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` UNITED STATES PATENT AND TRADEMARK OFFICE
` _______________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _______________________
` INTEL CORP., and
` CAVIUM, INC.,
` Petitioner,
` V.
` ALACRITECH, INC.,
` Patent Owner
` _______________________
` Case IPR 2017-01391
` U.S. Patent No. 7,237,036
`
` ROBERT HORST
` THURSDAY, JANUARY 25, 2018
`
` ORAL VIDEOTAPED DEPOSITION OF ROBERT HORST, produced
`as a witness at the instance of the Patent Owner and
`duly sworn, was taken in the above-styled and numbered
`cause on the 25th day of January, 2018, from 9:33 a.m.
`to 2:38 p.m., before Melinda Barre, Certified Shorthand
`Reporter in and for the State of Texas, reported by
`computerized stenotype machine at the offices of Quinn
`Emanuel Urquhart & Sullivan, LLP, 711 Louisiana Street,
`Suite 500, Houston, Texas, pursuant to the Rules of Civil
`Procedure and the provisions stated on the record or attached hereto.
`Job No. 136764
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`TSG Reporting 877-702-9580
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` INDEX
` PAGE
`Examination by Mr. Mack ...........................5
`Signature Page .................................142
`Court Reporter's Certificate ....................144
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` EXHIBITS
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`EXHIBIT DESCRIPTION PAGE
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`Exhibit 1200 Supplemental Declaration of 44
` Robert Horst, Ph.D., in Support
` of Petitions for Inter Partes
` Review
`
`Page 5
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` ROBERT HORST
` ROBERT J. HORST,
`having been first duly sworn, testified as follows:
` EXAMINATION
`QUESTIONS BY MR. MACK:
` Q. Good morning. Could you please state your full
`name and address for the record.
` A. Robert Whiting Horst at 1182 Glenn Avenue in
`San Jose, California.
` Q. And you've been deposed a number of times
`before today, correct?
` A. That's right.
` Q. You understand that you are under an oath to
`tell the truth today?
` A. Yes.
` Q. It's the same oath that you would be under if
`you were testifying live in a court of law. Do you
`understand that?
` A. Yes.
` Q. There isn't anything that would interfere with
`your ability to testify truthfully today, is there?
` A. No.
` Q. You're not on any medications that could impede
`your ability to recollect or tell the truth?
` A. No.
`
`2 (Pages 2 to 5)
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` APPEARANCES
`
`FOR THE PATENT OWNER:
` Mr. Brian Mack, Esq.
` Mr. Sean Li, Esq.
` QUINN EMANUEL URQUHART & SULLIVAN
` 50 California Street
` San Francisco, California 94111
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`FOR THE PETITIONER:
` Mr. Justin Constant, Esq.
` WEIL, GOTSHAL & MANGES
` 700 Louisiana
` Houston, Texas 77002
`
`ALSO PRESENT: Robert Birdsall, Videographer
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`Page 4
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` ROBERT HORST
` THE VIDEOGRAPHER: This is the start of
`the deposition of Dr. Robert Horst in the case styled
`Intel Corporation and Cavium, Incorporated versus
`Alacritech, Inc. in the United States Patent and
`Trademark Office, Case No. IPR 2017-01391.
` The deposition today is being held at
`711 Louisiana, Suite 500, Houston, Texas. Today's date
`is January 25th, 2018, and the time is 9:33. My name is
`Robert Birdsall, legal video specialist. The court
`reporter today is Melinda Barre. We are both with TSG
`Worldwide Reporting. Will counsel please identify
`yourselves for the record.
` MR. MACK: Brian Mack of Quinn Emanuel
`representing the plaintiff -- or the patent owner,
`Alacritech, Inc.
` MR. LI: Sean Li of Quinn Emanuel for
`Alacritech.
` MR. CONSTANT: Justin Constant with Weil
`Gotshal Manges representing petitioner, Intel
`Corporation.
` THE VIDEOGRAPHER: Thank you. Court
`Reporter, would you please swear in the witness.
