`DR. RADHAKRISHNAIAH PARACHURU 12/20/2017DR. RADHAKRISHNAIAH PARACHURU 12/20/2017
`
`DR. RADHAKRISHNAIAH PARACHURU 12/20/2017DR. RADHAKRISHNAIAH PARACHURU 12/20/2017
`
`------------------- I N D E X -------------------
`WITNESS
` EXAMINATION BY
`DR. PARACHURU MR. MUDD
`MR. WALDEN
`
`73
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`Page 3
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` PAGE
` 4
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`----------- PREVIOUSLY MARKED EXHIBITS ----------
`FREDMAN DESCRIPTION
` FOR REF.
`Exhibit 1001 Patent US 8,887,332
` 14
`Exhibit 1006 International Application 48
`Exhibit 1047 Patent US 9,015,883
` 14
`Exhibit 1049 Patent US 8,646,134
` 14
`BEDGEAR
`Exhibit 2002 Curriculum Vitae
`Exhibit 2004 Declaration of
` Dr. Radhakrishnaiah
` Parachuru 15
`
` 18
`
` (EXHIBITS TO BE PRODUCED)
`
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`Page 1
`UNITED STATES PATENT AND TRADEMARK OFFICE
`------------------------------------------------X
`FREDMAN BROS. FURNITURE COMPANY, INC.,
` Petitioner,
`-against-
`BEDGEAR, LLC,
` Patent Owner.
`Case IPR 2017-00350, 2017-351 and 2017-00352
`------------------------------------------------X
`
`1290 Avenue of the Americas
`New York, New York
`
`December 20, 2017
`10:05 a.m.
`
` DEPOSITION of DR. RADHAKRISHNAIAH
`PARACHURU, taken in the above-entitled matters,
`before Sadie L. Herbert, a Registered
`Professional Reporter and Notary Public of the
`States of New York and New Jersey.
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`Page 2
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`A P P E A R A N C E S:
`
`ON BEHALF OF PETITIONER:
`(Via video conference)
` ERISE IP, P.A.
` 7015 College Blvd.
` Suite 700
` Overland Park, Kansas 66211
` Phone 913.777.5600
` BY: JASON R. MUDD, ESQ.
` Jason.mudd@eriseip.com
` CARIE BADER, ESQ.
` ADAM SANDWELL, ESQ.
`
`ON BEHALF OF DEFENDANT:
` BRYAN CAVE
` 1290 Avenue of the Americas
` New York, New York 10104
` Phone 212.541.2000
` BY: ALEXANDER WALDEN, ESQ.
` Alexander.walden@bryancave.com
` FRANK FABIANI, ESQ.
` Frank.fabiani@bryancave.com
`
`Page 4
`DR. RADHAKRISHNAIAH PARACHURU, the witness
` herein, having first been duly sworn by a
` Notary Public of the State of New York,
` was examined and testified as follows:
`EXAMINATION
`BY MR. MUDD:
`
` Q Good morning. Q Good morning.
`
` Q Good morning. Q Good morning.
` A Good morning.
`
` Q Could you state your name and address Q Could you state your name and address
`
` Q Could you state your name and address Q Could you state your name and address
`
`for the record, please.for the record, please.
`
`for the record, please.for the record, please.
` A My first name is Radhakrishnaiah, my
`second -- my last name Parachuru, and the
`address where I live is 8240 Royal Troon Drive,
`Duluth, Georgia 30097.
`
` Q And could you state your occupation, Q And could you state your occupation,
`
` Q And could you state your occupation, Q And could you state your occupation,
`
`please.please.
`
`please.please.
` A I'm employed at the university.
`
` Q Which university? Q Which university?
`
` Q Which university? Q Which university?
` A Georgia Institute of Technology.
`
` Q And what's your position there? Q And what's your position there?
`
` Q And what's your position there? Q And what's your position there?
` A I have my position described as
`principal research scientist and senior academic
`professional.
