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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS AMERICA, INC.,
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`Petitioner
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`V.
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`UNILOC LUXEMBOURG S.A.,
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`Patent Owner
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`_______________
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`Case No. IPR2017-01797
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`Patent No. 8,724,622
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`***************************************
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`ORAL DEPOSITION OF WILLIAM C. EASTTOM
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`AUGUST 3, 2018
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`***************************************
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`Job No. 144980
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`SAMSUNG EXHIBIT 1040
`Samsung Electronics America, Inc. v. Uniloc Luxembourg, S.A.
`IPR2017-01802
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`Page 1 of 195
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS AMERICA, INC.,
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`Petitioner
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`V.
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`UNILOC LUXEMBOURG S.A.,
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`Patent Owner
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`_______________
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`Case No. IPR2017-01797
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`Patent No. 8,724,622
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`***************************************
`
`ORAL DEPOSITION OF WILLIAM C. EASTTOM
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`AUGUST 3, 2018
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`***************************************
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`Job No. 144980
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`SAMSUNG EXHIBIT 1040
`Samsung Electronics America, Inc. v. Uniloc Luxembourg, S.A.
`IPR2017-01802
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`Page 1 of 195
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`Page 2
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` SAMSUNG ELECTRONICS AMERICA, INC.,
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` Petitioner
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` V.
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` UNILOC LUXEMBOURG S.A.,
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` Patent Owner
`
` _______________
`
` Case No. IPR2017-01798
`
` Patent No. 8,724,622
`
`***************************************
`
` ORAL DEPOSITION OF WILLIAM C. EASTTOM
`
` AUGUST 3, 2018
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`***************************************
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`ANSWERS AND DEPOSITION OF WILLIAM C. EASTTOM,
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`produced as a witness at the instance of the Petitioner,
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`taken in the above-styled and -numbered cause on the 3rd
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`day of August, 2018, at 9:52 a.m., before Susan M.
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`Foreman, a Certified Shorthand Reporter in and for the
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`State of Texas, at the Renaissance Dallas at Plano
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`Legacy West Hotel, located at 6007 Legacy Drive, Plano,
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`Texas 75024, in the City of Plano, County of Collin,
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`and State of Texas, in accordance with the agreement
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`hereinafter set forth or in accordance with the Federal
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`Rules of Civil Procedure.
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` A P P E A R A N C E S
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`Page 4
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`FOR THE PETITIONER SAMSUNG ELECTRONICS AMERICA, INC.
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` MR. PHILLIP CITROEN, ESQ.
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` MR. MICHAEL WOLFE, ESQ.
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` MR. JOSEPH PALYS, ESQ. (VIA TELEPHONE)
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` PAUL HASTINGS
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` 875 15th Street, N.W.
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` Washington, DC 20005
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`FOR THE PATENT OWNER UNILOC LUXEMBOURG S.A.
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` MR. RYAN LOVELESS, ESQ.
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` ETHERIDGE LAW GROUP
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` 2600 East Southlake Boulevard
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` Southlake, Texas 76092
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`
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`I N D E X
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`Page 5
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`PAGE
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`Appearances.................................... 4
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`WILLIAM C. EASTTOM
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`Examination by Mr. Citroen............... 6
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`Reporter's Certificate......................... 193
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`WILLIAM C. EASTTOM, II
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`P R O C E E D I N G S
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`WILLIAM C. EASTTOM, II,
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`Page 6
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`having been first duly sworn, testified as follows:
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`EXAMINATION
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`BY MR. CITROEN:
`
`Q.
`
`Good morning.
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`A.
`
`Good morning.
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`Q.
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`Nice to meet you. So just for the record
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`really quickly, my name is Phillip Citroen from Paul
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`Hastings on Samsung, and here with me today is Michael
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`Wolfe, and on the line is Joe Palys, also for Petitioner
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`Samsung and also from Paul Hastings.
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`MR. LOVELESS: And this is Ryan Loveless on
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`behalf of Uniloc and the witness.
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`Q.
`
`Great. How are you this morning?
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`A.
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`Quite well. Thank you.
`
`Q.
`
`Okay. Can you please state your name for the
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`record?
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`A.
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`William Charles Easttom, II, usually simply
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`called Chuck Easttom.
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`Q.
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`Thank you, Mr. Easttom.
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`Can you also state your address for the
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`record?
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`A.
`
`5605 Woodspring Drive, Plano, Texas.
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` Q. Thank you.
`
` And I believe you've been deposed before,
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`Page 7
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`correct?
