`MARKUS JAKOBSSON Ph.D. 10/24/2018MARKUS JAKOBSSON Ph.D. 10/24/2018
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`MARKUS JAKOBSSON Ph.D. 10/24/2018MARKUS JAKOBSSON Ph.D. 10/24/2018
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` INDEX TO EXAMINATIONS
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` WITNESS: MARKUS JAKOBSSON, Ph.D.
`EXAMINATION
` PAGE
`BY MR. MUDD
` 5
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`Page 4
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` INDEX TO EXHIBITS
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` EXPERT
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC.
`
` Petitioner,
`
`v.
`
` IPR2018-00067
`U.S. Patent No. 8,577,813
`UNIVERSAL SECURE REGISTRY
`LLC,
`
` Patent Owner.
`_____________________________
`
` DEPOSITION OF EXPERT
` MARKUS JAKOBSSON, Ph.D.
`
` OCTOBER 24, 2018
`
` 50 California Street, 22nd Floor
` San Francisco, California
`
`REPORTED BY:
`Siew G. Ung
`CSR No. 13994, RPR, CSR
`
`APPEARANCES:
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` MARKUS JAKOBSSON, Ph.D.
`
` WEDNESDAY, OCTOBER 24, 2018
`
` Siew G. Ung CSR No. 13994, RPR
`
`MARKED
`
` DESCRIPTION
`
` PAGE
`
`Exhibit 1
`
` Petitioner's Notice of 5
`
` Deposition of Markus Jakobsson
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`Exhibit 2
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` United States Patent, Bohannon 110
`
` et al.; Patent No.: US 6,901,145
`
` B1; Date of Patent: May 31, 2005
`
`Exhibit 3
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` United States Patent Application 166
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` Publication, Jakobsson et al.;
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` Pub No.: US 2004/0172535 A1; Pub
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` Date: September 2, 2004
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` For Petitioner:
` ERISE IP, P.A.
` JASON R. MUDD, ESQ.
` 7015 College Boulevard, Suite 700
` Overland Park, Kansas 66211
` 913.777.5600
` jason.mudd@eriseip.com
`
` MICHELLE A. CALLAGHAN, ESQ.
` 5600 Greenwood Plaza Boulevard, Suite 200
` Greenwood Village, Colorado 80111
` 913.777.5600
` michelle.callaghan@eriseip.com
`
` For Patent Owner:
` QUINN EMANUEL URQUHART & SULLIVAN, LLP
` NIMA HEFAZI, ESQ.
` 865 South Figueroa Street, 10th Floor
` Los Angeles, California 90017
` 213.443.3000
` nimahefazi@quinnemanuel.com
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`www.alaris.uswww.alaris.us
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`www.alaris.uswww.alaris.us
`
`
`ALARIS LITIGATION SERVICESALARIS LITIGATION SERVICES
`
`ALARIS LITIGATION SERVICESALARIS LITIGATION SERVICES
`
`Phone: 1.800.280.3376Phone: 1.800.280.3376
`
`Phone: 1.800.280.3376Phone: 1.800.280.3376
`
`1 (Pages 1 to 4)
`
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`Fax: 314.644.1334Fax: 314.644.1334
`
`Fax: 314.644.1334Fax: 314.644.1334
`
`IPR2018-00067
`Unified EX1033 Page 1
`
`

`

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`MARKUS JAKOBSSON Ph.D. 10/24/2018MARKUS JAKOBSSON Ph.D. 10/24/2018
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`MARKUS JAKOBSSON Ph.D. 10/24/2018MARKUS JAKOBSSON Ph.D. 10/24/2018
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` SAN FRANCISCO, CALIFORNIA;
`
` WEDNESDAY, OCTOBER 24, 2018, 9:02 A.M.
`
` ***
`
` (Whereupon, Exhibit 1 was pre-marked
`
` for identification.)