`
`TSG Reporting 877-702-9580
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` ROBERT HORST
` Q. Dr. Horst, you're being compensated for your
`work in this case, correct?
` A. Yes.
` Q. And who is compensating you?
` A. Intel Corporation is compensating me.
` Q. And are your invoices paid directly by Intel
`Corporation?
` A. They are paid by Weil representing Intel.
` Q. Okay. So your invoices are paid by the law
`firm Weil Gotshal, correct?
` A. Correct.
` Q. Who do you submit your invoices to?
` A. I submit them to Weil.
` Q. And is any of your compensation being paid by
`Cavium?
` A. For the initial preparation of my depositions,
`everything was done by Weil. Later when the other --
`when Cavium joined the case, I had an invoice to them
`just for converting my declaration, primarily the title
`page, to show Cavium.
` Q. Okay. What is the date of that invoice to
`Cavium, do you recall?
` A. It would have been at the end of the month
`after Cavium submitted their IPR.
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`Page 8
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` ROBERT HORST
` A. Not in connection with this case.
` Q. How about in connection with other cases?
` A. I don't recall any conversations with Cavium,
`but there could have been some employees that were
`formerly with Cavium that I don't know about.
` Q. And how many invoices in total have you
`submitted to Cavium?
` A. One.
` Q. And do you recall how much that invoice was
`for?
` A. No, I don't.
` Q. And has that invoice been paid?
` A. I believe it's been paid, but I'm not sure.
` Q. And approximately how many hours was that
`invoice covering?
` A. It was just a few hours, but I don't remember
`exactly how many.
` Q. And what work was that invoice covering, what
`type of work?
` A. I did a careful read of my entire declaration
`for that when I was retained by Cavium, and in the
`process I found a few typos and things to fix. So it
`involved fixing those typos and then printing out the
`reports and signing them.
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` ROBERT HORST
` Q. So are you an expert for both Intel and Cavium
`in these proceedings?
` A. At the present only Intel is directing my work.
`But if for some reason Intel drops out, at that point
`Cavium or one of the other defendants would direct my
`work.
` Q. And how were you contacted with attorneys for
`Cavium -- or how were you connected with attorneys for
`Cavium? Did Weil Gotshal attorneys connect you with the
`Cavium attorneys?
` MR. CONSTANT: Objection. You can answer
`to the extent that it doesn't disclose any conversations
`that you may have had with Weil attorneys or Cavium
`attorneys.
` A. I don't recall who made the first contact, but
`I understood from Weil that Cavium was going to join and
`the Cavium attorneys would contact me at some point.
` Q. (By Mr. Mack) In connection with your initial
`preparation of your declarations, the declarations that
`were submitted in April, had you ever spoken to Cavium
`attorneys prior to that point?
` A. No, I hadn't.
` Q. Have you ever spoken to any Cavium employees,
`current or past, in connection with this case?
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` ROBERT HORST
` Q. And the Cavium attorneys, did they gave you any
`guidance or direction in connection with your
`declaration that you submitted in the Cavium petitions?
` A. There is -- nothing having to do with the
`substance. It was only directed to the formatting.
`There may have been some claims that were not asserted
`against Cavium, and those were removed from my report.
` Q. But the substance of your two declarations, the
`one that you submitted in the Intel petitions and the
`ones that you submitted in the Cavium petitions, the
`substance are identical?
` A. Yes.
` Q. How about Dell? Has Dell ever compensated any
`portion of your work in this case?
` A. It was a similar arrangement with Dell. Later
`they contacted me, and I only worked with them to sign a
`version of my report with Dell cited on the cover page.
` Q. And had you spoken to any attorneys or
`employees representing Dell prior to submission of your
`initial declarations in April?
` A. Not with regard to this case.
` Q. How about Wistron? Have you ever spoken to any
`attorneys or employees of Wistron?
` A. It was a similar arrangement with Wistron in
`
`TSG Reporting 877-702-9580
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`3 (Pages 6 to 9)
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` ROBERT HORST
`filing the IPRs for Wistron.