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` A. That's correct.
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` Q. Okay. About how many times?
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` A. Well, counting trials, hearings, and
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`depositions, today will be my 39th time testifying.
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` Q. Okay. So I'm guessing you probably know kind
`
`of the ground rules for going through depositions, but
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`if you don't mind, I'll just go through them quickly.
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` A. Please.
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` Q. So just so we have a clear record, let's try
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`not to talk over each other. I'll try not to -- I'll
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`try to let you finish your answer before I ask another
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`question if you can let me finish asking my question
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`before you give an answer. That way we can have a clear
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`record. Is that okay?
`
` A. Certainly.
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` Q. Please respond with a verbal answer instead of
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`shaking your head or nodding or making just a noise. Is
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`that okay?
`
` A. Understood.
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` Q. If I'm speaking too quickly or you don't
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`understand a question, just ask me to slow down or
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`repeat the question, and I'll do so. I'll go ahead and
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`apologize in advance. I'm a little hoarse, and I'm
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`losing my voice a little bit, so if I'm speaking too
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`Page 8
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`softly, just let me know.
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` A. I will.
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` Q. Okay. We'll try and take a break about every
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`hour or so, but if you need a break sooner than that,
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`let me know. I just ask that if there's a pending
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`question, that you finish answering the question before
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`we take a break.
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` A. Certainly.
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` Q. Is there any reason you cannot testify
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`completely, truthfully, and accurately today?
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` A. No, not at all.
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` Q. Okay. And you understand you're under oath
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`today?
`
` A. Yes, I do.
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` Q. Okay. Do you understand why you're here today,
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`Mr. Easttom?
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` A. Yes.
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` Q. Okay. And why is that?
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` A. There is an IPR pending on -- I believe we're
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`doing two patents today, two IPRs, and we're for you to
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`inquire as to my opinions and the bases thereof.
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` WILLIAM C. EASTTOM, II
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` Q. Okay. I want to hand you a few documents.
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`Here's the first document, and one more. So I just
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`handed you three documents, correct?
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` A. Yes.
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` Q. Okay. One of those documents, is it a patent?
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` A. Yes, it appears to be the '622 patent, the
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`patent at issue today.
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` Q. Okay. And then can you tell me what the other
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`two documents are that I handed you?
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` A. The two appear to be my declarations regarding
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`the two IPRs regarding this patent at issue today.
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` Q. Okay. And that's the '622 patent?
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` A. That's correct.
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` MR. WOLFE: What number is that? '622?
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` MR. CITROEN: Can we go off the record just
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`for one second?
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` (Brief recess.)
`
` Q. So you stated that the -- you have your two
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`declarations involving the '622 patent, correct, in
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`front of you?
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` A. That's correct.
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` Q. Okay. Is it okay if we refer to the
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`declaration that is labeled IPR 2017-01797 on the cover
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`as the 1797 declaration?
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` WILLIAM C. EASTTOM, II
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` A. Yes.
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` Q. Okay. And then the second declaration that you
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`have with respect to the '622 patent, it's labeled on
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`the cover IPR 2017-01798. Is it okay if we refer to
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`that as the 1798 declaration?
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` A. Certainly.
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` Q. And just for record, these are Exhibit
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`Number 2001 in each respective proceeding.
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` If we can look at your 1797 declaration
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`quickly. Did you prepare this declaration?
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` A. No.
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` Q. Did you write it yourself?
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` A. Yes.
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` Q. Every word?
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` A. I normally turn over declarations and reports
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`to attorneys for a little basic editing. I'm actually
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`kind of renowned for typos and such. And there's
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`normally some suggested cleanup and things like that.
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`But I approve or disapprove any suggested changes, and
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`it is totally my opinions and my thoughts and words in
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`the final declaration.
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` Q. Okay. Can you look at paragraph 2 in the 1797
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`declaration?
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` A. I have it in front of me.
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` Q. Do you see there's a blank about -- I think
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`it's -- it's in the first sentence, towards the bottom.
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` A. I actually noted that in reviewing this for
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`this proceeding. I had intended to go back and put the
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`specific dates for that on there and simply neglected to
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`do so. But they are in my CV that's attached.
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` Q. The beginning of the sentence, it says from
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`2000 to 2003, though. So are you referring to different
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`dates than the 2000 to 2003?
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` A. Well, it would have either been the dates or
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`the location of the college, which would be Garland,
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`Texas.
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` Q. Okay. You just couldn't recall where the
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`college was at the time?