`
` MARKUS JAKOBSSON, Ph.D.,
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` having been first duly sworn, was examined and
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` testified as follows:
`
` EXAMINATION BY MR. MUDD
`
`BY MR. MUDD:
`
`
` Q. Good morning. Q. Good morning.
`
` Q. Good morning. Q. Good morning.
` A. Good morning.
`
`
` Q. Can you state your name for the record, Q. Can you state your name for the record,
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` Q. Can you state your name for the record, Q. Can you state your name for the record,
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`please, and spell it?please, and spell it?
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`please, and spell it?please, and spell it?
` A. Bjorn Markus Jakobsson.
`
`
` Q. And could you spell that, please, for the Q. And could you spell that, please, for the
`
` Q. And could you spell that, please, for the Q. And could you spell that, please, for the
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`court reporter?court reporter?
`
`court reporter?court reporter?
` A. B-J-O-R-N, M-A-R-K-U-S, J-A-K-O-B-S-S-O-N.
`
`
` Q. Okay. Good morning, Dr. Jakobsson. My Q. Okay. Good morning, Dr. Jakobsson. My
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` Q. Okay. Good morning, Dr. Jakobsson. My Q. Okay. Good morning, Dr. Jakobsson. My
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`name is Jason Mudd. I'm with the law firm of Erisename is Jason Mudd. I'm with the law firm of Erise
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`name is Jason Mudd. I'm with the law firm of Erisename is Jason Mudd. I'm with the law firm of Erise
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`IP and representing the petitioner, Unified Patents,IP and representing the petitioner, Unified Patents,
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`IP and representing the petitioner, Unified Patents,IP and representing the petitioner, Unified Patents,
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`in this proceeding.in this proceeding.
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`in this proceeding.in this proceeding.
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` First, I'm going to hand you what's been First, I'm going to hand you what's been
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` First, I'm going to hand you what's been First, I'm going to hand you what's been
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`marked Exhibit 1, which has a title: "Petitioner'smarked Exhibit 1, which has a title: "Petitioner's
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`marked Exhibit 1, which has a title: "Petitioner'smarked Exhibit 1, which has a title: "Petitioner's
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`Notice of Deposition of Markus Jakobsson."Notice of Deposition of Markus Jakobsson."
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`Notice of Deposition of Markus Jakobsson."Notice of Deposition of Markus Jakobsson."
`
`1
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` You understand that you are appearing You understand that you are appearing
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` You understand that you are appearing You understand that you are appearing
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`Page 6
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`ask that we not speak over each other.ask that we not speak over each other.
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`ask that we not speak over each other.ask that we not speak over each other.
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` A. That's fine.
`
`
` Q. So I'll wait for you -- so if you'll wait Q. So I'll wait for you -- so if you'll wait
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` Q. So I'll wait for you -- so if you'll wait Q. So I'll wait for you -- so if you'll wait
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`for me to finish asking my question before you beginfor me to finish asking my question before you begin
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`for me to finish asking my question before you beginfor me to finish asking my question before you begin
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`answering, and I will wait for you to finish youranswering, and I will wait for you to finish your
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`answering, and I will wait for you to finish youranswering, and I will wait for you to finish your
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`answer before I ask the next question. Is thatanswer before I ask the next question. Is that
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`answer before I ask the next question. Is thatanswer before I ask the next question. Is that
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`fair?fair?
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`fair?fair?
`
` A. That is fair.
`
` MR. HEFAZI: And, Markus, just before we
`
`get going, could you please take a little bit of
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`time so that I could lodge an objection if I need to
`
`before you respond?
`
` THE WITNESS: Yes, I will.
`
` BY MR. MUDD:
`
`
` Q. And that was my next point. Your counsel Q. And that was my next point. Your counsel
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` Q. And that was my next point. Your counsel Q. And that was my next point. Your counsel
`
`
`may object at certain times during the deposition,may object at certain times during the deposition,
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`may object at certain times during the deposition,may object at certain times during the deposition,
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`but you understand that you are to answer thebut you understand that you are to answer the
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`but you understand that you are to answer thebut you understand that you are to answer the
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`question still unless your counsel specificallyquestion still unless your counsel specifically
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`question still unless your counsel specificallyquestion still unless your counsel specifically
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`instructs you not to answer?instructs you not to answer?
