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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC., )
` )
` Petitioner, )
` ) Case No. IPR2018-00044
` vs. )
` ) Volume II
`VILOX TECHNOLOGIES LLC )
` ) Pages 57 to 101
` Patent Owner. )
`_________________________________)
`
` DEPOSITION OF WESLEY CHU, Ph.D.
` Marina del Rey, California
` Tuesday, November 6, 2018
`
`Reported by:
`ELIZABETH BORRELLI, CSR No. 7844, CCRR, CLR
`JOB NO. 150729
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC., )
` )
` Petitioner, )
` ) Case No. IPR2018-00044
` vs. )
` ) Volume II
`VILOX TECHNOLOGIES LLC )
` ) Pages 57 to 101
` Patent Owner. )
`_________________________________)
`
` DEPOSITION OF WESLEY CHU, Ph.D.
` Marina del Rey, California
` Tuesday, November 6, 2018
`
`Reported by:
`ELIZABETH BORRELLI, CSR No. 7844, CCRR, CLR
`JOB NO. 150729
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`Page 58
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` Deposition of WESLEY CHU, Ph.D., Volume
`II, taken on behalf of the Petitioner, at 4100
`Admiralty Way, Marina Del Rey, California,
`commencing at 10:03 a.m., Tuesday, November 6,
`2018, before Elizabeth Borrelli, a Certified
`Shorthand Reporter in the State of California,
`License No. 7844.
` * * *
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`APPEARANCES OF COUNSEL:
`
`For the Petitioner:
` HAYNES AND BOONE
` BY: JOHN EMERSON
` Attorney at Law
` 2323 Victory Avenue
` Dallas, Texas 75219
`
`For the Patent Owner:
` LAW OFFICES OF JOHN HARROP
` BY: JOHN HARROP
` Attorney at Law
` 601 Los Caminos Street
` St. Augustine, Florida 32095
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`Unified v. Vilox / Page 3 of 45
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` I N D E X
`WITNESS EXAMINATION
`WESLEY CHU, Ph.D.
`By MR. EMERSON 61
`By MR. HARROP 81
`
`Page 60
`
` R E F E R E N C E D E X H I B I T S
`
`EXHIBIT DESCRIPTION PAGE
`Exhibit 2027 Declaration of Wesley W. Chu, 61
` Ph.D. dated October 22, 2018,
` 17 pages
`Exhibit 1014 Goldberg patent, Patent No. 76
` 6,452,597, 14 pages
`
`Exhibit 1001 De Bellis patent, Patent No. 81
` 7,302,423, 69 pages
`
` INFORMATION REQUESTED
` (None)
` UNANSWERED QUESTIONS
` (None)
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`Page 61
` MARINA DEL REY, CALIFORNIA; TUESDAY, NOVEMBER 6, 2018
` 10:03 A.M.
`
` WESLEY CHU, Ph.D.,
` having been duly administered an oath in
` accordance with CCP 2094, was examined
` and testified as follows:
`
` EXAMINATION
`BY MR. EMERSON:
` Q. So, Dr. Chu, good morning again.
` A. Good morning.
` Q. How are you?
` A. Good.
` Q. Good. Any reason why you can't give
`truthful and accurate testimony today?
` A. No.
` Q. Not on any medications ore anything like
`that?
` A. No, uh-uh.
` Q. Good. So what you have in front of you,
`the Declaration of Wesley W. Chu, Ph.D. dated
`October 22, 2018. And this is Exhibit 2027 in this
`IPR.
` Do you see that?
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` A. Yes.
`BY MR. EMERSON:
` Q. And you're familiar with this document,
`right?
` A. Yes.
` Q. Did you write this?
` A. Yes.
` Q. You did?
` Did you write it by yourself?
` A. No, it was together with John.
` Q. How much time did you spend on it?
` A. Oh, like a week.
` Q. A week?
` A. Yeah.
` Q. Okay. How much -- I mean, how much time
`during that week, how many hours would you expect
`you spent on this declaration?
` A. Maybe like 40 hours.
` Q. 40 hours?
` A. Yeah.
` Q. So a full week on this, full workweek on
`this?
` A. Yeah. Off and on, yeah, yeah.
