise me to
`make sure that it does comply.
`BY MR. PHILBIN:
` Q Okay. In your opinion, as a legal and
`technical expert, does Exhibit 2 comply with your
`obligations under the Federal Rules of Civil
`Procedure?
` MR. SAAD: Same objection.
` A I think it does. But I'm happy to -- I
`haven't looked at the specific rule and I'm relying
`on counsel to help me do that.
`BY MR. PHILBIN:
` Q You reviewed all of Exhibit 2 before you
`signed it, correct?
` A Yes.
` Q In your expert legal and technical opinion,
`are there any misstatements of law in Exhibit 2?
` MR. SAAD: Objection. Form.
` A Again, I relied on counsel to help me with
`the applicable legal standards.
`BY MR. PHILBIN:
` Q Well, as someone that holds himself out as
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`a professor of law and an expert of law, you
`certainly wouldn't sign a Declaration if you saw any
`misstatements of law contained therein, would you?
` A I was just focused on my role in this case,
`and so here I'm a technical expert and I reviewed
`the legal standards, but I did not do any
`independent study of it and I relied on counsel.
` Q Could you point me in Exhibit 2 to where
`you have disclosed the other cases in which you've
`testified?
` A I don't see that here. I see only my CV
`and list of publications.
` Q As a practicing attorney, a professor of
`law, and someone that holds themselves out as an
`expert in legal matters, is it your understanding
`that, under the Federal Rules of Civil Procedure,
`you're required to disclose your prior testimony in
`cases?
` MR. SAAD: Objection. Form.
` A Again, I've -- I think that is correct, but
`I've not checked for whether the information was
`otherwise given or so on, and I'm relying on counsel
`to satisfy all those requirements.
`BY MR. PHILBIN:
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` Q Why did you choose not to disclose your
`prior testimony in this case?
` MR. SAAD: Objection. Form.
` A Oh, I didn't -- I don't think I've not
`disclosed it, so. I think counsel has a copy of the
`cases that I've appeared in.
`BY MR. PHILBIN:
` Q You agree with me it's not in Exhibit 2?
` A Yeah, it's -- I don't see it here in
`Exhibit 2, but I -- I don't know if it was otherwise
`disclosed through some other mechanism by counsel or
`not, but -- but I've provided a list of all the
`cases that I've appeared in.
` Q What are cellular communication systems?
` A Well, they're wireless communication
`systems essentially.
` Q Are there any differences between cellular
`communication systems and wireless communication
`systems?
` A It's a type of wireless communication
`system.
` Q So cellular would be included within
`wireless, but not wireless within cellular; is
`that --
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` A No. Wireless is a broader term.
` Q Okay. Do you understand what the term
`"cellular communication systems" means?
` A Yes.
` Q Do you understand what Cellular
`Communications Equipment means?
` A Yes.
` Q In fact, that's the name of your client,
`right?
` A Yes, that's the name of the patent owner
`here, yeah.
` Q Do you consider yourself an expert in
`cellular communication systems?
` A You know, that's a very broad term and
`there are numerous aspects of it, to cellular
`systems, but, generally, yes.
` Q Are you familiar with ETSI, E-T-S-I?
` A Yes.
` Q What is ETSI?
` A It's a --
` MR. SAAD: Objection. Scope.
` A It's a standard-setting organization in
`Europe.
`BY MR. PHILBIN:
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` Q How many ETSI meetings have you ever
`attended?
` A I've participated --
` MR. SAAD: Objection -- sorry -- objection.
`Outside the scope of his Declaration.
` A I've been -- I've met and written and
`spoken with ETSI officials, but I have not attended
`a ETSI standard-setting meeting.
`BY MR. PHILBIN:
` Q So your answer is zero, correct?
` A Yeah. I've not attended any
`standard-setting meeting, no.
` Q How many publications have you submitted to
`an ETSI committee?
` A I have not submitted a Tdoc, or so on, to
`an ETSI committee, no.
` Q So you know what Tdocs are, right?
` A Right.
` Q You know what technical submissions are?
` A Right.
` Q What is 3GPP?
` A It's basically third generation partnership
`project.
` Q How many different committees does 3GPP
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`have?
` A There's a lot of sub groups.
` Q Of all the sub groups within 3GPP, how many
`of those meetings have you attended?
` A I've spent most of my career in academia,
`and so I've not been involved in companies that
`typically are involved in the standard-setting
`process, companies that submit typically things like
`Tdocs.
` Q So my question was: How many meetings of
`3GPP and all the subcommittees have you attended?
