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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`------------------x
`GOOGLE LLC,
`) Case No. IPR2017-00913
` Petitioner, ) U.S. Patent No. 8,402,384
`v.
`)
`BLACKBERRY LTD., ) Case No. IPR2017-00914
` Patent Owner.) U.S. Patent No. 8,713,466
`------------------x
`
` DEPOSITION OF DANIEL R. OLSEN, JR., PH.D.
`Tuesday, November 21, 2017
`Washington, D.C.
`
`Reported by: Lori J. Goodin, RPR, CLR, CRR,
`RSA, California CSR #13959
`Job No: 133575
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`TSG Reporting 877-702-9580
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`------------------x
`GOOGLE LLC,
`) Case No. IPR2017-00913
` Petitioner, ) U.S. Patent No. 8,402,384
`v.
`)
`BLACKBERRY LTD., ) Case No. IPR2017-00914
` Patent Owner.) U.S. Patent No. 8,713,466
`------------------x
`
` DEPOSITION OF DANIEL R. OLSEN, JR., PH.D.
`Tuesday, November 21, 2017
`Washington, D.C.
`
`Reported by: Lori J. Goodin, RPR, CLR, CRR,
`RSA, California CSR #13959
`Job No: 133575
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`TSG Reporting 877-702-9580
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` November 21, 2017
` 8:57 a.m.
`
` Deposition of DANIEL R.
`OLSEN, JR., PH.D., held at offices of Paul
`Hastings LLP, 875 15th Street, N.W., Washington,
`D.C., before Lori J. Goodin, RPR, CLR, CRR,
`RSA, California CSR #13959, and a Notary
`Public in and for the District of Columbia.
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` A P P E A R A N C E S:
`
`ON BEHALF OF THE PETITIONER:
` JOSEPH PALYS, ESQUIRE
` PHILLIP CITROEN, ESQUIRE
` ARVIND JAIRAM, ESQUIRE
` PAUL HASTINGS
` 875 15th Street, N.W.
` Washington, DC 20005
`
`ON BEHALF OF THE PATENT OWNER:
` SAMUEL DILLON, ESQUIRE
` SHARON LEE, ESQUIRE
` SIDLEY AUSTIN
` 1501 K Street, N.W.
` Washington, DC 20005
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` DANIEL R. OLSEN, Ph.D.
` * * *
`Whereupon,
` DANIEL R. OLSEN, JR., Ph.D.,
`a witness called for examination, having been
`first duly sworn, was examined and testified as
`follows:
` * * *
` EXAMINATION
`BY MS. LEE:
` Q. Good morning, Dr. Olsen.
` A. Good morning.
` Q. So, I know you were deposed on
`Friday, but I just want to remind ourselves of
`some of the rules for the deposition.
` A. Okay.
` Q. So, the first is I'm going to ask
`you questions today, and you'll answer them.
`And from time to time, your counsel may object,
`but you must still answer the question, unless
`your attorney instructs you not to do so.
` Do you understand?
` A. Yes.
` Q. And we want to be sure to answer
`questions verbally and not make physical
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` DANIEL R. OLSEN, Ph.D.
`gestures since it is being transcribed.
` Do you understand that?
` A. Yes.
` Q. Okay. And, if you don't understand
`a question, you can ask me to clarify or to
`repeat the question, and I will be happy to do
`so, but otherwise I will assume that you have
`understood my question.
` Is that fair?
` A. Yes.
` Q. And if for any reason you need a
`break, please ask, and I will do my best to
`accommodate you, but I will ask that you answer
`a question if there is one pending before we
`take the break.
` Is that okay?
` A. Uh-huh.
` Q. Is there any reason you cannot
`provide truthful testimony today?
` A. No.
` Q. Okay. You understand that today we
`will be discussing two proceedings:
`IPR 2017-00913 and IPR 2017-00914.
` A. Oh, yes.
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` DANIEL R. OLSEN, Ph.D.
` Q. Is that right?