`
` Q Have you been deposed before, Q Have you been deposed before,
`
` Q Have you been deposed before, Q Have you been deposed before,
`
`Dr. Parachuru?Dr. Parachuru?
`
`Dr. Parachuru?Dr. Parachuru?
`
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`www.alaris.uswww.alaris.us
`
`www.alaris.uswww.alaris.us
`
`
`ALARIS LITIGATION SERVICESALARIS LITIGATION SERVICES
`
`ALARIS LITIGATION SERVICESALARIS LITIGATION SERVICES
`
`Phone: 1.800.280.3376Phone: 1.800.280.3376
`
`Phone: 1.800.280.3376Phone: 1.800.280.3376
`
`1 (Pages 1 to 4)
`
`
`Fax: 314.644.1334Fax: 314.644.1334
`
`Fax: 314.644.1334Fax: 314.644.1334
`
`IPR2017-00351
`Fredman EX1061 Page 1
`
`

`

`
`DR. RADHAKRISHNAIAH PARACHURU 12/20/2017DR. RADHAKRISHNAIAH PARACHURU 12/20/2017
`
`DR. RADHAKRISHNAIAH PARACHURU 12/20/2017DR. RADHAKRISHNAIAH PARACHURU 12/20/2017
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`Page 5
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` A Yes.
`
` Q How many times? Q How many times?
`
` Q How many times? Q How many times?
` A About six or seven times.
`
` Q When was the most recent one? Q When was the most recent one?
`
` Q When was the most recent one? Q When was the most recent one?
` A Let me try to recollect. The most
`recent one was a hearing in LA where -- yeah,
`hearing in LA, yeah.
`
` Q About how long ago was that? Q About how long ago was that?
`
` Q About how long ago was that? Q About how long ago was that?
` A About a year ago.
`
` Q Okay. I'll quickly just go through Q Okay. I'll quickly just go through
`
` Q Okay. I'll quickly just go through Q Okay. I'll quickly just go through
`
`some ground rules with you to make sure we're onsome ground rules with you to make sure we're on
`
`some ground rules with you to make sure we're onsome ground rules with you to make sure we're on
`
`the same page.the same page.
`
`the same page.the same page.
` A Mm-hmm.
`
` Q If you could, wait for me to finish my Q If you could, wait for me to finish my
`
` Q If you could, wait for me to finish my Q If you could, wait for me to finish my
`
`question before you begin answering, andquestion before you begin answering, and
`
`question before you begin answering, andquestion before you begin answering, and
`
`similarly, I'll wait for you to finish yoursimilarly, I'll wait for you to finish your
`
`similarly, I'll wait for you to finish yoursimilarly, I'll wait for you to finish your
`
`answer before I ask another question.answer before I ask another question.
`
`answer before I ask another question.answer before I ask another question.
`
` Is that fair? Is that fair?
`
` Is that fair? Is that fair?
` A That's fair.
`
` Q If you don't understand a question I Q If you don't understand a question I
`
` Q If you don't understand a question I Q If you don't understand a question I
`
`ask, please let me know; otherwise, I'll assumeask, please let me know; otherwise, I'll assume
`
`ask, please let me know; otherwise, I'll assumeask, please let me know; otherwise, I'll assume
`
`you understood the question; is that fair?you understood the question; is that fair?
`
`you understood the question; is that fair?you understood the question; is that fair?
` A Fair.
`
` Q Now, your counsel may object at times, Q Now, your counsel may object at times,
`
` Q Now, your counsel may object at times, Q Now, your counsel may object at times,
`
`but you understand you still have to answer thebut you understand you still have to answer the
`
`but you understand you still have to answer thebut you understand you still have to answer the
`
`Page 6
`
`question, unless you're instructed not to.question, unless you're instructed not to.
`
`question, unless you're instructed not to.question, unless you're instructed not to.
`
` Do you understand that? Do you understand that?
`
` Do you understand that? Do you understand that?
` A Understand that, yeah.