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`instructs you not to answer?instructs you not to answer?
`
` A. Yes.
`
`
` Q. Is there any reason today such as a Q. Is there any reason today such as a
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` Q. Is there any reason today such as a Q. Is there any reason today such as a
`
`
`medication or illness or anything that would preventmedication or illness or anything that would prevent
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`medication or illness or anything that would preventmedication or illness or anything that would prevent
`
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`you from testifying truthfully and fully today?you from testifying truthfully and fully today?
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`you from testifying truthfully and fully today?you from testifying truthfully and fully today?
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` A. No.
`
`
` Q. If at any time today I ask you a question Q. If at any time today I ask you a question
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` Q. If at any time today I ask you a question Q. If at any time today I ask you a question
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`you don't understand, will you let me know?you don't understand, will you let me know?
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`you don't understand, will you let me know?you don't understand, will you let me know?
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`Page 8
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`today to testify pursuant to this deposition notice,today to testify pursuant to this deposition notice,
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`today to testify pursuant to this deposition notice,today to testify pursuant to this deposition notice,
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` A. I sure will.
`
`
`Exhibit 1?Exhibit 1?
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`Exhibit 1?Exhibit 1?
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` A. Yes.
`
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` Q. You understand this deposition is for the Q. You understand this deposition is for the
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` Q. You understand this deposition is for the Q. You understand this deposition is for the
`
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`proceeding IPR2018-00067?proceeding IPR2018-00067?
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`proceeding IPR2018-00067?proceeding IPR2018-00067?
`
` A. Yes.
`
`
` Q. And this proceeding relates to U.S. Patent Q. And this proceeding relates to U.S. Patent
`
` Q. And this proceeding relates to U.S. Patent Q. And this proceeding relates to U.S. Patent
`
`
`8577813. Do you understand that?8577813. Do you understand that?
`
`8577813. Do you understand that?8577813. Do you understand that?
`
` A. Correct.
`
`
` Q. Dr. Jakobsson, about how many times have Q. Dr. Jakobsson, about how many times have
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` Q. Dr. Jakobsson, about how many times have Q. Dr. Jakobsson, about how many times have
`
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`you been deposed before?you been deposed before?
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`you been deposed before?you been deposed before?
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` A. Ten to 15.
`
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` Q. I'll just briefly go through some of the Q. I'll just briefly go through some of the
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` Q. I'll just briefly go through some of the Q. I'll just briefly go through some of the
`
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`ground rules. You understand that you're under oathground rules. You understand that you're under oath
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`ground rules. You understand that you're under oathground rules. You understand that you're under oath
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`today, and it's the same oath that you take as iftoday, and it's the same oath that you take as if
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`today, and it's the same oath that you take as iftoday, and it's the same oath that you take as if
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`you were testifying in a court of law?you were testifying in a court of law?
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`you were testifying in a court of law?you were testifying in a court of law?
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` A. Yes, I do.
`
`
` Q. And do you understand that I need you to Q. And do you understand that I need you to
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` Q. And do you understand that I need you to Q. And do you understand that I need you to
`
`
`give verbal responses today, so yeses and nos rathergive verbal responses today, so yeses and nos rather
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`give verbal responses today, so yeses and nos rathergive verbal responses today, so yeses and nos rather
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`than uh-huh's or huh-uh's or head shakes or nods.than uh-huh's or huh-uh's or head shakes or nods.
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`than uh-huh's or huh-uh's or head shakes or nods.than uh-huh's or huh-uh's or head shakes or nods.
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`Do you understand that?Do you understand that?
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`Do you understand that?Do you understand that?
`
` A. Understood.