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` A. I don't think I recalled the specific time. I
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`had to go back and review, and then I just didn't get
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`around to putting it back into the blank.
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` Q. Okay. Did anyone help you prepare the
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`declarations, both the 1797 and the 1798 declarations?
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` A. Aside from the basic review that I already
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`discussed where only suggestions are made, but it's
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`ultimately my decision, no.
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` Q. Okay. Are there any paragraphs in here you did
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`not write or have input in?
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` WILLIAM C. EASTTOM, II
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` A. No.
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` Q. Okay. And if you can go to the back of the
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`1797 declaration before your CV. You can let me know
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`when you're there, please.
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` A. Are you referring to paragraphs 70 through 72
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`in the conclusions?
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` Q. Yes, sir.
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` A. I am there.
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` Q. Okay. Is that your signature at the bottom?
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` A. Yes.
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` Q. Okay. And it's dated November 7th, 2017; is
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`that right?
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` A. That's the date here, but I don't have an exact
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`recollection of when I signed it, but that sounds about
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`right.
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` Q. Okay. Could you have signed it after that
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`date?
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` A. No, I don't think so.
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` Q. And I just want to ask you the same question
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`quickly for the 1798 -- 1798, excuse me, declaration, if
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`you could go to the signature page as well and let me
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`know when you're there.
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` A. I'm there.
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` Q. Okay. Is that your signature at the bottom of
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`the page? I believe it's page 42 of your 1798
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`declaration.
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` A. Yes, it is.
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` Q. And, again, you have a date there of
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`November 8th, 2017. Is that the date that you signed
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`the declaration?
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` A. To the best of my recollection. I don't have
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`an identic memory, and I couldn't guarantee it was on
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`that date, but it would have been if I put that date on
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`there.
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` Q. Okay. Do you recall if you signed it after
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`that date?
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` A. I'm pretty certain I didn't.
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` Q. Okay. So what materials did you consider when
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`preparing your declarations?
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` And if it's okay with you, when I say
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`"declarations," plural, I'm referring to both the 1797
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`and the 1798.
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` A. Certainly.
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` I believe I actually enumerated those in
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`the declaration. For example, on the 1797 in paragraph
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`4, I specifically mention that I of course reviewed the
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`262 patent, its prosecution file wrapper, in other
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`words, all the files and the prosecution history, the
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` WILLIAM C. EASTTOM, II
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`state of the art at the time, all the references that
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`Samsung had asserted. There were several of them.
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` Now, I particularly point out Zydney
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`Griffin. And I'm probably going to mispronounce this
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`name, Aravamudan and Vuori. And, of course, there were
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`other declarations that had previously been done on this
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`same patent that I also took a look at.
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` Q. These other declarations that you're referring
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`to, are those your own declarations?
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` A. I believe they would have been, yes.
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` Q. Did you review any declarations of other
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`experts other than Dr. Haas in preparing these
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`declarations?
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` A. None that I recall.
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` Q. Do you know Dr. Dieuliis?
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` A. The name doesn't strike me as familiar.
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` Q. Okay. I'm going to spell it just in case I'm
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`mispronouncing it. It's D-I-E-U-L-I-I-S.
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` A. The name doesn't stand out to me. Now, to be
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`totally frank, I go to a tremendous number of
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`conferences, and I probably meet 2,000 people a year,
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`and if I met him, it was a passing meeting at a
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`conference, but nothing that would cause me to recall
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`the name or the person.
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` WILLIAM C. EASTTOM, II
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` Q. Did you consider any materials that are not
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`listed here in paragraph -- I think you said it was 4;
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`is that right?
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` A. It is paragraph 4; and, no, I did not.
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` Q. Do you recall when you started the process of
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`preparing these declarations?
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` A. No, I don't.
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` Q. Okay. Do you recall when you were retained for
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`these proceedings?
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` A. Well, that's difficult to discern because in
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`late 2016 I was retained for a number of items related
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`to Uniloc, and they sort of, from my perspective, simply
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`flowed from one to the other. So the demarcation point
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`for this specific matter, I don't recall.
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` Q. Okay. Do you recall who contacted you with
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`respect to these proceedings regarding your retention?
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` A. I don't recall the specific name. I believe it
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`was one of the attorneys that are now with the firm of
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`Prince Lobel, who handled some of the other Uniloc
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`matters. And there was -- there were two or three of
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`those attorneys that I've worked with in the past when
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`they were at other firms, and it was one of those two or
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`three that reached out to me.
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` Q. So it wasn't any of the attorneys at the
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`Etheridge Law Firm?