`
` Q Is there any reason today that would Q Is there any reason today that would
`
` Q Is there any reason today that would Q Is there any reason today that would
`
`prevent you from testifying truthfully andprevent you from testifying truthfully and
`
`prevent you from testifying truthfully andprevent you from testifying truthfully and
`
`accurately?accurately?
`
`accurately?accurately?
` A No.
`
` Q No medication that would prevent you Q No medication that would prevent you
`
` Q No medication that would prevent you Q No medication that would prevent you
`
`from testifying truthfully and accurately?from testifying truthfully and accurately?
`
`from testifying truthfully and accurately?from testifying truthfully and accurately?
` A No.
`
` Q We'll try to take regular breaks, but Q We'll try to take regular breaks, but
`
` Q We'll try to take regular breaks, but Q We'll try to take regular breaks, but
`
`if you need a break sooner, will you let meif you need a break sooner, will you let me
`
`if you need a break sooner, will you let meif you need a break sooner, will you let me
`
`know?know?
`
`know?know?
` A Mm-hmm, yes.
`
` Q And the only thing I'll ask is if Q And the only thing I'll ask is if
`
` Q And the only thing I'll ask is if Q And the only thing I'll ask is if
`
`there's a pending question, you have to answerthere's a pending question, you have to answer
`
`there's a pending question, you have to answerthere's a pending question, you have to answer
`
`that question before we take a break.that question before we take a break.
`
`that question before we take a break.that question before we take a break.
`
` Do you understand that? Do you understand that?
`
` Do you understand that? Do you understand that?
` A I understand.
`
` Q Did you prepare for today's deposition? Q Did you prepare for today's deposition?
`
` Q Did you prepare for today's deposition? Q Did you prepare for today's deposition?
` A Yes.
`
` Q And when did you prepare for the Q And when did you prepare for the
`
` Q And when did you prepare for the Q And when did you prepare for the
`
`deposition?deposition?
`
`deposition?deposition?
` A I'm trying to understand your question
`in a larger context.
`
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` Q Oh, did you meet with counsel to Q Oh, did you meet with counsel to
`
` Q Oh, did you meet with counsel to Q Oh, did you meet with counsel to
`
`prepare for the deposition today?prepare for the deposition today?
`
`prepare for the deposition today?prepare for the deposition today?
` A For prep -- preparation today, no,
`today.
`
` Q Okay. Did you meet with counsel Q Okay. Did you meet with counsel
`
` Q Okay. Did you meet with counsel Q Okay. Did you meet with counsel
`
`yesterday to prepare for the deposition?yesterday to prepare for the deposition?
`
`yesterday to prepare for the deposition?yesterday to prepare for the deposition?
` A Yes.
`
` Q Did you meet with counsel on Monday to Q Did you meet with counsel on Monday to
`
` Q Did you meet with counsel on Monday to Q Did you meet with counsel on Monday to
`
`prepare for the deposition?prepare for the deposition?
`
`prepare for the deposition?prepare for the deposition?
` A No.
`
` Q Did you look at documents to prepare Q Did you look at documents to prepare
`
` Q Did you look at documents to prepare Q Did you look at documents to prepare
`
`for today's deposition?for today's deposition?
`
`for today's deposition?for today's deposition?
` A Yes, documents I think, yes, documents
`is a very exhaustive list, so, yeah, I don't
`know what all documents you mean, so some of the
`documents at least I looked at.
`
` Q Did you review any documents to prepare Q Did you review any documents to prepare
`
` Q Did you review any documents to prepare Q Did you review any documents to prepare
`
`that have not already been submitted in thisthat have not already been submitted in this
`
`that have not already been submitted in thisthat have not already been submitted in this
`
`proceeding?proceeding?
`
`proceeding?proceeding?
` A Not submitted, no.
`
` Q You've been retained as an expert Q You've been retained as an expert
`
` Q You've been retained as an expert Q You've been retained as an expert
`
`witness in this matter; is that right?witness in this matter; is that right?