`
`
` Q. And we have a court reporter here today Q. And we have a court reporter here today
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` Q. And we have a court reporter here today Q. And we have a court reporter here today
`
`
`taking everything down in a written record, so I'dtaking everything down in a written record, so I'd
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`taking everything down in a written record, so I'dtaking everything down in a written record, so I'd
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` Q. And if you answer my question, I'll assume Q. And if you answer my question, I'll assume
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` Q. And if you answer my question, I'll assume Q. And if you answer my question, I'll assume
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`you've understood it. Is that fair?you've understood it. Is that fair?
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`you've understood it. Is that fair?you've understood it. Is that fair?
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` A. That is fair.
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`
` Q. What did you do to prepare for today's Q. What did you do to prepare for today's
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` Q. What did you do to prepare for today's Q. What did you do to prepare for today's
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`deposition?deposition?
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`deposition?deposition?
`
` MR. HEFAZI: And I will caution the
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`witness not to reveal any kind of attorney-client
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`privileged information or any discussions with
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`counsel.
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` THE WITNESS: So among other things, I met
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`with Nima and Jordan on -- on the phone here at
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`these offices yesterday.
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` BY MR. MUDD:
`
`
` Q. So Nima was in person with you yesterday Q. So Nima was in person with you yesterday
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` Q. So Nima was in person with you yesterday Q. So Nima was in person with you yesterday
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`and someone named Jordan was on the phone duringand someone named Jordan was on the phone during
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`and someone named Jordan was on the phone duringand someone named Jordan was on the phone during
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`your prep yesterday?your prep yesterday?
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`your prep yesterday?your prep yesterday?
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` A. For portions of the meeting, yes.
`
`
` Q. Okay. Did you meet with anyone else to Q. Okay. Did you meet with anyone else to
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` Q. Okay. Did you meet with anyone else to Q. Okay. Did you meet with anyone else to
`
`
`prepare for your deposition today?prepare for your deposition today?
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`prepare for your deposition today?prepare for your deposition today?
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` A. No.
`
`
` Q. Did you review documents to prepare for Q. Did you review documents to prepare for
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` Q. Did you review documents to prepare for Q. Did you review documents to prepare for
`
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`your deposition today?your deposition today?
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`your deposition today?your deposition today?
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` MR. HEFAZI: And --
`
`
`www.alaris.uswww.alaris.us
`
`www.alaris.uswww.alaris.us
`
`
`ALARIS LITIGATION SERVICESALARIS LITIGATION SERVICES
`
`ALARIS LITIGATION SERVICESALARIS LITIGATION SERVICES
`
`Phone: 1.800.280.3376Phone: 1.800.280.3376
`
`Phone: 1.800.280.3376Phone: 1.800.280.3376
`
`2 (Pages 5 to 8)
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`Fax: 314.644.1334Fax: 314.644.1334
`
`Fax: 314.644.1334Fax: 314.644.1334
`
`IPR2018-00067
`Unified EX1033 Page 2
`
`

`

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`MARKUS JAKOBSSON Ph.D. 10/24/2018MARKUS JAKOBSSON Ph.D. 10/24/2018
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`MARKUS JAKOBSSON Ph.D. 10/24/2018MARKUS JAKOBSSON Ph.D. 10/24/2018
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` THE WITNESS: Yes, I did.
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` BY MR. MUDD:
`
`
` Q. And did you review any documents to Q. And did you review any documents to
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` Q. And did you review any documents to Q. And did you review any documents to
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`prepare today that were not already an exhibit ofprepare today that were not already an exhibit of
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`prepare today that were not already an exhibit ofprepare today that were not already an exhibit of
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`record in this case?record in this case?
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`record in this case?record in this case?
` A. I did not.
`
`
` Q. So you didn't refer to any outside Q. So you didn't refer to any outside
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` Q. So you didn't refer to any outside Q. So you didn't refer to any outside
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`reference materials in preparing -- that were notreference materials in preparing -- that were not
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`reference materials in preparing -- that were notreference materials in preparing -- that were not
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`already of record in this case?already of record in this case?
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`already of record in this case?already of record in this case?
` A. No.