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` A. I don't believe so, although I've also worked
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`with Etheridge Law Firm before.
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` Q. Okay. Did you prepare for today's deposition?
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` A. Yes.
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` Q. And how did you prepare for today's deposition?
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` A. Primary was simply rereading the declarations,
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`rereading the references, rereading the petition for the
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`IPR; and there was a brief conversation with counsel via
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`phone.
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` Q. When did you have the conversation via phone?
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` A. I think that was Monday.
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` Q. And who did you speak to on Monday?
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` A. This is terribly embarrassing because he's
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`sitting next to me, and I do not recall his name.
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` Q. That's okay. Is it Mr. Loveless?
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` A. Yes. Thank you.
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` THE WITNESS: Very sorry about that. I'm
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`terrible with names.
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` MR. CITROEN: I am, too. I'm surprised
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`that I remembered.
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` Q. Okay. And about how long did you talk to
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`Mr. Loveless on Monday?
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` A. I would estimate between an hour and an hour
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`and a half.
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` Q. Okay. And the rest of the time that you spent
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`preparing for today's deposition was on your own?
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` A. That would be correct.
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` Q. You didn't speak to anyone else regarding
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`today's deposition?
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` A. Other than to tell my wife my schedule, no.
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` Q. Okay. How much time do you think you spent in
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`total preparing for today's deposition?
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` A. Well, not inclusive of the time spent
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`originally preparing the declarations, I would say
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`somewhere in the eight- to ten-hour range.
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` Q. And what -- I apologize. I know you listed
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`what you reviewed, but I can't see what you stated. So
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`can you tell me again what you reviewed to prepare for
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`today's deposition?
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` A. Certainly. Obviously, the declarations
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`themselves, the '622 patent itself, the actual IPR
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`petitions that were filed, and the various exhibits
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`attached to those petitions.
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` Q. Did you review the board's institution
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`decisions in these two proceedings?
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` A. I believe I saw it, but I don't believe I
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`focused particularly on that matter.
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` Q. Okay. So do you know for sure if you saw that
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`or not?
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` A. I don't know for certainty, no.
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` Q. What about the patent owner's preliminary
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`responses in these two proceedings, did you review those
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`in preparing for today's deposition?
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` A. I don't have a specific recollection of
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`reviewing that. It might have been in the material, but
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`if so, it didn't stand out particularly to me.
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` Q. And did you look at the patent owner responses
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`before or in preparation for today's deposition?
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` A. Again, I don't have a specific recollection of
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`doing that. It may have been amongst the material.
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` Just to be clear, I form independent
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`opinions based on the technology. So what one party or
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`the other to the case, their opinions don't influence
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`mine.
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` Q. So other than reviewing the few materials that
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`you identified and having the call with Mr. Loveless on
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`Monday, is there anything else that you did to prepare
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`for today's deposition?
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` A. No. But just one minor correction. It wasn't
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`a few materials. As you're probably aware, there were a
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`lot of exhibits to these IPRs. There was --
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` Q. Okay.
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` A. -- quite a lot of materials. But, no, nothing
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`other than that.
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` Q. Okay. So did you review every exhibit for the
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`proceeding?
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` A. At least gave it a quick scan.
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` Q. Okay. Thanks for the correction.
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` So do you believe you had sufficient amount
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`of time to prepare for today's deposition?
`
` A. Yes.
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` Q. So in your own words, what would you describe
`
`as your technical expertise?
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` A. Well, as you may have noted from the CV,
`
`there's a wide range of computer science-related
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`expertise. Particularly related to this case, I have
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`specific expertise in a wide range of networking
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`technologies, telecommunications, mobile devices,
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`including mobile programming and even mobile forensics.
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` Now, there are other areas of computer
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`science that aren't necessarily related to this case.
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`I'm happy to enumerate them if you wish.
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` Q. That's okay for now.
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` And, in your opinion, what is the field of
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`the invention with respect to the '622 patent?
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` WILLIAM C. EASTTOM, II
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` MR. LOVELESS: Objection, form.
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` A. The '622 patent involves voice over IP to begin
`
`with it, and then it involves messaging with voice over
`
`IP.
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` Q. Do you have any experience -- strike that.
`
` Prior to December 2003, did you have any
`
`experience with instant messaging?
`
` A. Yes.
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` Q. And what was that experience?
`
` A. It was several. To begin with, in the late
`
`'90s, I worked for a company, Digital Speech Systems,
`
`where I created software for voicemail servers. One of
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`the applications at that company I personally did was to
`
`integrate different types of messaging into Outlook, so
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`you would get both instant messaging and voicemail into
`
`your Outlook inbox.