`
`witness in this matter; is that right?witness in this matter; is that right?
` A That's right.
`
` Q And you've been retained by Bedgear? Q And you've been retained by Bedgear?
`
` Q And you've been retained by Bedgear? Q And you've been retained by Bedgear?
` A Yes.
`
`Page 8
`
` Q And you're being compensated for your Q And you're being compensated for your
`
` Q And you're being compensated for your Q And you're being compensated for your
`
`time spent working on this matter?time spent working on this matter?
`
`time spent working on this matter?time spent working on this matter?
` A Yes.
`
` Q What hourly rate are you charging for Q What hourly rate are you charging for
`
` Q What hourly rate are you charging for Q What hourly rate are you charging for
`
`your time?your time?
`
`your time?your time?
` A 250.
`
` Q About how much total have you billed on Q About how much total have you billed on
`
` Q About how much total have you billed on Q About how much total have you billed on
`
`this matter to date?this matter to date?
`
`this matter to date?this matter to date?
` A To date, I don't remember off my
`head -- off my head I can -- I can take a rough
`guess. Maybe -- maybe at a hundred hours.
`
` Q And so for a hundred hours, that would Q And so for a hundred hours, that would
`
` Q And so for a hundred hours, that would Q And so for a hundred hours, that would
`
`be about $25,000?be about $25,000?
`
`be about $25,000?be about $25,000?
` A That's true.
`
` Q Now, you've served as an expert witness Q Now, you've served as an expert witness
`
` Q Now, you've served as an expert witness Q Now, you've served as an expert witness
`
`in the past; is that right?in the past; is that right?
`
`in the past; is that right?in the past; is that right?
` A Right.
`
` Q Who besides counsel have you had Q Who besides counsel have you had
`
` Q Who besides counsel have you had Q Who besides counsel have you had
`
`discussions with regarding this matter?discussions with regarding this matter?
`
`discussions with regarding this matter?discussions with regarding this matter?
` A Besides counsel? You mean -- which
`counsel are you talking about?
`
` Q So I assume you've been working with Q So I assume you've been working with
`
` Q So I assume you've been working with Q So I assume you've been working with
`
`Mr. Walden who is there with you on this matter?Mr. Walden who is there with you on this matter?
`
`Mr. Walden who is there with you on this matter?Mr. Walden who is there with you on this matter?
` A Mm-hmm.
`
` Q And I -- have you been working with Q And I -- have you been working with
`
` Q And I -- have you been working with Q And I -- have you been working with
`
`
`www.alaris.uswww.alaris.us
`
`www.alaris.uswww.alaris.us
`
`
`ALARIS LITIGATION SERVICESALARIS LITIGATION SERVICES
`
`ALARIS LITIGATION SERVICESALARIS LITIGATION SERVICES
`
`Phone: 1.800.280.3376Phone: 1.800.280.3376
`
`Phone: 1.800.280.3376Phone: 1.800.280.3376
`
`2 (Pages 5 to 8)
`
`
`Fax: 314.644.1334Fax: 314.644.1334
`
`Fax: 314.644.1334Fax: 314.644.1334
`
`IPR2017-00351
`Fredman EX1061 Page 2
`
`

`

`
`DR. RADHAKRISHNAIAH PARACHURU 12/20/2017DR. RADHAKRISHNAIAH PARACHURU 12/20/2017
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`DR. RADHAKRISHNAIAH PARACHURU 12/20/2017DR. RADHAKRISHNAIAH PARACHURU 12/20/2017
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`Page 9
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`other lawyers at his law firm as well?other lawyers at his law firm as well?
`
`other lawyers at his law firm as well?other lawyers at his law firm as well?
` A I've been working with Alex, Alex,
`Mr. -- Mr. Fabiani, Frank Fabiani, and I also
`worked with Mr. Hassan Albakri.
