UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
`
`INTEL CORPORATION, )
` )
` )
` Petitioner, )
`vs. ) IPR2017-01405
` ) IPR2017-01409
`ALACRITECH, ) IPR2017-01410
` )
` Patent Owner. )
`___________________________)
`
` VIDEO-RECORDED DEPOSITION OF BILL LIN, Ph.D.
` La Jolla, California
` Friday, February 9, 2018
`
`Reported by:
`Tricia Rosate, RDR, RMR, CRR, CCRR
`CSR No. 10891
`Job No. 137188
`
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`INTEL EX. 1456.001
`
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Page 1
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`INTEL CORPORATION, )
` )
` )
` Petitioner, )
`vs. ) IPR2017-01405
` ) IPR2017-01409
`ALACRITECH, ) IPR2017-01410
` )
` Patent Owner. )
`___________________________)
`
` VIDEO-RECORDED DEPOSITION OF BILL LIN, Ph.D.
` La Jolla, California
` Friday, February 9, 2018
`
`Reported by:
`Tricia Rosate, RDR, RMR, CRR, CCRR
`CSR No. 10891
`Job No. 137188
`
`TSG Reporting - Worldwide 877-702-9580
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`INTEL EX. 1456.001
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`Page 2
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` Friday, February 9, 2018
` 9:30 a.m.
`
` VIDEO-RECORDED DEPOSITION OF BILL LIN, Ph.D.,
`taken at Residence Inn, 8901 Gilman Drive, La Jolla,
`California, commencing at 9:30 a.m. and concluding at
`1:37 p.m., Friday, February 9, 2018, before
`Tricia Rosate, RDR, RMR, CRR, CCRR, CSR 10891, a
`Certified Shorthand Reporter.
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`INTEL EX. 1456.002
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`A P P E A R A N C E S:
`For the Petitioner, INTEL CORPORATION:
` WEIL, GOTSHAL & MANGES
` 2001 M Street, NW
` Washington, DC 20036
` BY: SUTTON ANSLEY, ESQ.
`
`
` -and-
` WEIL, GOTSHAL & MANGES
` 201 Redwood Shores Parkway
` Redwood Shores, California 94065
` BY: AMANDA BRANCH, ESQ.
`
`
`
`For the Patent Owner, ALACRITECH:
` QUINN EMANUEL URQUHART & SULLIVAN
` 50 California Street
` San Francisco, California 94111
` BY: BRIAN MACK, ESQ.
`
`
`
`
`
`Also Present:
` JOHN DUSENBERY, The Videographer
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`INTEL EX. 1456.003
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`
`
` I N D E X
`WITNESS: Bill Lin, Ph.D.
`EXAMINATION PAGE
`By Mr. Mack .................................. 5
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`Page 4
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` E X H I B I T S
`EXHIBIT DESCRIPTION PAGE
`Exhibit 1015 ........................... 63
`Exhibit 205-1001 ........................... 38
`Exhibit 880-1001 ........................... 125
`Exhibit 880-01-1003 ........................... 123
`Exhibit 880-02-1003 ........................... 123
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`INTEL EX. 1456.004
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` LA JOLLA, CALIFORNIA; FRIDAY, FEBRUARY 9, 2018
` 9:30 A.M. - 1:37 P.M.
` - - - -
` THE VIDEOGRAPHER: Good morning. This is the
`start of Media No. 1 in the videotaped deposition of
`Dr. Bill Lin testifying in the matter of Alac- --
` How do you pronounce that name?
` MR. MACK: Alacritech.
` THE VIDEOGRAPHER: -- Alacritech, Inc., vs.
`CenturyLink Communications, LLC, et al., and Wistron
`Corporation, et al., and Dell Inc. It's in the
`United States District Court, Eastern District of
`Texas; Case Nos. 2:16-cv-693RWS, 2:16-cv-692-JRG,
`2:16-cv-695-JRG.