` Q. Have you spoken to any attorneys or employees
`prior to April when you filed your initial declarations?
` A. No.
` Q. And finally CenturyLink? Same answer with
`respect to CenturyLink?
` A. I am not retained by CenturyLink.
` Q. But sitting here today, you agree that you are
`retained by Wistron, Dell, Cavium and Intel, correct?
` A. Yes.
` Q. Do you have formal retention agreements with
`each of those four parties?
` A. Yes.
` Q. And what is your hourly rate for your work on
`this case?
` A. 550.
` Q. And is your hourly rate the same for each of
`Intel, Cavium, Dell and Wistron?
` A. Yes.
` Q. Is $550 an hour your typical consulting rate?
` A. Yes. That's the rate for my expert witness
`work.
` Q. And are you being paid for your time testifying
`here today?
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` ROBERT HORST
` Q. And when were you first contacted about working
`on this case?
` A. I don't recall. It was over a year ago, but I
`don't remember when.
` Q. And do you recall who first contacted you about
`working on this case?
` A. I am not sure. I had previously worked --
`known one of the attorneys at Weil, and he may have
`contacted me.
` Q. Which attorney at Weil did you have a prior
`relationship?
` A. Garland Stephens.
` Q. And have you worked for Mr. Stephens before
`this case?
` A. In?
` Q. In an expert litigation capacity. Has he
`retained you previously?
` A. I had spoken with him in another case, but I
`don't -- I can't recall if he was actually on that case
`or not.
` Q. Okay. And how many times prior to this case
`have you been retained by the law firm Weil Gotshal?
` A. I am not sure. It may have been one other
`time.
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` A. Yes.
` Q. And that's also at the same $550 an hour rate?
` A. That's right.
` Q. Other than your compensation that we just
`discussed, do you have any other financial interest in
`the outcome of these proceedings?
` A. No.
` Q. Do you own any stock in Intel Corporation?
` A. No, not directly unless it's part of a mutual
`fund.
` Q. How about any stock in Dell, Cavium or
`CenturyLink?
` A. No.
` Q. And how many declarations in total have you
`submitted on behalf of Intel in this case, do you
`recall?
` A. I believe it was eight declarations plus one
`supplemental declaration.
` Q. And did you also submit those same eight
`declarations on behalf of Cavium?
` A. Cavium -- I submitted a number of declarations,
`but I'm not sure that all of them were submitted. I
`believe all eight were for Cavium but not all eight for
`the other defendants.
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` ROBERT HORST
` Q. And were you contacted directly by Weil
`attorneys or through an expert search firm?
` A. Directly.
` Q. Are you associated with any expert search or
`placement firms today?
` A. I have done -- I have had a few cases through
`search firms, but most of my cases are now directly with
`the law firms.
` Q. And which search firms have you used in the
`past?
` A. There used to be a group called the Silicon
`Valley Expert Witness Group, and then they were acquired
`or sold to another company, which I don't recall the
`name. And there have been a few others that I may have
`been contacted, but I don't recall their names.
` Q. Approximately how much -- how many hours have
`you billed on this case from your initial engagement to
`today?
` A. I haven't counted up the hours. It's been
`several hundred hours, but I don't know how many.
` Q. And have you been compensated for each of those
`several hundred hours?
` A. Yes.
` Q. And how much compensation have you collected to
`
`TSG Reporting 877-702-9580
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`4 (Pages 10 to 13)
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` ROBERT HORST
`date working on the IPRs in this case?
` A. I haven't gone back to check my records to
`know.
` Q. Okay. Do you know approximately how much?
` A. I would just have to guess.
` Q. What would be your best guess?
` A. It's probably something over a hundred
`thousand, but I don't know.
` Q. Are you working on any other matters
`simultaneously with this matter?
` A. Yes.
` Q. And how many other matters are you working on
`simultaneously with this matter?
` A. There's two other expert cases, and I'm also
`working with a company on some engineering work.