` Q. Off and on, okay.
` But the amount of time you spent working
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`on it was about 40 hours?
` A. Yeah.
` Q. Okay. So why don't turn to page 2 of 17.
`Are you there?
` A. Page 2 of 17?
` Q. Two, yes, sir. It will be to your left.
` A. 17, page --
` Q. Page 2 of 17.
` A. Oh, 2, yes, yes.
` Q. All right. Is that the one where at the
`top it says "Introduction"?
` A. Yeah.
` Q. All right. So I'm looking at -- in
`paragraph 2, you mention that you reviewed
`Exhibit 2022, which is a declaration of Joseph De
`Bellis.
` Do you see that?
` A. Yes.
` Q. All right. And Joseph De Bellis is the
`inventor of the patent that is the subject of this
`the IPR, right?
` A. Right.
` Q. Have you ever met Dr. De Bellis?
` A. Yes.
` Q. How many times?
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` A. One or two times.
` Q. One or two times?
` And when was that?
` A. Oh, many years ago.
` Q. Many years ago? Really?
` A. Yeah.
` Q. How did you -- how did you meet him?
` A. Okay. I read -- Dr. De Bellis is a
`schoolmate of my son.
` Q. Okay.
` A. We met on that occasion.
` Q. Okay. When was that?
` A. Maybe 20 years ago.
` Q. 20 years ago?
` A. Yeah.
` Q. And when you say Dr. De Bellis was a
`schoolmate of your son --
` A. Yeah.
` Q. -- was this when your son was in college?
` A. Yeah, they were schoolmate together at
`Georgetown.
` Q. At Georgetown, studying what?
` A. Medicine.
` Q. Medicine?
` A. Yeah.
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` Q. Okay. Your son's a doctor?
` A. Yeah.
` Q. What kind of doctor?
` A. Ophthalmologist.
` Q. That's right. I think we talked about
`this offline?
` A. Right, yeah.
` Q. -- at our last depo, didn't we?
` A. Right.
` Q. Okay. So how did you meet Dr. De Bellis?
`Let me back up a second.
` So your son and Dr. De Bellis were in
`medical school at Georgetown?
` A. Right.
` Q. All right. And so how did you come to
`meet Dr. De Bellis?
` A. Oh, he -- he came to -- okay. He came
`to -- to visit my son. My son was studying at
`Georgetown for two years, and last two years he
`finished medical school at UCLA. But he did come
`to -- they're friends. He came to Los Angeles to
`visit my son, and so I just casually met them.
`That's all.
` Q. Okay. When you met Dr. De Bellis, did you
`discuss any of the technology --
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` A. Nothing.
` Q. -- during --
` A. Nothing.
` Q. Okay.
` A. Just shake hands.
` Q. Sure.
` A. That's it. My son's friend, you know,
`that's it.
` Q. So let's -- I'll try to do this too.
`Let's try not to talk over each other, okay?
` A. Okay.
` Q. All right. It gets easy when we start
`talking like this, just a regular conversation, you
`know, we cut each other off.
` So do you -- do you have any firsthand
`knowledge of Dr. De Bellis conceiving the claimed
`subject matter?
` A. No, not except from the -- from the -- his
`deposition -- in his declaration.
` Q. Other than his declaration --
` A. Yeah, yeah.
` Q. -- do you have any independent knowledge
`of Dr. De Bellis's conception of the claimed subject
`matter?
` A. No.
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` Q. Other than his declaration, do you have
`any firsthand knowledge or independent knowledge of
`Dr. De Bellis reducing the claimed subject matter to
`practice?
` A. No.
` Q. Have you ever used the product that
`Dr. De Bellis allegedly developed?
` A. No.
` Q. Okay. Let's turn to page 4, please.
` Are you there?
` A. Yeah, I'm here.
` Q. And I'm going to direct your attention to
`paragraph 10.
` Do you see that?
` A. Yes.
` Q. And there in the first sentence of
`paragraph 10 you mention a PHOSITA, P-H-O-S-I-T-A.
` Do you see that?
` A. Right, right.
` Q. What's a PHOSITA?
` A. PHOSITA is a person that was -- was the --
`with the knowledge of the -- with the knowledge of
`the field and able to understand the patent and...