` A. I was looking at different numbers.
`Yes, I understand that.
` Q. I will refer to these proceedings by
`using the last three numbers of the IPR case
`number, so 913 and 914. Is that okay?
` A. Yes.
` Q. The 913 proceeding involves U.S.
`patent number 8,402,384. Correct?
` A. Correct.
` Q. And, I will be referring to that as
`the '384 patent. Is that okay?
` A. That will be good.
` Q. And the 914 proceeding involves U.S.
`patent number 8,713,466, correct?
` A. Correct.
` Q. And I will be referring to that as
`the '466 patent. Is that okay?
` A. Okay.
` Q. And, you submitted a declaration in
`each of these proceedings, correct?
` A. I did.
` Q. And, I see you have some binders in
`front of you. What is in them?
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` DANIEL R. OLSEN, Ph.D.
` A. Here I have my declarations.
` Q. In the two proceedings?
` A. Yes, they are both together here.
`Here I have exhibits in the 914, and here I
`have exhibits in the 913.
` Q. And are those exhibits the exhibits
`that are cited in your declaration?
` A. Yes, they are.
` Q. Are there any additional exhibits in
`there?
` A. No.
` Q. Are there any markings or notes that
`you've made in the documents in those binders?
` A. In my declaration I have put tabs on
`each claim term, claim item -- claim element,
`excuse me.
` Q. Any other markings?
` A. No.
` Q. How about on those exhibits?
` A. Nope.
` Q. I will refer to these declarations
`by using the last three numbers of the IPR case
`number. So, if I refer to your 913
`declaration, I'm referring to your declaration
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` DANIEL R. OLSEN, Ph.D.
`in IPR 2017-00913. Does that make sense?
` A. I understand.
` Q. Okay. And you signed each of these
`two declarations, correct?
` A. I did.
` Q. And did anyone help you prepare the
`913 declaration?
` A. Counsel.
` Q. Which counsel?
` A. Phillip Citroen and Joe Palys.
` Q. Anyone else?
` A. No.
` Q. Did anyone help you prepare the 914
`declaration?
` A. Same answer.
` Q. How long did you personally spend
`preparing the 913 declaration?
` A. Between 20 and 60 hours.
` Q. And this is just for the 913
`declaration; is that right?
` A. Yes.
` Q. And how long did you spend preparing
`the 914 declaration?
` A. Similar amount of time.
`
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` DANIEL R. OLSEN, Ph.D.
` Q. Did you rely on any documents when
`preparing the 913 declaration?
` A. The ones that are listed in my
`declaration, I did.
` Q. And, is that list in Paragraph 10 of
`your -- let's start with the 913 declaration.
` A. 913, Paragraph 10. I have that.
` Q. Does this, does Paragraph 10 list
`all of the documents that you relied on in
`preparing your 913 declaration?
` A. Yes, it does.
` Q. Did you rely on any documents that
`are not listed in Paragraph 10?
` A. I did not.
` Q. Okay. Let's turn to your 914
`declaration. Does Paragraph 10 of your 914
`declaration list all of the documents that you
`considered in preparing this declaration?
` A. Yes, it does.
` Q. Did you rely on any documents that
`are not listed here?
` A. I did not.
` Q. Okay. Were any of the documents
`listed in those two paragraphs provided to you?
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` DANIEL R. OLSEN, Ph.D.
` A. Yes.
` Q. Which ones?
` A. The patent obviously. Prosecution
`history, Cadiz, all of them. I provided Inside
`Macintosh and Macintosh Human Interface
`Guidelines.
` Q. So, other than Inside Macintosh and
`Macintosh Human Interface Guidelines, the rest
`were provided to you?
` A. That is correct.
` Q. And were they provided to you by
`counsel?
` A. Yes.
` Q. In preparing your 913 declaration,
`did you review the '384 file history?
` A. The '384 file history -- Oh, I'm
`sorry.
` Q. That would be the prosecution
`history for the '384 patent?
` A. I did review it briefly.