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` MR. HEFAZI: And, Markus, again, if you
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`could just pause a little bit before you answer so I
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`have an opportunity to object if necessary.
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` THE WITNESS: You bet.
`
`BY MR. MUDD:
`
`
` Q. Okay. Dr. Jakobsson, I'm going to hand Q. Okay. Dr. Jakobsson, I'm going to hand
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` Q. Okay. Dr. Jakobsson, I'm going to hand Q. Okay. Dr. Jakobsson, I'm going to hand
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`you what's already been previously marked Exhibityou what's already been previously marked Exhibit
`
`you what's already been previously marked Exhibityou what's already been previously marked Exhibit
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`2004 in this case, which states: "The declaration2004 in this case, which states: "The declaration
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`2004 in this case, which states: "The declaration2004 in this case, which states: "The declaration
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`of Markus Jakobsson in support of patent owner'sof Markus Jakobsson in support of patent owner's
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`of Markus Jakobsson in support of patent owner'sof Markus Jakobsson in support of patent owner's
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`response."response."
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`response."response."
`
` Is this your declaration you prepared in Is this your declaration you prepared in
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` Is this your declaration you prepared in Is this your declaration you prepared in
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`this case?this case?
`
`this case?this case?
` A. Yes, it is.
`
`
` Q. And this declaration contains your Q. And this declaration contains your
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` Q. And this declaration contains your Q. And this declaration contains your
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`opinions in this proceeding?opinions in this proceeding?
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`opinions in this proceeding?opinions in this proceeding?
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`Page 10
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` A. Yes, it is.
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` Q. You still stand by the opinions contained Q. You still stand by the opinions contained
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` Q. You still stand by the opinions contained Q. You still stand by the opinions contained
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`in Exhibit 2004?in Exhibit 2004?
`
`in Exhibit 2004?in Exhibit 2004?
` A. Yes, I do.
`
`
` Q. Are you aware of any errors or corrections Q. Are you aware of any errors or corrections
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` Q. Are you aware of any errors or corrections Q. Are you aware of any errors or corrections
`
`that you'd like to make in the document?that you'd like to make in the document?
`
`that you'd like to make in the document?that you'd like to make in the document?
` A. I'm aware of a small number of typos.
`
` MR. HEFAZI: And I'll lodge an objection
`
`to form.
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` Markus, again, if you can just pause a
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`little bit before you answer.
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` BY MR. MUDD:
`
`
` Q. Other than the small number of typos you Q. Other than the small number of typos you
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` Q. Other than the small number of typos you Q. Other than the small number of typos you
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`just listed, are you aware of any other errors injust listed, are you aware of any other errors in
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`just listed, are you aware of any other errors injust listed, are you aware of any other errors in
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`your declaration, Exhibit 2004, that you'd like toyour declaration, Exhibit 2004, that you'd like to
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`your declaration, Exhibit 2004, that you'd like toyour declaration, Exhibit 2004, that you'd like to
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`correct?correct?
`
`correct?correct?
` MR. HEFAZI: Same objection.
`
` THE WITNESS: No.
`
`BY MR. MUDD:
`
`
` Q. About how much time did you spend Q. About how much time did you spend
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` Q. About how much time did you spend Q. About how much time did you spend
`
`preparing your declaration, Exhibit 2004?preparing your declaration, Exhibit 2004?
`
`preparing your declaration, Exhibit 2004?preparing your declaration, Exhibit 2004?
` A. I cannot recall. I'm sorry.
`
`
` Q. Can you give me an approximate amount of Q. Can you give me an approximate amount of
`
` Q. Can you give me an approximate amount of Q. Can you give me an approximate amount of
`
`time that you spent preparing it?time that you spent preparing it?
`
`time that you spent preparing it?time that you spent preparing it?
` MR. HEFAZI: Objection. Calls for
`
`Page 12
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` A. It does. I may augment it if I learn new
`facts.