` Q. Okay. When we talk about a PHOSITA, are
`we referring to a particular time?
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` A. We would -- I think we are talking about
`when he presented claim 24, 25, at that time he
`should be able to understand and -- understand what
`this claim is and whether this could be implemented
`in practice and things like that.
` [Reporter requests clarification.]
` THE WITNESS: Could be implemented in
`practice and make judgments on.
`BY MR. EMERSON:
` Q. So we would determine -- we would
`determine a PHOSITA as of the time that the inventor
`presents his claims, right?
` A. Right.
` Q. Okay. But in this particular case, how
`would you define a PHOSITA?
` A. Well, this is a person with a computer
`science degree --
` Q. Uh-huh.
` A. -- and one year's experience, practical
`experience, in database area.
` Q. Okay. Now I'm going to stick with
`paragraph 10 --
` A. Okay.
` Q. -- but if you could turn to the next page,
`please.
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` A. Okay.
` Q. Now, on the second complete sentence, do
`you see there that it begins, "That is" --
` A. Yes.
` Q. -- comma?
` A. Yeah.
` Q. So you state there, "That is, as a PHOSITA
`would understand, neither proposed amended claim 24
`nor 25 recites or requires, 'displaying each
`truncated entry.'"
` Do you see that?
` A. Yes.
` Q. All right. And then you are comparing
`that to some language two sentences down that reads
`as follows: "The claim limitation of 'a truncated
`portion of each entry in the selected database field
`is displayed.'"
` Do you see that language?
` A. Yeah, yeah.
` Q. So my question for you is this: What is
`the difference between displaying each truncated
`entry and a truncated portion of each entry in the
`selected database field is displayed? Can you
`explain to me how those two phrases differ?
` A. Let me just -- need to read the two
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`paragraph, two sentence. Display each truncated
`entry. First is a truncated portion of each entry
`in the select database for display.
` Q. Correct.
` A. Pretty much the same.
` Q. Okay. Got it. Thank you.
` All right. Would you turn, then, to page
`7. And I'm looking -- are you there?
` A. Yeah.
` Q. I'm looking at paragraph 13?
` A. Yeah.
` Q. You have a quotation here. You are
`purporting to quote from Dr. Greenspun's
`declaration, and you have a quotation here that
`begins "Would be taught by" and ends "small in
`size."
` Do you see that?
` A. Yeah, I saw it.
` Q. Is that an accurate quotation?
` A. We can look at the exhibit to --
` Q. Sure. Actually, you know what, I don't
`have a -- I don't have a hard copy of that. Can
`I -- I can walk around and show you --
` A. Yeah, yeah.
` Q. -- on my iPad, if that's okay?
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` A. Yeah, yeah.
` MR. HARROP: Or he can walk around and
`looked at yours.
` MR. EMERSON: Oh, either way. Yeah,
`that's fine.
` MR. HARROP: So will I.
` THE WITNESS: I just want to be accurate.
`BY MR. EMERSON:
` Q. No, sure. Paragraph 13. And I don't --
`okay. So here is -- let me just make sure we're --
`let's see here. I'm on page 6, and so let me
`just -- so here we have Dr. Greenspun's dec, right?
` A. Yeah.
` Q. And you're citing to paragraph 13.
` A. Uh-huh.
` Q. Here's paragraph 13.
` A. "Small in size."
` [Reporter requests clarification.]
`BY MR. EMERSON:
` Q. Do you need it bigger?
` A. No, in here, it says "small in size," the
`words.
` Q. Right. Anyway, I was just -- it looks
`like we've got some extra language in here, turning
`back to paragraph 13 of your dec, after Kanevsky,
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`you have a semicolon, and then "Greenspun MtA,
`asserts."
` A. "If the underlying database was small in
`size."
` Q. Yeah.
` A. Yeah, that's what the --
` [Reporter requests clarification.]
` THE WITNESS: "Small in size." That's
`what this is stating in Greenspun's declaration.
`BY MR. EMERSON:
` Q. Anyway, it looks like we have a few extra
`words after -- in your quotation, after Bertram,
`right? So here, I'll even highlight it for you.