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` Since that time, as I mentioned before,
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`extensive work with mobile phones, including mobile
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`phone forensics, which involves not only understanding
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`the architecture of the phones and the software, but
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`being able to extract and analyze data from those phones
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`often including instant messaging.
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` Q. You said software for voicemail servers?
`
` A. Yes.
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` Q. Can you explain what that means?
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` A. Well, a voicemail server is hardware. It's a
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`box. At the time, I believe we used voicemail cards
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`from Dialogic, a company that made voice technology.
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`And I had to write the software, or was part of a team
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`that wrote the software that made all of that function.
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`It would store voicemail, allow you to retrieve them.
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`We would do call forwarding, various things like that.
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` Q. Okay. And just to be clear, so I was asking
`
`you about instant messaging. So is this software that
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`you designed for the -- or worked on for the voicemail
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`servers, was that software instant messaging software
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`for voicemail servers?
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` A. The voicemail servers was not, but as I
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`indicated, I also personally wrote an application -- not
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`part of a team, just me -- to integrate a variety of
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`different messages into your Outlook inbox, so that if
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`you open up Outlook, you would get your e-mail, of
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`course, but you would also get voicemail and even
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`instant messages if they were sent through the
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`appropriate channels.
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` Q. Was that part of your -- strike that.
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` You stated that that was -- you personally
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`wrote the application, so that was not part of your work
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`with Digital Speech Systems?
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` A. That's incorrect. What I meant to indicate was
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`that some of the software was done by a team.
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` Q. Okay.
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` A. This was still at that company for a particular
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`customer, but I personally and alone developed that
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`particular application, as opposed to working as part of
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`a software engineering team.
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` Q. Understood. Thank you.
`
` So you mentioned Outlook. Is that the
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`e-mail program that you're referring to?
`
` A. Microsoft Outlook, which is their e-mail
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`application.
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` Q. Okay. Is -- in your opinion, before
`
`December 2003, was e-mail an instant messaging system?
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` MR. LOVELESS: Objection, form.
`
` A. No. E-mail was precisely asynchronous;
`
`therefore, not instant.
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` Q. Okay. But you integrated instant messaging
`
`into Outlook e-mails; is that correct? I'm just trying
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`to understand what the system did exactly.
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` A. Well, there are some limits to what I can
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`discuss. It was a confidential system done for an
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`embassy, so...
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` Q. Okay. Understood.
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` A. But, in general, a variety of messages,
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`including instant messages and voicemail, could be
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`viewed from within your Outlook inbox. So instead of
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`you having to check your phone, your instant messaging
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`device, which could also be a phone or could be
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`whatever, and checking your e-mail, you simply check
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`your e-mail, and all of your various communications
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`appeared with differential icons so you would know this
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`is a voicemail or this is a message as opposed to an
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`e-mail.
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` Q. Okay. So the -- so this integration was not
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`messages integrated within an e-mail message; it was
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`just within the -- the user interface of Outlook that
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`you were providing the integrated messages?
`
` A. That's correct.
`
` Q. So was the integrating messages already known
`
`types of instant messaging systems, such as AOL Instant
`
`Messenger, or was it a proprietary instant messaging
`
`software application that was being integrated?
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` MR. LOVELESS: Objection, form.
`
` A. We took messages from a variety of platforms
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`that were specific to this customer.
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` Q. Okay. And, yes, I don't want you to reveal
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`anything that's confidential. So, please, if I do ask
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`anything that touches on confidential information,
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`Page 24
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`please let me know.
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` A. I will.
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` Q. Okay. So if you could, and I apologize if you
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`did this already, but if the Outlook user interface is
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`open -- and I'm referring to the system that you helped
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`design or you did design yourself. If an instant
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`message was received, what would happen?
`
` A. Well --
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` MR. LOVELESS: Objection, form.
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` A. -- as much detail as I can go into,
`
`essentially, it was taken from wherever it would have
`
`normally been sent and additionally displayed within
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`your inbox. The same thing happened with voicemails.
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`They go to your voicemail server, but they're also
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`displayed within your inbox. So you could have accessed
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`the message through either interface that was preferable
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`to you.
`
` Q. So when you say displayed within the inbox, it
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`would be displayed along with e-mails, for example?
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` A. Correct. It would be an item in your inbox
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`that you could open and view.
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` Q. And if you wanted to respond to an instant
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`message that's displayed in your inbox, how would you do
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`that?