` Q. And are any of those cases also with the Weil
`law firm?
` A. No.
` Q. What percentage of your time -- currently what
`percentage of your time is occupied working on the IPRs
`for this matter?
` A. The time varies quite a lot depending on what
`deadlines. So it's pretty hard to gauge that.
` Q. Fair enough. Supplemented by your preparation
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` ROBERT HORST
` Q. (By Mr. Mack) And when did you do the initial
`search for prior art?
` A. It was shortly after I was retained by Weil.
` Q. Did Dell, Wistron or Cavium send you any of the
`prior art that you cited in your expert declarations?
` A. No.
` Q. Did you personally locate all of the prior art
`cited in your declarations?
` A. No. Weil supplied a lot of it, and I found
`some other documents.
` Q. And the prior art that Weil had supplied to
`you, had you seen any of that prior art prior to the
`time they had supplied it to you?
` A. I may have. I don't recall exactly which ones
`they sent and which ones I found.
` Q. Did you meet with anyone to prepare for today's
`deposition?
` A. Yes. I met with Weil attorneys.
` Q. Okay. Which Weil attorneys did you meet with?
` A. With Mr. Constant and Mr. Stephens.
` Q. And when did you meet with Mr. Constant and
`Mr. Stephens?
` A. Yesterday and part of the day before.
` Q. And how long were each of those meetings?
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` ROBERT HORST
`for today's deposition, what did you do to prepare for
`your deposition today?
` A. I primarily read my declarations and the prior
`art cited in those declarations and read some of the
`documents connected with the case like the PTAB
`decisions instituting the IPRs.
` Q. And did anything you read in the PTAB decisions
`instituting the IPRs change any of your views in this
`case?
` A. No.
` Q. You mentioned you also reviewed the prior art
`cited in your declarations, correct?
` A. Yes.
` Q. Did you review all of the prior art?
` A. I reviewed the primary art that was cited. I'm
`not sure that I read every piece.
` Q. Okay. And how did you locate the prior art
`that you cited in your declarations?
` MR. CONSTANT: Objection, privileged. You
`can answer to the extent it doesn't disclose
`communications that we may have had.
` A. I had copies of most of those documents on my
`computer from when I did the initial search for prior
`art.
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` ROBERT HORST
` A. Yesterday's was a full day and the day before
`was about a half a day.
` Q. And I think you mentioned you reviewed your
`declarations in preparation for today's deposition,
`right?
` A. Yes.
` Q. Did you also review the patents-in-suit?
` A. Yes. I read through the provisional that all
`the patents are based on.
` Q. Was there anything else that you reviewed other
`than the institution decisions, the patents-in-suit,
`your declarations and the prior art?
` A. There were a few other documents connected with
`the case, but I can't remember exactly which ones.
` Q. To prepare for today's deposition, did you
`speak with any nonlawyers?
` A. Not in connection with the case.
` Q. How about not in connection with today's
`deposition but just generally in connection with this
`engagement, did you speak with any engineers at Intel,
`for instance?
` A. No.
` Q. How about engineers at Cavium?
` A. No.
`
`TSG Reporting 877-702-9580
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`5 (Pages 14 to 17)
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` ROBERT HORST
` Q. Did you speak with any engineers from Dell or
`CenturyLink?
` A. No.
` Q. How about Wistron?
` A. No.
` Q. I have Exhibit 1004, which is a copy of your
`CV. You recognize this document, right?
` A. Yes.
` Q. And is this -- this is your CV, correct?
` A. Yes. It appears to be.
` Q. Is this a current version of your CV?
` A. Yes.
` Q. The bottom left-hand corner says that it was
`printed in January of last year. Is there a more recent
`version of your CV?
` A. No. I don't have a more recent version.
` Q. Does this version of your CV, Exhibit 1004, is
`this complete?
` A. Yes. As far as I know, it's complete.
` Q. Okay. But you don't see anything missing in
`this CV, correct?
` A. No.