` A. "If the underlying database was small in
`size"; is that what you...
` Q. Here you've got some -- you see "Greenspun
`MtA asserts"?
` A. Yeah, it says, "if the underlying database
`was small in size."
` Q. Yeah. So it's just some extra language in
`there, right --
` A. Yeah.
` Q. -- in paragraph 13 of your --
` A. Yeah, right.
` Q. -- declaration? Just a typo?
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` A. "Would be taught by" -- oh, this
`(indecipherable.)
` [Reporter requests clarification.]
`BY MR. EMERSON:
` Q. The part that says Greenspun -- the part
`that goes, "; Greenspun MtA asserts," that's not in
`Dr. Greenspun's declaration, right?
` A. No.
` Q. No, okay.
` So let me just -- that's -- that's good.
` A. Okay.
` Q. All right. Did you -- did you proofread
`this declaration? Who was -- who was -- let me put
`this way, Dr. Chu: Who was responsible for
`proofreading this declaration?
` A. I guess I have to say I am, yeah.
` Q. Okay.
` A. But we're doing -- joining was -- was John
`and -- but -- but the idea points are mine.
` Q. Okay. All right. Let's -- let's go on to
`page 11, please.
` Are you there?
` A. Yeah.
` Q. So on page 11 --
` A. Uh-huh.
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` Q. -- this is part of paragraph 23 of your
`declaration.
` A. Yes.
` Q. And in paragraph 23 of your declaration,
`you're talking about the Goldberg reference, right?
` A. Yes.
` Q. And about halfway down the page on page
`11, you state, "Even were Goldberg." Do you see
`that sentence, begins "Even were Goldberg"?
` A. We have a lot of Goldbergs here. Can
`understand. "Even" -- yeah --
` Q. Yeah, "Even" --
` A. -- "Even were Goldberg."
` Q. Right. So that reads -- and I'll just
`read it into the record.
` A. Yeah.
` Q. "Even were Goldberg to be read to apply to
`a 'plurality of entries' (which no PHOSITA would
`understand from studying Goldberg), a PHOSITA would
`understand it because Goldberg's system is directed
`to making data 'readable' to a vehicle operator
`(driver), Goldberg simply would display each of the
`entries (adjusted in size or not adjusted) on a
`separate screen or page so that the driver could
`readily read (and grasp) the data using only brief
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`glances at the computer screen to avoid distraction
`from safe operation of the vehicle."
` Do you see that?
` A. Yes.
` Q. Okay. Now, your -- your declaration
`doesn't point us to anything in Goldberg that would
`support that statement, does it?
` A. In the Goldberg's patent, it does mention
`they want to be readable and for the vehicle
`operators.
` Q. Okay. So specifically what I'm talking
`about is that you don't provide any support for your
`testimony that Goldberg says to display each entry
`on a separate screen or on a separate page, correct?
` A. Well, if you don't have enough space, then
`you have to go display that on another page.
` [Reporter requests clarification.]
` THE WITNESS: Yeah, another screen. Yeah.
`BY MR. EMERSON:
` Q. Understood.
` But your declaration doesn't direct the
`reader to anything in Goldberg that says to display
`each entry on a separate screen or a separate page,
`does it?
` A. I have to look at the Goldberg's patent.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Ex. 1016 / IPR2018-00044
`Unified v. Vilox / Page 19 of 45
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`Page 76
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` Q. Okay.
` A. So can maybe -- yeah.
` Q. And we can do that.
` But first I want to -- I'm talking about
`simply your declaration.
` A. Okay.
` Q. Okay?
` A. Yeah.
` Q. Now, your declaration doesn't provide
`support for your statement that Goldberg says to
`display each entry on a separate screen or a
`separate page, right?
` A. No.
` Q. No, okay.
` So here is Goldberg. And for the record,
`Goldberg is Exhibit 1014.
` MR. EMERSON: And off the record.
` (Discussion off the record.)
` THE WITNESS: I cannot specifically find
`the sentence of going to a different screen, but I
`feel that, like, if you want -- the screen is very
`small, you cannot display all the things in spite of
`the fact you can shrink the font size, then if this
`fails, then you have to use a different size, an
`additional screen to see the text. So...