` Q. Which parts did you review?
` A. I couldn't tell you at this time.
` Q. But you didn't review the whole
`thing?
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` DANIEL R. OLSEN, Ph.D.
` A. I looked through it --
` MR. CITROEN: Objection, objection,
` mischaracterizes his testimony.
` THE WITNESS: I looked through it.
` I couldn't tell you which parts. It is a
` big document.
`BY MS. LEE:
` Q. Did you review the '466 prosecution
`history when preparing your declarations?
` A. Yes, I did.
` Q. Which parts did you review?
` A. I couldn't tell you at this time.
`It is a big document.
` Q. So, is it fair to say that you
`didn't review the entire prosecution history?
` MR. CITROEN: Objection to the
` extent it mischaracterizes testimony.
` THE WITNESS: So, I looked through
` it. I couldn't tell you which parts I did
` or did not, or what -- I couldn't tell you
` at this time.
`BY MS. LEE:
` Q. How long would you say you spent
`reviewing the prosecution history of the '384
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` DANIEL R. OLSEN, Ph.D.
`patent?
` A. I have --
` MR. CITROEN: Objection, form.
` THE WITNESS: I have no idea.
`BY MS. LEE:
` Q. Can you venture a guess?
` A. Some hours, less.
` Q. Less than five?
` A. Yes.
` Q. Less than two?
` A. Probably.
` Q. And, what about for the '466 file
`history. How long did you spend reviewing
`that?
` MR. CITROEN: Objection, form.
` THE WITNESS: Not very long.
`BY MS. LEE:
` Q. Less than an hour?
` A. Maybe. Maybe a little more.
` Q. You are aware that the '384 patent
`is a parent to the '466 patent, correct?
` MR. CITROEN: Objection, form to the
` extent it calls for a legal conclusion.
` THE WITNESS: By parent, I think it
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` DANIEL R. OLSEN, Ph.D.
` is a continuation of the '384, if I
` remember correctly, if that is what you
` meant.
`BY MS. LEE:
` Q. Okay. In Paragraph 10 of your 914
`declaration --
` A. Yes.
` Q. -- in the fourth line -- or, sorry,
`from the third line to the fourth line, you
`have, "The prosecution file history for U.S.
`patent number 8,402,384, which is the parent of
`the '466 patent."
` A. It says that.
` Q. So, what did you understand parent
`of the '466 patent to mean, when you wrote
`that?
` A. The '466 was a continuation of the
`'384.
` Q. How did you prepare for today's
`deposition?
` A. Spent time with counsel. Reviewed
`documents.
` Q. Which counsel did you meet with?
` A. Phillip Citroen, Joe Palys.
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` DANIEL R. OLSEN, Ph.D.
` Q. Anyone else?
` A. Arvind --
` THE WITNESS: I forgot your last
` name, Arvind. I'm sorry.
` He was there also.
`BY MS. LEE:
` Q. Anyone else?
` A. No.
` Q. And how long did you meet with
`counsel for?
` A. A couple of days.
` Q. Is that two days?
` A. Yes.
` Q. How many hours per each day?
` A. Between eight and ten.
` Q. That is for each day?
` A. Yes.
` Q. And how many hours did you spend
`reviewing documents?
` MR. CITROEN: Objection, form.
` THE WITNESS: Which time? I mean,
` over the entire course of preparing the
` declaration?
`BY MS. LEE:
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` DANIEL R. OLSEN, Ph.D.
` Q. How long did you spend reviewing
`documents to prepare for today's deposition?
` A. Oh, thank you. Four or five hours.
` Q. And what documents did you look at
`to prepare for today's deposition?
` A. My declarations and the exhibits.
` Q. Any other documents?
` A. No.
` Q. Have you read Blackberry's
`preliminary responses in these proceedings?
` A. No.
` Q. Have you read the board's decisions
`to institute review in these proceedings?
` A. No.
` Q. Have you ever been deposed before?
` A. Yes.