` Q. On page 1 of your CV it says under Professional
`Summary that you currently work for a company called
`
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` ROBERT HORST
` A. Again, throughout the year that varies quite a
`bit. So it depends on what's happening in the cases.
` Q. How about currently like as of today? Do you
`have any non-litigation consulting tasks?
` A. Yes. I'm helping out with a PC board design.
`I've been talking with them this week as well.
` Q. And what specifically are you -- what work are
`you performing in connection with the PC board design?
` A. It's a company that's designing a board, and
`I'm helping them with the schematics and the layout of
`that PC board.
` Q. Other than the PC board consulting, are there
`any other active technical consulting arrangements other
`than your litigation consulting that you're working on
`today?
` A. I also occasionally consult with AlterG, my
`former company. So once in a while they will call me
`with a technical question or something to work on.
` Q. But as of today, would it be fair to say that
`more than 90 percent of your work at HT Consulting
`relates to expert litigation services?
` A. I don't know what the percentage is, but it's
`over half for sure of my work.
` Q. How about on a compensation basis? Is over
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` ROBERT HORST
`HT Consulting. Is that right?
` A. Yes.
` Q. And HT Consulting stands for Horst Technology
`Consulting, right?
` A. That's right.
` Q. Are you the sole proprietor of that company?
` A. Yes.
` Q. And what -- legally do you know what type of
`company that is?
` A. It's a sole proprietorship.
` Q. And are there any other -- how many employees
`are associated with HT Consulting?
` A. There are no other employees.
` Q. So you're the sole employee of HT Consulting,
`right?
` A. Yes.
` Q. Do you employ any research assistants or
`helpers in connection with your work?
` A. No.
` Q. Part of your work at HT Consulting includes
`expert litigation consulting like this case, correct?
` A. Yes.
` Q. What percentage of your work at HT Consulting
`today relates to expert litigation consulting?
`
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` ROBERT HORST
`90 percent of your compensation today derived from
`expert litigation consulting services?
` A. Yes. It would be over 90 percent.
` Q. Do you know how much over 90 percent?
` A. No.
` Q. You also advertise your consulting services on
`a website, correct?
` A. Yes.
` Q. And that's www.horsttech.com, right?
` A. Yes.
` Q. Did you create that website?
` A. Yes.
` Q. And when did you create that website?
` A. It was probably around 2001 or '2, something
`like that.
` Q. And do you update that website regularly?
` A. Not very often.
` Q. Do you personally maintain the website, or do
`you hire someone to maintain that website?
` A. I maintain it myself.
` Q. And why did you create the horsttech.com
`website?
` A. So that companies that needed my services could
`find me.
`
`TSG Reporting 877-702-9580
`
`6 (Pages 18 to 21)
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`Alacritech, Ex. 2028 Page 6
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` Q. And has the website increased the level or
`quantity of the work that you've been receiving?
` A. I don't really know since I have no way of
`tracking how I got different work.
` Q. I want to move on to your education and
`technical experience briefly. If you'd turn to page 6
`of your CV, Exhibit 1004.
` A. (Witness complies.)
` Q. At the top do you see where it says Education?
` A. Yes.
` Q. Okay. And you received your Ph.D. in computer
`science in 1991. Is that correct?
` A. Yes.
` Q. Your thesis title isn't listed here; but your
`thesis was entitled Task-Flow: A Novel Approach to
`Fine-Grain Wafer-Scale Parallel Computing. Does that
`sound right?
` A. It was related to that. I don't know if that
`was the exact title.
` Q. What was the general subject matter of your
`Ph.D. thesis?
` A. It was a parallel computer architecture
`designed to efficiently solve problems like neural
`network simulations.
`
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` ROBERT HORST
` A. Yes.
` Q. And that thesis also does not mention or relate
`to any protocol off-loading, does it?
` MR. CONSTANT: Objection, vague.
` A. Again, that thesis isn't directly related to
`off-loading; but some of the elements like the
`processors are similar to the types of processors that
`are used in off-load engines.