`
` Q Okay. Besides Alex, Mr. Fabiani and Q Okay. Besides Alex, Mr. Fabiani and
`
` Q Okay. Besides Alex, Mr. Fabiani and Q Okay. Besides Alex, Mr. Fabiani and
`
`Mr. Albakri, is there any other counsel youMr. Albakri, is there any other counsel you
`
`Mr. Albakri, is there any other counsel youMr. Albakri, is there any other counsel you
`
`worked with on this matter?worked with on this matter?
`
`worked with on this matter?worked with on this matter?
` A No.
`
` Q And besides that counsel, have you had Q And besides that counsel, have you had
`
` Q And besides that counsel, have you had Q And besides that counsel, have you had
`
`discussions with anyone else regarding thisdiscussions with anyone else regarding this
`
`discussions with anyone else regarding thisdiscussions with anyone else regarding this
`
`matter?matter?
`
`matter?matter?
` A No -- oh, yeah, in -- actually -- yeah,
`in the beginning, before -- before I actually
`started, at that stage, I probably had a very
`brief con- -- conversation with -- with someone
`from Bedgear, that was -- that was a very
`generic type of conversation, nothing much.
`
` Q And who did you speak with at Bedgear? Q And who did you speak with at Bedgear?
`
` Q And who did you speak with at Bedgear? Q And who did you speak with at Bedgear?
` A I don't remember the name off my head
`now, thank you.
`
` Q And when did you speak with someone at Q And when did you speak with someone at
`
` Q And when did you speak with someone at Q And when did you speak with someone at
`
`Bedgear?Bedgear?
`
`Bedgear?Bedgear?
` A During my first visit to the law
`office, Bryan Cave law office when I came to
`learn more about this case, at that time.
`
`Page 10
`
`
` Q So during your first visit to Bryan Q So during your first visit to Bryan
`
` Q So during your first visit to Bryan Q So during your first visit to Bryan
`
`Cave's law office?Cave's law office?
`
`Cave's law office?Cave's law office?
` A Yes.
`
` Q Do you know, did you speak with the Q Do you know, did you speak with the
`
` Q Do you know, did you speak with the Q Do you know, did you speak with the
`
`inventor on the patents, Eugene Alletto?inventor on the patents, Eugene Alletto?
`
`inventor on the patents, Eugene Alletto?inventor on the patents, Eugene Alletto?
` A No, I did not.
`
` Q And what did you discuss with Q And what did you discuss with
`
` Q And what did you discuss with Q And what did you discuss with
`
`Bedgear -- with the person at Bedgear about thisBedgear -- with the person at Bedgear about this
`
`Bedgear -- with the person at Bedgear about thisBedgear -- with the person at Bedgear about this
`
`matter?matter?
`
`matter?matter?
` A Not much, actually, I -- it was an
`intro- -- intro- -- introduction of myself to
`her, mostly an introduct- -- introductory
`meeting. And I think she -- I -- it may be at
`the most for about five to six minutes and she
`complimented me on my background. That's all
`that happened at that meeting.
`
` Q Did you discuss the patents at issue on Q Did you discuss the patents at issue on
`
` Q Did you discuss the patents at issue on Q Did you discuss the patents at issue on
`
`that call?that call?
`
`that call?that call?
` A No.
`
` Q Is there anything else you discussed on Q Is there anything else you discussed on
`
` Q Is there anything else you discussed on Q Is there anything else you discussed on
`
`that call that you haven't described?that call that you haven't described?
`
`that call that you haven't described?that call that you haven't described?
` A No.
`
` Q Have you worked with any of the counsel Q Have you worked with any of the counsel
`
` Q Have you worked with any of the counsel Q Have you worked with any of the counsel
`
`you're working with on this case on any prioryou're working with on this case on any prior
`
`you're working with on this case on any prioryou're working with on this case on any prior
`
`matters?matters?
`
`matters?matters?
`
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` A No.