` Q. How many times have you been
`deposed?
` A. One more than last time. Between
`five and eight.
` Q. And in what context were those
`depositions?
` A. Let's see. First time was relative
`to the Communications Decency Act. I was an
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` DANIEL R. OLSEN, Ph.D.
`expert witness on behalf of the government.
`There was the Child Online Protection Act,
`again on behalf of the government.
` There may have been a couple of
`times in state actions relative to those two.
`I can't remember if we reached deposition or
`not.
` There have been a variety of patent
`cases.
` Q. Can you be more specific about the
`patent cases that you provided depositions in?
` A. The one that stands out the most to
`me at this point would be ITC, Apple versus
`Samsung.
` Q. And which party were you retained on
`behalf of?
` A. Samsung.
` Q. Any other patent cases?
` A. There were others, but I don't have
`a list before me.
` Q. Do you remember what form they were
`in?
` A. A couple of them were regarding
`business method reviews.
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` DANIEL R. OLSEN, Ph.D.
` Q. Covered business method reviews?
` A. I think so, yes.
` Q. Any others?
` A. Maybe. I don't remember at this
`time. Those are the ones that stand out.
` Q. Are you aware that the '384 and the
`'466 patents were asserted in litigation?
` A. Yes.
` Q. And how do you know that?
` A. It was mentioned sometime during
`preparation.
` Q. Do you know the status of that
`litigation?
` A. I have no idea.
` Q. Do you know the parties of that
`litigation?
` A. No. Not in detail, no.
` Q. Have you ever seen any analysis
`regarding infringement of the '384 patent?
` A. I have not.
` Q. What about for the '466 patent?
` A. I have not.
` Q. And other than your two
`declarations, have you ever seen any analysis
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` DANIEL R. OLSEN, Ph.D.
`regarding invalidity of the '384 patent?
` A. I have not.
` Q. And what about for the '466 patent?
` A. I have not.
` Q. Have you ever seen any draft
`complaints involving the '384 patent?
` A. No.
` Q. And what about for the '466 patent?
` A. No.
` Q. Have you ever worked on mobile
`devices or cellular telephones?
` A. Yes.
` Q. And what type of work did you do?
` A. If we would look in my CV, you will
`find a variety of papers that describe the work
`I have done.
` Q. Do the papers in your CV list the
`universe of work that you've performed
`regarding mobile devices and cellular
`telephones?
` A. I'm going to translate that to mean
`that, does that represent everything I've ever
`done in cellular telephones, is that what you
`meant?
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` DANIEL R. OLSEN, Ph.D.
` Q. Yes.
` A. No. No. I have done applications.
`I have done things to teach courses. I have
`written books.
` Q. Let's turn to your CV. Do you have
`a copy of it?
` A. I believe so, yes.
` Q. Should be Exhibit 1003 in both
`proceedings.
` (Whereupon, previously marked
` Exhibit 1003, first referral.)
` THE WITNESS: Okay. I'm currently
` in the '384, and I have that.
`BY MS. LEE:
` Q. Let's start with your papers. You
`said that these papers describe the work that
`you've done in the 2000 to 2004 time period.
`Which of these papers describe work that you've
`done in the mobile device or cellular telephone
`space?
` A. 2000 to 2004. Is that correct?
` Q. Yes.
` A. Okay. I'm going to start with 2000
`and work up. Okay. So, in 2000 there is a
`
`TSG Reporting 877-702-9580
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`Google LLC v. Blackberry Ltd., IPR2017-00914, Patent Owner Exhibit 2009, p. 19
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` DANIEL R. OLSEN, Ph.D.
`paper called Cross-Modal Interaction in XWeb.
` A paper in 2001, Join and Capture:
`A Model for Nomadic Interaction.
` 2004, you said?
` Q. Yes.
` A. Yes, I think that is the ones I find
`here.
` Q. Let's start with the first one that
`you identified, which is Cross-modal
`Interaction in XWeb. What was that paper
`about?