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` Q. Do you -- have you prepared any other Q. Do you -- have you prepared any other
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` Q. Do you -- have you prepared any other Q. Do you -- have you prepared any other
`
`documents containing your opinions in thisdocuments containing your opinions in this
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`documents containing your opinions in thisdocuments containing your opinions in this
`
`proceeding?proceeding?
`
`proceeding?proceeding?
` A. I presume you're not referring to
`documents that I've sent to the attorneys --
` MR. HEFAZI: Markus, I'll caution you not
`to kind of reveal any kind of attorney-client
`communications, anything you've sent to the
`attorneys or spoken with the attorneys. I don't
`think you are calling for that, Jason.
` MR. MUDD: No.
` THE WITNESS: No, those are not the
`documents you're referring to?
`BY MR. MUDD:
`
` Q. No, I'm not referring to those kinds of Q. No, I'm not referring to those kinds of
`
` Q. No, I'm not referring to those kinds of Q. No, I'm not referring to those kinds of
`
`documents.documents.
`
`documents.documents.
` A. There are no further documents I have
`prepared in the context of this particular case.
`
` Q. So this is the only declaration or expert Q. So this is the only declaration or expert
`
` Q. So this is the only declaration or expert Q. So this is the only declaration or expert
`
`report you've issued in this proceeding?report you've issued in this proceeding?
`
`report you've issued in this proceeding?report you've issued in this proceeding?
` A. So far, yes.
`
` Q. And on the very last page, page 63, that's Q. And on the very last page, page 63, that's
`
` Q. And on the very last page, page 63, that's Q. And on the very last page, page 63, that's
`
`your signature?your signature?
`
`your signature?your signature?
`
`speculation.
`
` THE WITNESS: I remember it being a fair
`
`amount of work. I don't remember the exact number
`
`of hours. If I were to guesstimate it, it's on the
`
`order of 20 hours.
`
`BY MR. MUDD:
`
`
` Q. Okay. And what's your hourly rate in this Q. Okay. And what's your hourly rate in this
`
` Q. Okay. And what's your hourly rate in this Q. Okay. And what's your hourly rate in this
`
`
`case?case?
`
`case?case?
`
` A. That is 625 for work-related and half of
`
`that for travel-related.
`
`
` Q. And -- and how much time did you say you Q. And -- and how much time did you say you
`
` Q. And -- and how much time did you say you Q. And -- and how much time did you say you
`
`
`spent preparing for the deposition yesterday?spent preparing for the deposition yesterday?
`
`spent preparing for the deposition yesterday?spent preparing for the deposition yesterday?
`
` A. How much time did I spend yesterday?
`
`
` Q. Yes. Q. Yes.
`
` Q. Yes. Q. Yes.
`
` A. I was here for roughly seven hours and
`
`then at night, I reviewed some notes for about an
`
`hour.
`
`
` Q. Other than those eight hours, Q. Other than those eight hours,
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` Q. Other than those eight hours, Q. Other than those eight hours,
`
`
`approximately, of prep, was there additional timeapproximately, of prep, was there additional time
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`approximately, of prep, was there additional timeapproximately, of prep, was there additional time
`
`
`you spent preparing?you spent preparing?
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`you spent preparing?you spent preparing?
`
` A. Yes.
`
`
` Q. And how much additional time? Q. And how much additional time?
`
` Q. And how much additional time? Q. And how much additional time?
`
` A. During the last week or so, I have
`
`reviewed the material, including my declaration,
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`maybe a total of ten hours.