`
` Q Have you worked with anybody at the Q Have you worked with anybody at the
`
` Q Have you worked with anybody at the Q Have you worked with anybody at the
`
`Bryan Cave law firm previously?Bryan Cave law firm previously?
`
`Bryan Cave law firm previously?Bryan Cave law firm previously?
` A No.
`
` Q Were you familiar with Bedgear prior to Q Were you familiar with Bedgear prior to
`
` Q Were you familiar with Bedgear prior to Q Were you familiar with Bedgear prior to
`
`this case?this case?
`
`this case?this case?
` A Familiar -- familiar in what sense?
`
` Q Did you know of Bedgear before this Q Did you know of Bedgear before this
`
` Q Did you know of Bedgear before this Q Did you know of Bedgear before this
`
`matter?matter?
`
`matter?matter?
` A I heard of Bedgear before the matter.
`
` Q Did you know anyone at Bedgear before Q Did you know anyone at Bedgear before
`
` Q Did you know anyone at Bedgear before Q Did you know anyone at Bedgear before
`
`this matter?this matter?
`
`this matter?this matter?
` A No.
`
` Q Are you familiar with Fredman Bros. Q Are you familiar with Fredman Bros.
`
` Q Are you familiar with Fredman Bros. Q Are you familiar with Fredman Bros.
`
`Furniture Company, also known as Glideaway?Furniture Company, also known as Glideaway?
`
`Furniture Company, also known as Glideaway?Furniture Company, also known as Glideaway?
` A Again, I -- I want you to explain what
`you mean by "familiar."
`
` Q Sure. Q Sure.
`
` Q Sure. Q Sure.
`
` Had you heard of Fredman Bros. Had you heard of Fredman Bros.
`
` Had you heard of Fredman Bros. Had you heard of Fredman Bros.
`
`Furniture Company or Glideaway before this case?Furniture Company or Glideaway before this case?
`
`Furniture Company or Glideaway before this case?Furniture Company or Glideaway before this case?
` A I heard of the name, yeah.
`
` Q And do you know anybody at Fredman Q And do you know anybody at Fredman
`
` Q And do you know anybody at Fredman Q And do you know anybody at Fredman
`
`Bros. Furniture Company or Glideaway?Bros. Furniture Company or Glideaway?
`
`Bros. Furniture Company or Glideaway?Bros. Furniture Company or Glideaway?
` A No.
`
` Q Did you know me or my law firm, Erise Q Did you know me or my law firm, Erise
`
` Q Did you know me or my law firm, Erise Q Did you know me or my law firm, Erise
`
`Page 12
`
`
`IP, prior to this matter?IP, prior to this matter?
`
`IP, prior to this matter?IP, prior to this matter?
` A No.
`
` Q And how was it that you came to work on Q And how was it that you came to work on
`
` Q And how was it that you came to work on Q And how was it that you came to work on
`
`this matter?this matter?
`
`this matter?this matter?
` A Can you -- can you repeat that
`question, I'm trying to understand the context
`of that.
`
` Q Sure. Q Sure.
`
` Q Sure. Q Sure.
`
` How did Bryan Cave find you for this How did Bryan Cave find you for this
`
` How did Bryan Cave find you for this How did Bryan Cave find you for this
`
`matter?matter?
`
`matter?matter?
` A How did they find me? Actually, yeah,
`I have been contacted at -- by Hassan Albakri, I
`did not know Hassan Albakri when he contacted
`me. I do not know how he knew about me.
`
` Q So Hassan Albakri contacted you about Q So Hassan Albakri contacted you about
`
` Q So Hassan Albakri contacted you about Q So Hassan Albakri contacted you about
`
`this matter?this matter?
`
`this matter?this matter?
` A Right.
`
` Q Did they find you through an expert Q Did they find you through an expert
`
` Q Did they find you through an expert Q Did they find you through an expert
`
`referral service?referral service?
`
`referral service?referral service?
` A I'm not aware of that.