` A. That paper was a, that paper was a
`system to deal with the fact that many people
`carry many devices, and there are many other
`devices that they may find in their
`environment.
` And so what we wanted to be able to
`do is we wanted to be able to transfer
`interactive behavior among all of those
`devices.
` So, cell phones, handheld devices
`would be some of them. There would be screens.
`There would be microphones. There would be
`cameras.
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`TSG Reporting 877-702-9580
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`Google LLC v. Blackberry Ltd., IPR2017-00914, Patent Owner Exhibit 2009, p. 20
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` DANIEL R. OLSEN, Ph.D.
` We basically designed an
`architecture that would cover a broad range of
`things. We designed the network protocols that
`deal with them.
` We worked a lot in the user
`interfaces of the cell phones, the other
`devices that we were capturing.
` Q. You said that the paper dealt with
`the fact that many people carried many devices,
`and you said cell phones, handheld devices,
`microphones, cameras were some of them. Is
`that right?
` A. Yes.
` Q. So, what other devices did you take
`into account?
` A. My favorite --
` MR. CITROEN: Objection, form.
` THE WITNESS: I'm sorry.
` My favorite was a ring that
` contained a Java interpreter on it.
`BY MS. LEE:
` Q. Any others?
` A. Big screens.
` Q. When you say big screens, what do
`
`TSG Reporting 877-702-9580
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`Google LLC v. Blackberry Ltd., IPR2017-00914, Patent Owner Exhibit 2009, p. 21
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` DANIEL R. OLSEN, Ph.D.
`you mean?
` A. The size of the white board there.
`Sorry, like 70-inch.
` Q. Like projectors?
` A. Actually we were using
`rear-projected screens. We were using a
`television. A big television.
` Q. Were you developing user interfaces
`for the big screen and the handheld devices and
`mobile telephones in this project?
` A. Yes, that is all of our research is
`user interfaces --
` Q. Okay.
` A. -- at least in that paper.
` Q. Did the big screen, like the TV,
`have the same user interface as the handheld
`devices and mobile telephones?
` A. No, that was the point of the
`research. Same application, adapted user
`interface to the device.
` Q. And why did you have to adapt the
`user interface to the user's device?
` A. There is differences in how far away
`people are from their screen. There is
`
`TSG Reporting 877-702-9580
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`Google LLC v. Blackberry Ltd., IPR2017-00914, Patent Owner Exhibit 2009, p. 22
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` DANIEL R. OLSEN, Ph.D.
`differences in how big their hands are, or
`their fingers, or size makes a big difference.
` Speed of the processor makes a
`difference. A lot of differences.
` Q. So, when you say size makes a big
`difference, is that the size of the display
`screen that makes a difference?
` A. It made a difference in how the user
`interfaces were organized, yes. Not the
`structure or the application, no.
` Q. But, the way that the user interface
`is presented to the user is adapted based on
`the size of the screen; is that correct?
` A. That would be correct, yes.
` Q. What was the name of this project?
` A. XWeb.
` Q. And who did you work with on this
`project?
` A. My graduate students.
` Q. Do you remember how many graduate
`students worked with you?
` A. On this particular project?
` Q. Yes.
` A. Their names are actually listed
`
`TSG Reporting 877-702-9580
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`Google LLC v. Blackberry Ltd., IPR2017-00914, Patent Owner Exhibit 2009, p. 23
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` DANIEL R. OLSEN, Ph.D.
`there. So, there would be one, two, three,
`four.
` Q. How long did it take you and your
`graduate students to complete this project?
` A. Well, that is hard to specify,
`because many of our projects are built out of
`fragments of other projects.
` So, total time for the whole thing,
`that project with those particular students, a
`couple of years.
` Q. So, that project with those
`particular students, does that mean --
` A. I would --
` Q. -- just the XWeb part of this
`project, the adaptation portion?
` MR. CITROEN: Objection, form.
` THE WITNESS: So, I couldn't
` actually clearly tell you this is when the
` project started and this is when the
` project ended. I can give you an estimate
` of the effort we put into it.