` A I've not attended any subcommittee meeting
`of 3GPP specifically.
` Q Okay. How many 3GPP meetings have you
`attended?
` MR. SAAD: Objection. Asked and answered.
`Scope. Relevance.
` A Not 3GPP specifically, no.
`BY MR. PHILBIN:
` Q How many technical documents have you
`submitted to a 3GPP entity?
` MR. SAAD: Objection. Relevance.
` A Once again, I've been involved more in
`research and -- and more as an academic and not been
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`involved with companies that have submitted
`documents to -- or Tdocs to an effort such as 3GPP.
`BY MR. PHILBIN:
` Q How many technical documents have you
`submitted to a 3GPP entity?
` A I have not submitted any documents --
` MR. SAAD: Objection. Can you just give me a
`chance to get my objection in?
` MR. PHILBIN: Do you all need to take a break?
` MR. SAAD: No. We're okay.
`BY MR. PHILBIN:
` Q Have you ever worked for Nokia?
` A No.
` Q Have you ever worked for Ericsson?
` A No.
` Q Have you ever worked for Siemens?
` A No.
` Q Have you ever worked for Cisco?
` A No.
` Q Have you ever worked for Huawei?
` A No.
` Q Have you ever worked for Motorola?
` A No.
` Q Have you ever worked for AT&T?
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` A No.
` Q Have you ever worked for Lucent or Bell
`Labs?
` A No.
` Q Have you ever worked for Nortel?
` A No.
` Q Have you ever worked for RIM or BlackBerry?
` A I've done some consulting.
` Q When they were RIM or BlackBerry?
` A I think RIM.
` Q So that was sometime ago?
` A A few years ago.
` Q Have you ever submitted a technical
`document to any cellular communications standards
`body?
` MR. SAAD: Objection. Relevance. Scope.
` A I -- I don't think I've submitted a
`technical document to a cellular communications
`body.
`BY MR. PHILBIN:
` Q Looking at Exhibit 2, could you identify
`any research grants that you've received in the
`cellular communication systems space?
` A So I've worked on --
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` Q I believe it's page 81, if that helps.
` A -- and been involved, for example --
`currently I'm working on some cyber-security risk
`assessment issues and they involve security in
`wireless systems.
` Q Could you identify on page 81 of Exhibit 2
`the research grants that you contend relate to
`cellular communication systems?
` A I think some of them have aspects of
`cellular to them, but I -- you know, for example,
`you know, I have a grant in digital forensics and a
`lot of that involves trying to track activity in a
`wireless environment.
` Q Which bullet point are you referring to on
`page 81 of Exhibit 2?
` A For example, the program in digital
`forensics is one of them.
` Q Anything else?
` A And -- so, again, these are grants that
`involve aspects of wireless communications, but I'm
`-- you know, I'm -- it's because they involve
`wireless communications. So, again, as I mentioned,
`with cyber security, again, that's found in a couple
`of different grants, cyber security necessarily
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`involves security of both wired and wireless
`communications.
` Q Can you identify any of your publications
`that relate to cellular communication systems in
`Exhibit 2?
` A There are quite a few of them, so I -- I
`have a number of, for example, patents on
`radiofrequency identification devices, which are the
`tags that are used, for example, on the internet of
`things that's coming up in -- as part of 5G, for
`example.
` Q Is it your -- is it your contention that
`RFID is a cellular communication system?
` A No. It's what -- it's -- it is what is
`used in -- in a -- it's designed to be used in a
`wireless communication network.
` Q So you would agree that RFID patents are
`not cellular communication systems patents, correct?
` A Well, they're parts of, you know,
`forthcoming wireless communication systems.
` Q Let's talk for a minute about 5G.
` 5G is kind of the next step from 4G; is
`that correct?
` A Right.
`
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` Q And 4G was the next step from 3G; is that
`right?
` A Correct.
` Q So 5G is built on the shoulders of 4G?
` A I mean, in some sense they're all built on
`what came before, but they're -- but they -- the way
`-- the capabilities and functionalities can be very
`different because you're trying to get pretty
`significant improvements and performances doing
`various things and you're in a different environment
`with different applications.
` Q Okay. Looking back at page 85 of Exhibit
`2, can you identify your peer review journal
`publications that you contend relate to cellular
`communication systems?
` A I have a number of publications that relate
`to RF in general and to radiofrequency.
` Q We just established that radiofrequency
`identification is not cellular communication
`systems, right?
` A In the -- parts of it.
` Q Okay.
` A And then there -- there's sort of parts of
`a wireless communication system, yeah.
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` Q So I'm not asking about RFID. I'm asking
`about cellular communication systems.