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`www.alaris.uswww.alaris.us
`
`www.alaris.uswww.alaris.us
`
`
`ALARIS LITIGATION SERVICESALARIS LITIGATION SERVICES
`
`ALARIS LITIGATION SERVICESALARIS LITIGATION SERVICES
`
`Phone: 1.800.280.3376Phone: 1.800.280.3376
`
`Phone: 1.800.280.3376Phone: 1.800.280.3376
`
`3 (Pages 9 to 12)
`
`
`Fax: 314.644.1334Fax: 314.644.1334
`
`Fax: 314.644.1334Fax: 314.644.1334
`
`IPR2018-00067
`Unified EX1033 Page 3
`
`

`

`
`MARKUS JAKOBSSON Ph.D. 10/24/2018MARKUS JAKOBSSON Ph.D. 10/24/2018
`
`MARKUS JAKOBSSON Ph.D. 10/24/2018MARKUS JAKOBSSON Ph.D. 10/24/2018
`
`Page 13
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`Page 15
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`
` Q. So 10 hours plus 8 would be about 18 hours Q. So 10 hours plus 8 would be about 18 hours
`
` Q. So 10 hours plus 8 would be about 18 hours Q. So 10 hours plus 8 would be about 18 hours
`
`of preparations for today's deposition; is thatof preparations for today's deposition; is that
`
`of preparations for today's deposition; is thatof preparations for today's deposition; is that
`
`fair?fair?
`
`fair?fair?
` A. That's a fair estimate.
`
`
` Q. So if you add the 18 with the 20 hours Q. So if you add the 18 with the 20 hours
`
` Q. So if you add the 18 with the 20 hours Q. So if you add the 18 with the 20 hours
`
`preparing the declaration, it would be in thepreparing the declaration, it would be in the
`
`preparing the declaration, it would be in thepreparing the declaration, it would be in the
`
`ballpark -- 38 hours you've billed on this matter;ballpark -- 38 hours you've billed on this matter;
`
`ballpark -- 38 hours you've billed on this matter;ballpark -- 38 hours you've billed on this matter;
`
`is that correct?is that correct?
`
`is that correct?is that correct?
` MR. HEFAZI: Objection. Form. Calls for
`
`speculation.
`
` THE WITNESS: I don't remember. And there
`
`was work leading up to the declaration that I have
`
`not taken into consideration when I estimated the
`
`declaration to have taken about 20 hours.
`
`BY MR. MUDD:
`
`
` Q. What was that work leading up to the Q. What was that work leading up to the
`
` Q. What was that work leading up to the Q. What was that work leading up to the
`
`declaration that you did not account for?declaration that you did not account for?
`
`declaration that you did not account for?declaration that you did not account for?
` A. For example, to read the '813 patent when
`
`I started working on the case.
`
`
` Q. And when did you start working on the Q. And when did you start working on the
`
` Q. And when did you start working on the Q. And when did you start working on the
`
`case?case?
`
`case?case?
` A. I don't remember the exact date. It was
`
`roughly a year and a half ago, but I don't remember
`
`more precise than that.
`
`
` Q. And you've been retained by Universal Q. And you've been retained by Universal
`
` Q. And you've been retained by Universal Q. And you've been retained by Universal
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` MR. HEFAZI: Objection. Form.
`
` THE WITNESS: Yes, I have.
`
`BY MR. MUDD:
`
`
` Q. When did you review that documentation? Q. When did you review that documentation?
`
` Q. When did you review that documentation? Q. When did you review that documentation?
` A. I don't remember exactly. Rather
`
`recently.
`
`
` Q. About how recently? Q. About how recently?
`
` Q. About how recently? Q. About how recently?
` A. Within the last month.
`
`
` Q. So you hadn't reviewed any confidential Q. So you hadn't reviewed any confidential
`
` Q. So you hadn't reviewed any confidential Q. So you hadn't reviewed any confidential
`
`internal Apple documentation by the time youinternal Apple documentation by the time you
`
`internal Apple documentation by the time youinternal Apple documentation by the time you
`
`executed this declaration, Exhibit 2004, onexecuted this declaration, Exhibit 2004, on
`
`executed this declaration, Exhibit 2004, onexecuted this declaration, Exhibit 2004, on
`
`August 30th; is that right?August 30th; is that right?
`
`August 30th; is that right?August 30th; is that right?
` A. That is right.
`
`
` Q. Were you familiar with Universal Secure Q. Were you familiar with Universal Secure
`
` Q. Were you familiar with Universal Secure Q. Were you familiar with Universal Secure
`
`Registry before being retained by them?Registry before being retained by them?