` To give you more details, I would
` have to go back and look at when these
` various students graduated, and when they
`
`TSG Reporting 877-702-9580
`
`Google LLC v. Blackberry Ltd., IPR2017-00914, Patent Owner Exhibit 2009, p. 24
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` DANIEL R. OLSEN, Ph.D.
` started their programs, as they
` participated in this work.
`BY MS. LEE:
` Q. And what is the estimate of the
`effort that you all put into it?
` A. So, we were all working part-time.
`I was teaching. They were going to school.
` More times in the summer, less times
`during the school year. And it was probably
`over the course of a couple of years that we
`worked on that.
` Q. Was this project funded?
` A. The answer is yes.
` Q. How much did it cost?
` A. I can't remember.
` Q. Can you ballpark it?
` A. Somewhere between 50 and 200
`thousand dollars.
` Q. Okay. The second paper that you
`identified is Join and Capture: A Model for
`Nomadic Interaction. Is that right?
` A. That's correct.
` Q. And what was this paper about?
` A. So, this paper continues on our XWeb
`
`TSG Reporting 877-702-9580
`
`Google LLC v. Blackberry Ltd., IPR2017-00914, Patent Owner Exhibit 2009, p. 25
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` DANIEL R. OLSEN, Ph.D.
`work.
` The challenge there was if all of
`these devices exist in an environment, how do I
`identify which devices I'm going to interact
`with, when I walk into a room or into someone's
`office.
` So, we developed the interaction
`techniques and the network protocols to make
`that happen.
` Q. What kind of interactions would
`these devices have with one another?
` A. So, basically what we are doing is
`we are appropriating interactive, again as with
`XWeb, various screens, various interactive
`devices, various processors, cameras,
`microphones.
` I mean we tried to cast a really
`broad net so that you could be able to write an
`application and use a variety of resources as
`you encounter them.
` Q. So, if I walk into a room with my
`cell phone, and I want to project what is on my
`phone on to the TV, is that within the scope of
`that project?
`
`TSG Reporting 877-702-9580
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`Google LLC v. Blackberry Ltd., IPR2017-00914, Patent Owner Exhibit 2009, p. 26
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` DANIEL R. OLSEN, Ph.D.
` A. Yes.
` Q. And, how would you project what is
`on my phone to the TV?
` A. So, we didn't actually project it,
`as you say. What we would do is we would
`deploy on that TV a user interface appropriate
`to the TV and appropriate to the devices that
`were connected to it.
` Q. So, when I see on my phone and what
`I see on the screen might be different; is that
`right?
` A. May be the same, may be different,
`depending on what was happening, what the
`application was.
` Being highly adaptable was the key
`to this research.
` Q. And what was the name of that
`project?
` A. Join and Capture.
` Q. And, who did you work on this
`project with?
` A. Coauthors are Travis Nielsen and
`David Parslow. They are listed there.
` Q. Was there anyone else?
`
`TSG Reporting 877-702-9580
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`Google LLC v. Blackberry Ltd., IPR2017-00914, Patent Owner Exhibit 2009, p. 27
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` DANIEL R. OLSEN, Ph.D.
` A. Probably. It was built on top of
`the things that we had in XWeb, so there would
`have been contributions from the other people
`who are listed below on the XWeb paper.
` I have a large lab of students with
`many people, and frequently there will be
`contributions from others.
` Q. And how long would say it took to
`complete this project?
` A. Again, overlapping with the XWeb
`project, I couldn't tell you this is XWeb, this
`is Join and Capture. That is not the way we
`work.
` So --
` Q. Because you've built on top of XWeb?
` A. Yes, we regularly build things, tear
`them apart, and build new things.
` Q. Are you able to estimate the effort
`that went into just the Join and Capture aspect
`of the project?
` A. Maybe another year, each of us
`working part-time, as I described earlier.
` Q. And, was this project separately
`funded?