`
`TSG Reporting - Worldwide 877-702-9580
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`Ex. 1016 / IPR2018-00044
`Unified v. Vilox / Page 20 of 45
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`BY MR. EMERSON:
` Q. Okay. All right.
` All right. Can you turn, please, to page
`15.
` A. Okay. Yes.
` Q. All right. So that's this -- sort of a
`claim chart you have here, right?
` A. Right.
` Q. All right. So on claim -- I'm sorry, the
`first -- the first complete row in -- on page 15,
`you have under claim limitation, "Determining a
`database schema for a database."
` A. Right.
` Q. Do you see that?
` A. Yeah.
` Q. And on the right-hand column, you state,
`"A PHOSITA would understand that a schema is
`determined in order to present the list of available
`data fields displayed in 201."
` A. Yes.
` Q. Do you see that? Okay.
` Now, here you don't explain how the schema
`is determined, do you?
` A. No.
` Q. No. Is it your opinion that if a list of
`
`TSG Reporting - Worldwide 877-702-9580
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`Ex. 1016 / IPR2018-00044
`Unified v. Vilox / Page 21 of 45
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`available data fields is displayed, that a POSITA
`would always understand that the schema was
`determined?
` A. You could use trial by error method to
`determine the schema based on the data that you
`have.
` Q. Okay.
` A. Received.
` Q. I don't think that's answering my
`question.
` A. Okay.
` MR. EMERSON: So I'll object to that as
`nonresponsive.
`BY MR. EMERSON:
` Q. So here's my question, and maybe it wasn't
`clear.
` Is it your opinion that if a list of
`available data fields is displayed, that a POSITA
`would always understand that the schema was
`determined -- regardless of the manner in which it
`was determined, would a POSITA always understand
`that the schema was determined?
` A. Well, you have -- the POSITA have to find
`a way to -- to derive the schema from the data. And
`as in the patent say there are many way you can do
`
`TSG Reporting - Worldwide 877-702-9580
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`Ex. 1016 / IPR2018-00044
`Unified v. Vilox / Page 22 of 45
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`it. One is by trial and error methods and try to
`see -- because if you look at the data, the set of
`data coming in from --
` [Reporter requests clarification.]
` THE WITNESS: -- the set of data that you
`receive, if it's relating with driving a vehicle,
`relating with --
` [Reporter requests clarification.]
` THE WITNESS: -- vehicle, and also related
`to the performance of the vehicle and things like
`that, then you can start to see this schema is
`related -- was driving a vehicle. And so you can
`construct a schema based on those information by
`trial and error methods.
`BY MR. EMERSON:
` Q. So is that a yes?
` A. Yes.
` Q. Okay.
` All right.
` A. Maybe not exactly right, you know, but I
`have to try many, many times.
` [Reporter requests clarification.]
` THE WITNESS: Trial and error but many
`times, so yeah. Maybe improve upon it so then you
`can get started.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Ex. 1016 / IPR2018-00044
`Unified v. Vilox / Page 23 of 45
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`Page 80
` MR. EMERSON: All right. I'll object to
`the last part of that answer as -- after I said "All
`right" as nonresponsive.
`BY MR. EMERSON:
` Q. All right. Let's stay on page 15, okay?
` A. Okay.
` Q. And I'm going to go down a couple of -- or
`three claim limitations to "determining a number of
`characters."
` Do you see that?
` A. Yes.
` Q. And then you have on the right-hand column
`a citation to the De Bellis patent.
` A. Yes.
` Q. And you list 38 different figures and
`about 10 pages of text?
` A. Uh-huh.
` Q. Is there any way that you can narrow that
`large citation down a bit? That's most of the
`patent.
` A. That's true. That's true.
` But you could just say -- just look at the
`first few, you know. Like page 7, 19. Well, I wish
`I had the patent.
` Q. Sure, I can hand you a copy. So this is
`
`TSG Reporting - Worldwide 877-702-9580
`
`Ex. 1016 / IPR2018-00044
`Unified v. Vilox / Page 24 of 45
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`Page 81
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`Exhibit 1001.
` A. Yeah.
` Q. The De Bellis patent.