`
`Registry before being retained by them?Registry before being retained by them?
` A. I was not.
`
`
` Q. Have you previously worked as an expert Q. Have you previously worked as an expert
`
` Q. Have you previously worked as an expert Q. Have you previously worked as an expert
`
`with the law firm Quinn Emanuel or any of thewith the law firm Quinn Emanuel or any of the
`
`with the law firm Quinn Emanuel or any of thewith the law firm Quinn Emanuel or any of the
`
`lawyers at Quinn that you've worked with on thislawyers at Quinn that you've worked with on this
`
`lawyers at Quinn that you've worked with on thislawyers at Quinn that you've worked with on this
`
`proceeding?proceeding?
`
`proceeding?proceeding?
` A. Yes.
`
`
` Q. Let's start with -- the lawyers you're Q. Let's start with -- the lawyers you're
`
` Q. Let's start with -- the lawyers you're Q. Let's start with -- the lawyers you're
`
`working with on this proceeding, have you workedworking with on this proceeding, have you worked
`
`working with on this proceeding, have you workedworking with on this proceeding, have you worked
`
`with them as an expert on past cases?with them as an expert on past cases?
`
`with them as an expert on past cases?with them as an expert on past cases?
` A. Yes.
`
`
`Secure Registry and their lawyers at -- the lawyersSecure Registry and their lawyers at -- the lawyers
`
`Secure Registry and their lawyers at -- the lawyersSecure Registry and their lawyers at -- the lawyers
`
`
`at Quinn Emanuel; is that correct?at Quinn Emanuel; is that correct?
`
`at Quinn Emanuel; is that correct?at Quinn Emanuel; is that correct?
`
`1
`
`2
`
`
` Q. Specifically which lawyers? Q. Specifically which lawyers?
`
` Q. Specifically which lawyers? Q. Specifically which lawyers?
` A. I have worked with Jordan in the past.
`
`Page 14
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` A. That is correct.
`
`
` Q. And when you refer to one and a half years Q. And when you refer to one and a half years
`
` Q. And when you refer to one and a half years Q. And when you refer to one and a half years
`
`
`ago, are you referring to being retained inago, are you referring to being retained in
`
`ago, are you referring to being retained inago, are you referring to being retained in
`
`
`connection with litigation that Universal Secureconnection with litigation that Universal Secure
`
`connection with litigation that Universal Secureconnection with litigation that Universal Secure
`
`
`Registry filed against Apple?Registry filed against Apple?
`
`Registry filed against Apple?Registry filed against Apple?
`
` A. Yes.
`
`
` Q. So -- Q. So --
`
` Q. So -- Q. So --
`
` MR. HEFAZI: And I'll just -- late
`
`objection. Object to form.
`
`BY MR. MUDD:
`
`
` Q. So you've been retained by Universal Q. So you've been retained by Universal
`
` Q. So you've been retained by Universal Q. So you've been retained by Universal
`
`
`Secure Registry in connection with the AppleSecure Registry in connection with the Apple
`
`Secure Registry in connection with the AppleSecure Registry in connection with the Apple
`
`
`litigation as well as this IPR proceeding; is thatlitigation as well as this IPR proceeding; is that
`
`litigation as well as this IPR proceeding; is thatlitigation as well as this IPR proceeding; is that
`
`
`right?right?
`
`right?right?
`
` MR. HEFAZI: Same --
`
` THE WITNESS: That is --
`
` MR. HEFAZI: Same objection.
`
` THE WITNESS: That is correct.
`
`BY MR. MUDD:
`
`
` Q. Have you had an opportunity to review Q. Have you had an opportunity to review
`
` Q. Have you had an opportunity to review Q. Have you had an opportunity to review
`
`
`confidential internal Apple documentation yet inconfidential internal Apple documentation yet in
`
`confidential internal Apple documentation yet inconfidential internal Apple documentation yet in
`
`
`connection with the -- the Universal Secure Registryconnection with the