` This deposition is taking place at the
`Residence Inn, located at 8901 Gilman Drive, La Jolla,
`California 92037.
` Today's date is February 9, 2018. The time is
`approximately 9:31 a.m.
` My name is John Dusenbery. I'm from
`TSG Reporting, Inc., and I am the legal video
`specialist.
` The court reporter is Tricia Rosate in
`association with TSG Reporting.
` Would counsel please identify themselves and
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`INTEL EX. 1456.005
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`state on the record who you're representing.
` MR. MACK: Brian Mack of Quinn Emanuel,
`representing the patent owner, Alacritech, Inc.
` MR. ANSLEY: Sutton Ansley of Weil Gotshal &
`Manges, here on behalf of the witness and the
`petitioner, Intel.
` With me is my colleague from the same law
`firm, Amanda Branch.
` THE VIDEOGRAPHER: Would the court reporter
`please administer the oath.
` BILL LIN, Ph.D.,
` having been first duly sworn, testified as follows:
` EXAMINATION
`BY MR. MACK:
` Q Good morning.
` Could you please state your name and address
`for the record.
` A My -- my name is Bill. Last name's Lin,
`L-i-n.
` The address of my home?
` Q Yes.
` A 1005 Valleyside Lane, Encinitas, California
`92024.
` Q And you've been deposed before, Dr. Lin;
`correct?
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`INTEL EX. 1456.006
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` A Correct.
` Q Okay. So we'll just run through the
`ground rules briefly since you've been deposed before.
` You understand that you are under oath to tell
`the truth today; right?
` A I do.
` Q And it's the same oath that you would be under
`if you were testifying live in a court of law.
` Do you understand that?
` A Yes.
` Q And you understand that there's a
`court reporter and videographer recording this
`deposition; correct?
` A Yes.
` Q So let's try to speak slowly and wait for me
`to finish answer- -- asking my question before you
`begin answering the question -- answering a question.
` If you answer my question, I'll assume that
`you understood the question. Is that fair?
` A Yes.
` Q And please answer my questions despite any
`objections by your counsel unless your counsel
`specifically instructs you not to answer the question.
`Is that fair?
` A Yes.
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`INTEL EX. 1456.007
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` Q Is there anything that could interfere with
`your ability to testify truthfully today?
` A No. Not that I'm aware of.
` Q Okay. You're not on any medications that
`could impede your ability to tell the truth?
` A I am not.
` Q We'll try to take breaks approximately every
`hour, but if you need a more-frequent break, just let
`me know.
` Dr. Lin, you're being compensated for your
`work in this case; correct?
` A I am.
` Q And who is compensating you?
` A I'm working with Weil Gotshal on behalf of
`Intel.
` Q And what is your hourly rate?
` A $600 an hour.
` Q And is that your normal expert consulting
`rate?
` A That is correct.
` Q Do you have a -- a written consulting
`agreement with the law firm Weil Gotshal?
` A I do have an engagement agreement.
` Q Is Weil Gotshal directly paying your invoices,
`or is Intel paying your invoices?
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`INTEL EX. 1456.008
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` A Actually, I do not know.
` Q Do you have any agreements with Cavium?
` A Yes.
` Q And what agreement do you have with Cavium?
` A It is also an engagement agreement.
` Q Okay. And is Cavium also compensating you for
`your time working on this matter?
` A I'm working with a law firm on behalf of
`Cavium. I'm not exactly sure who's -- who's
`compensating me.
` Q And which law firm is that?
` A Duane -- Duane Morris.
` Q And is Cavium also compensating you at your
`standard $600-an-hour rate?
` A They are.
` Q And how about Wistron? Do you have any formal
`agreements with Wistron?
` A I do not.
` Q CenturyLink? Do you have any formal agreement
`with CenturyLink?
` A I do not.
` Q And are you being compensated for your time
`appearing here for this deposition today?
` A I am.