` THE WITNESS: Well, I will say that let's
`just look at the paragraphs 7, 8, 9. That should be
`sufficient.
`BY MR. EMERSON:
` Q. Paragraphs 7, 8 and 9?
` A. I see paragraph 7 to -- 7 -- 10 to -- 10
`to 16, 40, right, through paragraph 16, but I think
`paragraph 7, 8, and 9 should -- and beginning of 9
`should cover quite a bit as well.
` Q. Okay. So do you mean column 7, 8 and 9?
` A. Column, sorry, sorry. Not paragraph,
`column, column.
` Q. Okay. All righty, then.
` MR. EMERSON: Well, I'm going to pass the
`witness.
` MR. HARROP: Okay. Can we take a short
`break, and I'll do a redirect?
` MR. EMERSON: Sure.
` (Recess.)
` EXAMINATION
`BY MR. HARROP:
` Q. Dr. Chu, earlier in your testimony you
`
`TSG Reporting - Worldwide 877-702-9580
`
`Ex. 1016 / IPR2018-00044
`Unified v. Vilox / Page 25 of 45
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`Page 82
`were asked about the content of paragraph 10 of your
`declaration. And you were directed to read a couple
`phrases or sentences from that paragraph 10.
` Would you turn to paragraph 10, please?
` A. Yeah.
` Q. Okay. Would you read -- would you read
`the entire content of paragraph 10 that's on this?
`Just read it to yourself --
` A. Okay.
` Q. -- from this page and all the way to the
`end of that sentence that ends on page 5. Read from
`here (indicating) --
` A. Here to --
` Q. -- to the end -- to the end of that
`sentence, to there (indicating). And read it to
`yourself.
` A. Here (indicating). Okay.
` Yeah.
` Q. Okay. So let's go back to the first
`sentence. Would you read that out loud, please?
` A. "A PHOSITA will understand that in
`proposed amended claims 24 and 25, the claimed
`truncation reduce characters and will result in
`collapsing the result list vertically so that the
`result list may be displayed on a terminal."
`
`TSG Reporting - Worldwide 877-702-9580
`
`Ex. 1016 / IPR2018-00044
`Unified v. Vilox / Page 26 of 45
`
`
`
`Page 83
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` Q. Okay. Now, read the next sentence.
` A. "Thus, the city amend -- Armandia and
`Armonk, in the disclosed example, become 'Arm'
`therefore -- thereby reducing the number of lines by
`one."
` Q. Okay.
` A. "However" --
` Q. Let's stop -- no, that's --
` A. Okay.
` Q. That's far enough.
` So in that sentence that you just read,
`"The cities Amandia and Armonk, in the disclosed
`example, become 'Arm' thereby reducing the number of
`lines to one," what does that mean?
` A. That means you -- you trunc- -- you
`reduce -- to reduce the vertical, you reduce the
`space by one line.
` Q. Well, what does the term "Arm" stand for
`in this sentence?
` A. Arm is a truncation. It's a -- it's a --
`it's a route of Armandia and Armonk.
` Q. Is Arm a truncated portion of an entry?
` A. Yes.
` Q. Is Arm a truncated portion of Armandia?
` A. Yeah.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Ex. 1016 / IPR2018-00044
`Unified v. Vilox / Page 27 of 45
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`Page 84
` Q. And is Arm a truncated portion of Armonk?
` A. Yes.
` Q. Is Arm a truncated portion of both
`Armandia and Armonk?
` A. Yes.
` Q. Okay. Let's go to the next page. You see
`the last sentence, paragraph 10. It starts "Thus"?
` A. Okay.
` Q. (Indicating.)
` A. Oh, "Thus," yeah.
` Q. Could you read that sentence, please?
` A. "Thus, a PHOSITA, viewing disclosure and
`each of the proposed amended claims 24 and 25, would
`understand that truncation of Armandia and Armonk to
`have -- to three characters and displaying 'Arm' on
`the terminal meets the limitation of the truncation
`of 'a truncated portion of each entry in the select
`database field is displayed' - 'Arm' being a
`truncated portion of Armandia and Armonk."
` Q. So do you understand what the purpose of
`the truncation down to Arm is trying to achieve?
` A. Trying to reduce space.
` Q. What kind of space?