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` MR. LOVELESS: Objection, form.
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` A. In this system you could not respond to these
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`messages. They were meant to allow you to receive them
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`in a single location.
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` Q. And you believe these messages are instant
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`messages?
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` MR. LOVELESS: Objection, form.
`
` A. Yes, they were.
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` Q. And why do you believe they were instant
`
`messages?
`
` A. Well, they were sent as instant messages and
`
`would have also been received at the intended device,
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`such as if someone sent you an instant message, a text
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`message, to your phone, it would appear on your phone,
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`but it also would appear in your inbox.
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` So, for example -- and, again, I'm going to
`
`go as far as I can -- there are locations where phones
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`are not allowed within government agencies, but where
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`you do have access to e-mail.
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` Q. Uh-huh.
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` A. And if you're in such a location and someone is
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`sending you an urgent message, you would not receive it
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`because it's going to your phone, which is normally
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`stored in a box outside of this room.
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` Q. Uh-huh.
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` A. However, your inbox says, hey, there's an
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`urgent message. You may wish to be aware of it.
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` Q. Okay. So what does -- in your opinion, what
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`does "instant" mean?
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` MR. LOVELESS: Objection, form.
`
` Q. To be clear, just -- I'm asking in a time frame
`
`before December 2003.
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` A. Certainly.
`
` In general, instantaneous -- and we'll have
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`to refine this within specific context because words do
`
`have meaning within context. But as a general
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`out-of-context definition, I would say something that's
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`synchronous. For example, I'm speaking to you live
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`right now, and it's a synchronous conversation whereas
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`you can respond in real time, and I can respond to you.
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`If there was some significant or substantial delay, it's
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`no longer synchronous; and, therefore, it's no longer
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`instant.
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` Q. How much of a delay is acceptable in order for
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`the communication to still be instant?
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` MR. LOVELESS: Objection, form.
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` A. Well, the issue there can't be quantified as in
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`X number of milliseconds or seconds. It's more in the
`
`form of a typical conversation that would seem
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`relatively uninterrupted. And this is a place where
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`context means everything.
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` For example, if you were doing a moon
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`landing, even with voice communication, there's
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`several-second delays simply due to the speed of light
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`constrictions. That would seem normal to you, and
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`that's as close to instant as you can get. However, if
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`every time you ask me a question here, I pause for 8 to
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`12 seconds to answer, that would be very bizarre and
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`would not be considered instant. In fact, it would
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`probably do to question my mental health, but it would
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`not be instant.
`
` Q. What about in the context of the '622 patent,
`
`how much delay would be appropriate --
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` MR. LOVELESS: Objection, form.
`
` Q. -- for you to still have an instant message?
`
` A. Only enough delay that you could still
`
`facilitate an actual conversation.
`
` Q. What do you mean by "facilitate an actual
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`conversation"?
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` A. Well, the best way to define this is to define
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`the opposite. If I send you a letter through postal
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`services, that's the antithesis of instant or real time
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`because you won't even get it till some period in the
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`future. And then if you respond, and there will be a
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`period in the future before you can respond. It's not
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`possible for us to have a direct synchronized
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`communication.
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` Q. So remaining in the context of the system
`
`described in the '622 patent, if every message was
`
`delayed over a minute, would it still be instant?
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` MR. LOVELESS: Objection, form.
`
` A. I think with telecommunications, particularly
`
`at the time, that wouldn't have been that odd, simply
`
`because we had slow connections and slow speeds.
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`Essentially, the idea is -- let's say my wife sends me a
`
`text right now to tell me that our house is on fire.
`
` Q. Uh-huh.
`
` A. She wants a response in real time,
`
`synchronized. She does not want a response tomorrow or
`
`later this day. As long as it is within a time that a
`
`normal, reasonable person would consider actually
`
`synchronized, I would consider it instant. And, again,
`
`that's going to be a contextually defined thing, and I
`
`cannot define it down to X number of seconds or
`
`TSG Reporting - Worldwide 877-702-9580
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`Page 28 of 195
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` WILLIAM C. EASTTOM, II
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`milliseconds.
`
` Q. Okay. So when you say "synchronous," is
`
`another way to explain what you mean that -- is that the
`
`conversation is interruptible?
`
` MR. LOVELESS: Objection, form.
`
` A. No. Any conversation is interruptible, whether
`
`it's synchronous or asynchronous.
`
` Q. Is an e-mail interruptible?
`
` A. Sure.
`
` Q. How is it interruptible?
`
`
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