`
`TSG Reporting 877-702-9580
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`Google LLC v. Blackberry Ltd., IPR2017-00914, Patent Owner Exhibit 2009, p. 28
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` DANIEL R. OLSEN, Ph.D.
` A. I don't know.
` Q. You also mentioned that you
`developed applications, some for teaching. Is
`that right?
` A. Yes.
` Q. Were any of those applications
`commercialized?
` A. Any application that I developed for
`teaching, was it commercialized?
` Q. Related to mobile devices and
`cellular telephones?
` A. Okay. So, applications relative to
`mobile devices and cellular telephones that I
`implemented for the purpose of teaching, is
`that the question?
` Q. Well, when I asked you earlier about
`your experience with mobile telephone -- mobile
`devices and cellular telephones, you identified
`the papers in your CV, correct?
` A. Yes.
` Q. And when I asked if the papers in
`your CV was a complete list of your experience
`with mobile devices and telephones, you said
`that you also had experience developing
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`TSG Reporting 877-702-9580
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`Google LLC v. Blackberry Ltd., IPR2017-00914, Patent Owner Exhibit 2009, p. 29
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` DANIEL R. OLSEN, Ph.D.
`applications and at least some in the context
`of teaching your classes.
` A. Yes.
` Q. So, my question is, were any of
`those applications that you referenced that
`relate to mobile -- your experience with mobile
`telephones -- mobile devices, excuse me, and
`cellular telephones, were any of those
`applications commercialized?
` A. Okay. So, if I stack up all of the
`things I think you said.
` Were the things that I said I did
`relative to mobile devices and cellular
`telephones relative to my teaching, were any of
`them commercialized? And the answer to that
`would be no.
` Q. Were there any applications that you
`developed for mobile devices or cellular
`telephones that were commercialized?
` A. There may have been something that
`they did relative to a consulting job. I can't
`remember at this time.
` Q. When you say they, who are you
`referring to?
`
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` DANIEL R. OLSEN, Ph.D.
` A. Applications that I might have
`built, that meets all of the things you were
`listing, except for teaching.
` Q. My question was, were there any
`applications that you developed for mobile
`devices or cellular telephones that were
`commercialized, and your answer was, there may
`have been something they did relative to a
`consulting job.
` A. Oh, I'm sorry. I'm sorry. Thank
`you for repeating that.
` There may have been something that I
`did relative to a consulting job. There were
`many consulting jobs over those years.
` Q. So, if I'm understanding you
`correctly, there were many consulting jobs for
`which you developed applications, but you are
`not certain if the party that you were
`consulting for commercialized those
`applications?
` A. I'm not certain if they
`commercialized, and I'm not certain at this
`point how much it involved cellular telephones
`or handheld devices.
`
`TSG Reporting 877-702-9580
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`Google LLC v. Blackberry Ltd., IPR2017-00914, Patent Owner Exhibit 2009, p. 31
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` DANIEL R. OLSEN, Ph.D.
` I did a lot of work for a lot of
`people over the years, so --
` Q. What if we narrow this to your work
`related to developing user interfaces for
`mobile devices and cellular telephones.
` Were there any user interfaces that
`you developed for mobile devices and cellular
`telephones that were commercialized or ended up
`in products that were commercialized?
` A. So, I cannot at this time identify a
`specific product, but I did a lot of work for a
`lot of different people on a lot of different
`contracts over the years.
` So, were there some? Maybe. Can I
`identify what they are today? No.
` Q. In your experience, are there any
`differences between designing and developing a
`graphical user interface for a desktop computer
`versus designing and developing a graphical
`user interface for a mobile device?
` A. So, there would be differences in
`designing, but it depends -- I have to rephrase
`that.
` It depends what we mean by
`
`TSG Reporting 877-702-9580
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`Google LLC v. Blackberry Ltd., IPR2017-00914, Patent Owner Exhibit 2009, p. 32
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` DANIEL R. OLSEN, Ph.D.
`designing. There are
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