` A. Space -- reduce it one line and so reduce
`the space, space on terminal.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Ex. 1016 / IPR2018-00044
`Unified v. Vilox / Page 28 of 45
`
`
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`Page 85
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` Q. And how does that one line get removed?
` A. Vertically there are -- there are --
`vertically reduce the vertical space.
` Q. But how is the vertical space removed or
`reduced?
` A. By instead of using two -- you just use
`one -- or one line Arm, you know.
` Q. Just use one Arm for what purpose?
` A. For -- for reduce the -- for the -- for
`reduce the space, the space space.
` Q. But what does the one Arm stand for?
` A. It stand for Armandia and Armonk, which is
`being a truncated portion of Armandia and Armonk.
` Q. Okay. Does that differ -- displaying Arm
`as a truncated portion of both Armandia and Armonk,
`does that differ from displaying each truncated
`entry?
` MR. EMERSON: Objection. Form.
` THE WITNESS: Repeat the question again?
`BY MR. HARROP:
` Q. Well, I'll try to rephrase it so I can try
`to get the form right here.
` In the second full sentence of paragraph
`10 on page 5, I'll read it. Page 5. "That is, as a
`PHOSITA would understand, neither proposed amended
`
`TSG Reporting - Worldwide 877-702-9580
`
`Ex. 1016 / IPR2018-00044
`Unified v. Vilox / Page 29 of 45
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`Page 86
`claim 24 nor 25 recites or requires 'displaying each
`truncated entry.'"
` A. Yes.
` Q. Right.
` A. Yeah.
` Q. You had said that there's not much
`difference -- or I don't want to mischaracterize
`what you were saying, but as I recall, you said
`something to the effect that there's not much
`difference between displaying each truncated entry
`and displaying a truncated portion of each entry.
` MR. EMERSON: Is there a question?
` MR. HARROP: Yeah. I'm -- there is a
`question coming. I just want him to catch up.
`BY MR. HARROP:
` Q. So is displaying each truncated entry
`essentially the same as displaying a truncated
`portion of each entry?
` MR. EMERSON: Object to the form.
` MR. HARROP: Let me --
` THE WITNESS: Yeah.
` MR. HARROP: Let me ask the question
`differently.
`BY MR. HARROP:
` Q. This sentence says, and I'll read this
`
`TSG Reporting - Worldwide 877-702-9580
`
`Ex. 1016 / IPR2018-00044
`Unified v. Vilox / Page 30 of 45
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`Page 87
`sentence, "That is, as a PHOSITA would understand,
`neither proposed amended claim 24 nor 25 recites or
`requires 'displaying each truncated entry.'"
` What do claims 24 and 25 recite?
` A. Recite just show the truncated --
`truncated terms, yeah, don't need to display --
` [Reporter requests clarification.]
` THE WITNESS: -- do not need to display
`each truncated entry.
`BY MR. HARROP:
` Q. Okay. I think we'll move on to another...
` This next question comes from the
`discussion we had starting on page 11 of your
`declaration.
` A. Yes.
` Q. And Mr. Emerson had you look at this
`paragraph and asked you if you had provided any
`citation to this notion that a POSITA would
`understand -- would not understand that Goldberg
`provides a teaching or suggestion to display each of
`the plurality of entries on a single page of the
`terminal. Hopefully I'm not mischaracterizing what
`you were saying. Okay.
` Now, would you look at the middle of this
`paragraph?
`
`TSG Reporting - Worldwide 877-702-9580
`
`Ex. 1016 / IPR2018-00044
`Unified v. Vilox / Page 31 of 45
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`
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` A. Yeah.
` Q. You see a citation to Exhibit 1014?
` A. 1014, yeah.
` Q. What is Exhibit 1014?
` A. Figure 5a --
` Q. No, no. What is Exhibit 1014?
` A. Oh, that is the patent.
` Q. Patent of what?
` A. Goldberg's patent.
` Q. Okay. And what is the citation that you
`provide there?
` A. Figure 5a to 5g.
` Q. What precedes that?
` A. 1:63.
` [Reporter requests clarification.]
` THE WITNESS: 63.
`BY MR. HARROP:
` Q. Okay. F
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