` A Right.
` Q So starting on page 85 of your Declaration,
`Exhibit 2, please identify all peer-reviewed
`publications that relate to cellular communication
`systems.
` A So I want to answer your question. And
`what I'm saying here is that RF -- not RFID -- RF,
`radiofrequency technology, RF technology is what
`I've worked on specifically things like --
` Q Can you just give me the numbers of the
`publications since you've numbered them in your
`Declaration?
` A Yeah. Let me -- let me try to find them.
`So -- so I've worked on things like oscillators and
`amplifiers and they are components that go into a RF
`system, so --
` Q Did you understand my question?
` A Try to find some of them. It's been a
`while since I've looked at some of these, but --
` Q Just so we're clear, I want the numbers of
`the publications of peer-reviewed journal
`publications starting on page 85 of Exhibit 2 that
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`you contend relate to cellular communication
`systems.
` A Again, what I have worked on are components
`that go into a cellular communication system. So
`some of the technologies that I've worked on are
`parts of, for example, transceiver and receiver
`chips that go into a wireless communication system.
` Q Are you finished with your answer?
` A Yes.
` Q Can you identify a single peer-reviewed
`journal publication that you have disclosed to us in
`Exhibit 2 that relates to cellular communication
`systems?
` A So early on, for example, public --
`publication 5, for example, relates to oscillator
`design. Publication 6 relates to, again, milli- --
`millimeter wave oscillator designs. Publication 8
`relates to microwave frequency operation of a
`specific type of device. All of these are RF
`applications of -- of components that go into RF
`systems.
` Publication 15, again, relates to another
`oscillator design. Again, these are devices that
`generate radiofrequency signals. Try to find some
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`more.
` So there are some other publications,
`again, relating to transistor design for various
`kinds of analog and RF applications. So there are
`-- publication 45 deals with optical data link
`applications, for example. The applications of
`certain other devices that I'm talking about are
`also in analog and communication environments.
` So I'm just looking through the
`publications to try to find the ones that would
`relate to RF technology.
` Q Are you finished?
` A I think those are the ones that I see.
` Q Not a single publication that you've
`identified uses the term "cellular" or
`"communication" in the title, does it?
` A It may use "communications," but I don't
`think it's limited to cellular. It's limited to
`sort of a broader RF technology environment and RF
`applications.
` Q Are millimeter wave devices used in
`cellular communication systems?
` A We're starting to get to the millimeter
`wave range now in -- they're used, of course, in --
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`there's communication in -- in the millimeter wave
`range.
` Q Is it your testimony that millimeter wave
`devices are used in 3G communication systems?
` A No. I mean, they're -- they're at a lower
`frequency technology.
` Q Are millimeter wave devices used in 4G
`communication systems?
` A So basically you're talking about, you
`know, beyond -- typically you think of millimeter
`wave, you're thinking of 30 megahertz and more. And
`so that's -- there is basic -- basically -- again,
`I'm talking roughly speaking -- you know, microwave,
`millimeter wave, and those kind of ranges are --
`we're starting to get into higher frequencies of
`that sort in sort of -- in cellular technologies.
`But not in 3G.
` Q Are you contending that -- well, strike
`that.
` Do cellular communication systems operate
`at 30 gigahertz?
` A I mean, not right now.
` Q Are optical communication devices used in
`cellular communication systems?
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` A The particular -- particular publication I
`was talking about was developing an optical data
`link in a computing environment.
` Q Are optical communication devices used in
`cellular communication systems?
` A Well, there may be some optics involved,
`but -- but not in the cellular communication.
` Q Do you have any books related to cellular
`communication systems?
` A Not specifically.
` Q Do you have any book chapters related to
`cellular communication systems?
` A There are a number of book chapters.
` MR. SAAD: Object to form.
` A Yeah, I don't see any that are directed at
`cellular communication systems.
`BY MR. PHILBIN:
` Q You're talking about like the chapters on
`the History of Civil Rights in Ohio. That's not
`directed to cellular communication systems, correct?
` A That's obviously not, but it was a piece I
`was invited to do, so I -- I did it. My home state,
`so.
` Q And none of your patents listed on pages 91
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`and 92 of your Exhibit 2 are directed to cellular
`communication systems, correct?
` A Well, they're all directed to -- so many of
`them are directed to radiofrequency identification
`devices and -- and networks of radiofrequency
`identification devices, which, as I mentioned, is --
`is now currently part of the internet of things,
`which is part of 5G. And then I have other patents
`that are directed to components that go into analog
`RF communication applications.