`
` Q Okay. Dr. Parachuru, you understand Q Okay. Dr. Parachuru, you understand
`
` Q Okay. Dr. Parachuru, you understand Q Okay. Dr. Parachuru, you understand
`
`that this first deposition this morning is forthat this first deposition this morning is for
`
`that this first deposition this morning is forthat this first deposition this morning is for
`
`three separate Inter Partes review proceedings?three separate Inter Partes review proceedings?
`
`three separate Inter Partes review proceedings?three separate Inter Partes review proceedings?
` A Yes.
`
` Q Is that right? Q Is that right?
`
` Q Is that right? Q Is that right?
`
`
`www.alaris.uswww.alaris.us
`
`www.alaris.uswww.alaris.us
`
`
`ALARIS LITIGATION SERVICESALARIS LITIGATION SERVICES
`
`ALARIS LITIGATION SERVICESALARIS LITIGATION SERVICES
`
`Phone: 1.800.280.3376Phone: 1.800.280.3376
`
`Phone: 1.800.280.3376Phone: 1.800.280.3376
`
`3 (Pages 9 to 12)
`
`
`Fax: 314.644.1334Fax: 314.644.1334
`
`Fax: 314.644.1334Fax: 314.644.1334
`
`IPR2017-00351
`Fredman EX1061 Page 3
`
`

`

`
`DR. RADHAKRISHNAIAH PARACHURU 12/20/2017DR. RADHAKRISHNAIAH PARACHURU 12/20/2017
`
`DR. RADHAKRISHNAIAH PARACHURU 12/20/2017DR. RADHAKRISHNAIAH PARACHURU 12/20/2017
`
`Page 13
`
` A Correct.
`
` Q And you understand that those three Q And you understand that those three
`
` Q And you understand that those three Q And you understand that those three
`
`proceedings are IPR 2017-00350 regarding theproceedings are IPR 2017-00350 regarding the
`
`proceedings are IPR 2017-00350 regarding theproceedings are IPR 2017-00350 regarding the
`
`'332 patent?'332 patent?
`
`'332 patent?'332 patent?
` A Yes, I -- I identify that as --
`
` Q IPR -- Q IPR --
`
` Q IPR -- Q IPR --
` A Mm-hmm.
`
` Q And IPR 2017-00351 regarding the '883 Q And IPR 2017-00351 regarding the '883
`
` Q And IPR 2017-00351 regarding the '883 Q And IPR 2017-00351 regarding the '883
`
`patent?patent?
`
`patent?patent?
` A Mm-hmm.
`
` Q And IPR 2017-00352 regarding the '134 Q And IPR 2017-00352 regarding the '134
`
` Q And IPR 2017-00352 regarding the '134 Q And IPR 2017-00352 regarding the '134
`
`patent?patent?
`
`patent?patent?
` A Right.
`
` Q And you understand those are the three Q And you understand those are the three
`
` Q And you understand those are the three Q And you understand those are the three
`
`proceedings you're testifying about thisproceedings you're testifying about this
`
`proceedings you're testifying about thisproceedings you're testifying about this
`
`morning?morning?
`
`morning?morning?
` A Yes.
` MR. MUDD: Sadie, if you could,
` please, hand the witness from the
` folders marked 1, 6 and 8 of the three
` patents, so you should be handing to
` Dr. Parachuru what's been marked
` Exhibit 1001, which is the '332 patent;
` Exhibit 1047, the '883 patent; and
` Exhibit 1049, the '134 patent.
`
`Page 14
`
` (Fredman Exhibit 1001, Exhibit
` 1001 Patent US 8,887,332, having
` been previously marked, was
` introduced into the record.)
` (Fredman Exhibit 1047, Patent US
` 9,015,883, having been previously
` marked, was introduced into the
` record.)
` (Fredman Exhibit 1049, Patent US
` 8,646,134, having been previously
` marked, was introduced into the
` record.)