` Q. (By Mr. Mack) Does your master's thesis --
`your master's thesis also doesn't reference the TCP/IP
`protocol, does it?
` A. No. I don't believe it does.
` Q. And how about your Ph.D. thesis? That also
`doesn't reference TCP/IP protocol, does it?
` A. I don't believe so.
` Q. How does your master's thesis relate, if at
`all, to your Ph.D. thesis?
` A. They aren't directly related, although I was
`working in the same group in Illinois at that time in
`the coordinated science lab.
` Q. Your Ph.D. was in computer science while your
`master's and bachelor's degrees were in electrical
`engineering, correct?
` A. Yes.
`
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` Q. Your Ph.D. thesis did not relate to protocol
`off-loading, right?
` A. It doesn't directly relate to protocol
`off-loading, although I did have part of the design
`which has elements that are in off-load engines.
` Q. But your thesis doesn't reference in the
`protocol off-loading, does it?
` A. No.
` Q. And your thesis doesn't reference or relate to
`accelerating TCP processing, does it?
` MR. CONSTANT: Objection, vague.
` A. No, it doesn't.
` Q. (By Mr. Mack) It says here that you received
`your MSEE degree also from the University of Illinois.
`Is that correct?
` A. Yes.
` Q. And that was in 1978?
` A. Yes.
` Q. You worked on a thesis during your master's
`program, correct?
` A. Yes.
` Q. And that thesis was entitled Amp One, The
`Design and Implementation of a Synchronous Multiple
`Micro Processor System. Do you recall that?
`
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` ROBERT HORST
` Q. Is it fair to say that your -- was your Ph.D.
`work less associated with hardware and more associated
`with software?
` MR. CONSTANT: Objection, vague.
` A. I wouldn't say that. The coursework was more
`software related, but the actual thesis was still
`directly related to hardware.
` Q. (By Mr. Mack) And why did you obtain your
`Ph.D. in computer science and not electrical
`engineering?
` A. Again, it was a chance to learn more about what
`had been happening in software. So I decided that I
`wanted to take more courses in software when I went back
`for my Ph.D.
` Q. You've never had any academic coursework
`specifically relating to protocol off-loading, have you?
` MR. CONSTANT: Objection, vague.
` A. I don't recall any of the coursework related to
`that, no.
` Q. (By Mr. Mack) Have you had any academic
`coursework relating to protocol acceleration?
` MR. CONSTANT: Objection, vague.
` A. Not that I recall.
` MR. MACK: And just for the record,
`
`TSG Reporting 877-702-9580
`
`7 (Pages 22 to 25)
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`Alacritech, Ex. 2028 Page 7
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`Justin, I know since we're going to be defending our
`expert in a few weeks probably, I think the PTO trial
`practice guidelines specifically says vague objections
`are not proper. It says form, and it gives vague as an
`example of a non-proper one.
` You can keep using vague and then we can
`do the same with our experts or we can just switch to
`form. It's up to you. I think it's in the trial
`practice guidelines. Specifically it mentions vague as
`an improper objection.
` Q. (By Mr. Mack) Let's look at page 1 of your
`resume, your professional summary. Other than
`HT Consulting it also lists two companies, Tibion
`Corporation and AlterG. Do you see those?
` A. Yes.
` Q. Is it Tibion or --
` A. Tibion.
` Q. Tibion. And you founded Tibion in 2001,
`correct?
` A. Yes.
` Q. So that was 17 years ago?
` A. Yes.
` Q. How would you characterize your work at Tibion?
` A. At Tibion most of my work was in the
`
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` ROBERT HORST
` A. That's right.
` Q. And is AlterG still in existence today?
` A. Yes.
` Q. And Tibion, I take it, is no longer in
`existence, right?
` A. Right. Tibion is not, although the bionic leg
`we developed at Tibion is still being sold by AlterG.
` Q. You remained at AlterG for approximately two
`years from 2013 to 2015, correct?
` A. Yes.
` Q. And you were the chief technology officer at
`AlterG during that time?