` Q None of your law review publications
`starting on page 92 of Exhibit 2 are directed to
`cellular communication systems, are they?
` A Some of them are directed to sort of -- to
`standard-setting organizations and things like that.
`Part of the environment of the development of these
`standards.
` Q Does RFID involve two-way communication?
` A It can.
` Q Does RFID involve packet-switching
`protocols?
` A So the -- the idea with RFIDs is to try to
`minimize the amount of -- to efficiently get very
`specific select amounts of information. And that --
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`that's what you're trying to do with a tag, is that,
`you know, you -- you -- you know, you're trying to
`be quick and efficient and you're not trying to be
`very burdensome in terms of sending back and forth,
`you know, a lot of information.
` MR. PHILBIN: Objection. Non-responsive.
`BY MR. PHILBIN:
` Q You understand I have limited time today,
`correct?
` A Yes.
` Q Does RFID involve packet-switching
`protocols?
` A So, again, the information, for example,
`that is sent back and forth from an RFID will
`eventually end up in a system that is -- involves
`packet switching. So that data that you collect
`from an RFID will -- will be part of a wireless
`system.
` Q Does the communication back and forth
`between the RFID device involve packet-switching
`protocol?
` MR. SAAD: Objection. Form.
` A Usually not the specific back and forth.
`You try to keep it simpler.
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`BY MR. PHILBIN:
` Q Does the communication between the RFID
`device involve wireless circuit-switching protocols?
` MR. SAAD: Objection. Form.
` A Yeah. It could involve setting up a
`communication link. And it depends on what, you
`know, you're -- you mean by sort of
`"circuit-switching protocol," but -- but you will
`set up a connection and you may have a handshaking
`routine and then send and receive data.
`BY MR. PHILBIN:
` Q At IBM, did you work on cellular
`communication systems?
` A Not directly.
` Q At MIT, did you work on cellular
`communication systems?
` A Again, I worked on the underlying
`technologies that go into, you know, broadly
`speaking, analog communications, analog
`environments.
` Q What courses have you taught regarding
`cellular communication systems?
` A Again, I've taught courses in where
`wireless communications are part of the environment
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`where we're discussing a particular issue.
` Q Give me the title of any course that you've
`taught regarding cellular communication systems.
` A Again, the kinds of courses that I have
`taught are -- relate to aspects of cellular and
`wireless communications.
` Q You can't give me the title of a single
`course?
` A Sure. For example, we discuss, you know,
`wireless communications in a course called digital
`forensics. In another course called security and
`privacy, we discuss wireless communications.
` Q Is that your complete answer?
` A Yes. I'm just giving some examples.
` Q I want all the courses you've taught,
`including the titles, that specifically related to
`cellular communication systems.
` A Again, we -- some of the courses I've
`taught involve wireless communication technologies
`and the ones that come to mind are digital
`forensics, privacy and security, for -- for example,
`and, you know, another class called cyber law and
`regulation.
` Q You finished?
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` A Yeah.
` Q Looking at Exhibit 1, the '676 patent.
`When did you first become aware of the '676 patent?
` A Year or two ago.
` Q How did you become aware of the '676
`patent?
` A I was asked to read it.
` Q In the context of litigation?
` A I was asked to read it by counsel, so I
`wasn't sure exactly what was -- if there was -- I
`was asked to read it, so, at that point.
` Q So you found out about the '676 patent in
`the context of a lawsuit, correct?
` A That was the first time I -- I -- I think
`that's the first time I saw this patent.
` Q So from the time the '676 patent issued to
`the time some lawyers told you to look at it, in
`connection with your technical consulting and your
`technical teaching, you never found out about the
`'676 patent, correct?
` A Yeah. I mean, there's a lot of patents --
`hundreds and thousands of patents in -- in the
`wireless communication space, so heavily-patented
`area.
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` Q So now can you answer my question?
` A Yeah. So it was brought to my attention.
` Q You didn't find out about the '676 patent
`between the time it issued and the time some lawyers
`told you about it, correct?
` A I don't recall having seen it before.
` Q Did you understand the '676 patent when you
`read it?
` A Yes.
` Q Is there any part of the '676 patent you do
`not understand?
` A No.
` Q Do you consider yourself an expert in
`reading patents?
` MR. SAAD: Objection. Form.
` A I don't know about an expert in the reading
`of patents, but I've read a few patents.
`BY MR. PHILBIN:
` Q Have you ever drafted a patent?
` A Yes.
` Q And as an inventor, you've signed a
`Declaration that you understood what a patent
`application said, correct?
` A Yes.
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