`
` Q Dr. Parachuru, are these three exhibits Q Dr. Parachuru, are these three exhibits
`
` Q Dr. Parachuru, are these three exhibits Q Dr. Parachuru, are these three exhibits
`
`the three patents you understand are at issue inthe three patents you understand are at issue in
`
`the three patents you understand are at issue inthe three patents you understand are at issue in
`
`these three IPR proceedings?these three IPR proceedings?
`
`these three IPR proceedings?these three IPR proceedings?
` A Yes.
`
` Q And have you reviewed these patents? Q And have you reviewed these patents?
`
` Q And have you reviewed these patents? Q And have you reviewed these patents?
` A Yes.
`
` Q Are you familiar with them? Q Are you familiar with them?
`
` Q Are you familiar with them? Q Are you familiar with them?
` A I'm familiar with them.
`
` Q And you understand these three patents Q And you understand these three patents
`
` Q And you understand these three patents Q And you understand these three patents
`
`all share the same written description?all share the same written description?
`
`all share the same written description?all share the same written description?
` A Yes.
`
` Q Do you understand that? Q Do you understand that?
`
` Q Do you understand that? Q Do you understand that?
` A Yes.
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1
`2
`3
`4
`5
`6
`7
`8
`9
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`Page 15
`
` Q So for the sake of simplicity, if I Q So for the sake of simplicity, if I
`
` Q So for the sake of simplicity, if I Q So for the sake of simplicity, if I
`
`refer to the written description of the '332refer to the written description of the '332
`
`refer to the written description of the '332refer to the written description of the '332
`
`patent, I'm also referring to the '883 and '134patent, I'm also referring to the '883 and '134
`
`patent, I'm also referring to the '883 and '134patent, I'm also referring to the '883 and '134
`
`patents.patents.
`
`patents.patents.
`
` Does that work okay for you? Does that work okay for you?
`
` Does that work okay for you? Does that work okay for you?
` A That work okay for me, yeah.
`
` Q And so any discussions we have Q And so any discussions we have
`
` Q And so any discussions we have Q And so any discussions we have
`
`regarding the description in the '332 patentregarding the description in the '332 patent
`
`regarding the description in the '332 patentregarding the description in the '332 patent
`
`would also apply to the '883 and '134 patents;would also apply to the '883 and '134 patents;
`
`would also apply to the '883 and '134 patents;would also apply to the '883 and '134 patents;
`
`is that fair?is that fair?
`
`is that fair?is that fair?
` A Yeah, for the most part.
`
` Q So except for the claims at the end, Q So except for the claims at the end,
`
` Q So except for the claims at the end, Q So except for the claims at the end,
`
`the written description is the same for thosethe written description is the same for those
`
`the written description is the same for thosethe written description is the same for those
`
`three patents?three patents?
`
`three patents?three patents?
` A Again, for the most part, yeah.
`
` Q And if I want to refer to a specific Q And if I want to refer to a specific
`
` Q And if I want to refer to a specific Q And if I want to refer to a specific
`
`claim at the end of the patents, I'll use thatclaim at the end of the patents, I'll use that
`
`claim at the end of the patents, I'll use thatclaim at the end of the patents, I'll use that
`
`specific patent; is that fair?specific patent; is that fair?
`
`specific patent; is that fair?specific patent; is that fair?
` A Yes, specific claim, yes, sir.
` MR. MUDD: Sadie, if you could hand
` the witness the document from Folder 2,
` which is Exhibit 2004, the Declaration
` in Support of Patent Owner's response.
` (Bedgear Exhibit 2004, Declaration
` of Dr. Radhakrishnaiah Parachuru,
`
`Page 16
` having been previously marked, was
` introduced into the record.)
`
` Q Do you have Bedgear Exhibit 2004? Q Do you have Bedgear Exhibit 2004?
`
` Q Do you have Bedgear Exhibit 2004? Q Do you have Bedgear Exhibit 2004?
` A Yes, I received it.
`
` Q This is a copy of your declaration; is Q This is a copy of your declaration;