` A. CTO of robotics was my title.
` Q. Your work at AlterG also didn't relate to
`protocol off-loading or TCP acceleration, did it?
` A. Not to TCP acceleration, although we used TCP
`for communications.
` Q. In your work at AlterG and Tibion, that
`accounts for roughly the last 15 years of your
`professional experience if you don't include your work
`at HT Consulting, right?
` A. Yes. I should add to that that during part of
`this period during 2002 I was working at Network
`Appliance also.
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` ROBERT HORST
`development of the bionic leg, which was developing both
`the mechanical and the electronics and the motor control
`for this assistive device, which was kind of similar to
`a powered knee brace used for stroke recovery.
` Q. And the bionic leg, it wasn't TCP/IP capable,
`was it?
` A. There was a version of the software that we
`developed to be able to remotely query the leg and
`understand what was going on and read some of the
`characteristics from it. So we did a Wi-Fi version
`which used TCP/IP.
` Q. And were you involved in developing the Wi-Fi
`version that included TCP/IP support?
` A. Yes.
` Q. And your work at Tibion, it didn't relate to
`any protocol off-loading, correct?
` A. No, it did not.
` Q. And your work at Tibion didn't relate to TCP
`acceleration, did it?
` A. No.
` Q. And you remained at Tibion for about 12 years.
`Is that right?
` A. Yes.
` Q. And then Tibion was acquired by AlterG?
`
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` ROBERT HORST
` Q. So you were simultaneously at Tibion and
`Network Appliance?
` A. Yes.
` Q. What was your role at Network Appliance?
` A. At Network Appliance my title was technical
`director, and I was involved in the architecture of new
`filing systems that they were developing.
` Q. And your work at Network Appliance, it was just
`one year, from 2002 to 2003?
` A. Yes.
` Q. Okay. Why did you leave Network Appliance?
` A. I left Network Appliance when we got funding
`for Tibion. Before that it was just self-funded.
` Q. Why did you leave AlterG in 2015?
` A. At that point AlterG discontinued doing their
`own engineering work. So that's the point that I left.
` Q. Turn to page 6 where it says Publications.
` A. (Witness complies.)
` Q. Your publications continue on to pages 7 and 8,
`correct?
` A. Yes.
` Q. Your first category of publications is in the
`bionics category or subcategory, correct?
` A. Yes.
`
`TSG Reporting 877-702-9580
`
`8 (Pages 26 to 29)
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` Q. And those publications, none of those mention
`protocol off-loading, do they?
` A. No, they don't.
` Q. Do any of those publications in the bionics
`subsection relate to protocol off-loading?
` A. No, they don't.
` Q. Looking through your Fault Tolerance, CPU
`Architecture, Storage and Networks, the remainder of
`your publications, do any of those specifically
`reference protocol off-loading?
` A. Some of those may have some references to
`protocol off-loading because they relate to systems that
`we designed that did checksum off-load and other types
`of protocol off-loading.
` Q. And sitting here today, do you recall which of
`those papers would relate to systems that you used to
`design off-loading?
` A. The last one in that section that relates to
`ServerNet would relate to off-loading.
` Q. And that's the paper entitled ServerNet and ATM
`Interconnects: Comparison for Compressed Video
`Transmission?
` A. No. I was looking at the last one in the Full
`Tolerance section, which was the Flexible ServerNet
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` ROBERT HORST
`inventor or co-inventor on a number of patents, correct?
` A. Yes.
` Q. And those are listed on page 3, 4 and 5 of your
`CV, right?
` A. Yes.
` Q. Do any of your patents relate specifically to
`protocol off-loading?
` A. Some of these patents include concepts of
`off-loading, in particular the ones related to
`ServerNet.
` Q. And looking at this list of patents, can you
`tell me which patents relate to off-loading?
` A. I would have to review them all individually to
`be able to tell you for sure. I can tell you a couple
`of them.
` Q. Do any of them relate specifically to TCP/IP
`off-loading?
`