` Q Do you have any other financial interest in
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`INTEL EX. 1456.009
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`Page 10
`the outcome of this case, other than the compensation
`that you're receiving for your consulting?
` MR. ANSLEY: Objection. Form.
` THE WITNESS: I do not.
`BY MR. MACK:
` Q Do you own any stock in Intel Corporation?
` A I do not.
` Q How about Dell, Cavium, or CenturyLink? Do
`you own any stock in those corporations?
` A I do not.
` Q And in connection with this matter, the
`Alacritech matter, how many declarations have you
`submitted?
` A Three. One --
` Actually, three relevant to this IPR
`proceeding here.
` Q And on behalf of which entity did you submit
`those declarations?
` A On behalf of -- well, actually, let me take it
`back.
` I submitted a total of -- it should be -- I
`submitted one declaration for '205 patent and two
`declarations for '880 with Weil Gotshal on behalf of
`Intel, and I submitted the same three declarations on
`behalf of Cavium with Duane Morris, and also the same
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`INTEL EX. 1456.010
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`Page 11
`declarations on behalf of Dell with Alston Bird.
` Q But you don't have any formal agreement with
`Dell or Alston Bird, do you?
` A I have an engagement with them as well.
` Q Okay. And that's also at your standard $600
`an hour?
` A That is correct.
` Q And the various petitions -- the various
`declarations that you submitted on behalf of Intel,
`Cavium, and Dell, you said "the same" petitions. Are
`they substantively the same across --
` A They're --
` Q -- the three parties?
` A Yes.
` Q Were there any changes that you're aware of
`between the declarations across the three parties?
` A Simply some typos.
` Q And who corrected those typos?
` A I did.
` Q Do you recall when you were first approached
`and asked to work on this matter?
` A I was approached in probably September of
`2016 -- or I believe around September.
` Q Okay. And who approached you?
` A I was approached by Intel and Weil Gotshal.
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`INTEL EX. 1456.011
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` Q Do you recall which attorney at Weil Gotshal?
` A No, I don't remember.
` Q Had you worked for Intel or the law firm Weil
`Gotshal prior to this engagement?
` A Not with Weil Gotshal. With Intel, I've
`worked on other cases.
` Q Have you worked on other IPR matters on behalf
`of Intel before?
` A I -- I believe the answer's yes. I don't
`recall exactly right now.
` Q And the other IPR matters that you worked for
`Intel, were they on the side of the patent owner or the
`party challenging the patent?
` A The party challenging the patent.
` Q Have you ever worked on an IPR matter on
`behalf of the patent owner?
` A I -- I don't recall. I don't think so, but
`I'm not 100 percent sure.
` Q And in total, how many IPR -- how many
`different IPR matters have you worked on in an expert
`consulting capacity?
` A You mean the number of different patents or
`the number of different law firms or cases?
` Q Why don't we start with the number of
`different patents. How many -- how many different
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`INTEL EX. 1456.012
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`patents have you worked on in connection with IPR
`matters?
` A I honestly don't remember right now off the
`top of my head, because a lot of cases involve several
`patents, and I just don't remember right now how many
`in different cases.
` Q Okay. Do you think it could be more than ten?
` A Could be.
` Q And in each of those cases, you were
`representing --
` A More than ten patents but not more than ten
`cases.
` Q Okay. And in each -- and in each of those
`ten -- for each of those ten patents, did you submit an
`expert declaration?
` A No. Not all of them.
` Q How many expert declarations have you
`submitted in any IPR matter?
` A Again, I don't remember right now, so --
` More than five. I just don't remember
`exactly.
` Q And in each of those expert declarations, you
`were representing the challenger of the patent?
` A "Challenger" means what?
` Q The petitioner.
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`INTEL EX. 1456.013
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` A Yes. I believe so.
` Q And in any of those expert declarations, did
`you render an opinion that any claim of any one of
`those patents was valid?
` A Can you repeat the question?
` Q Sure. In any of your expert IPR declarations,
`have you ever rendered an opinion that any claim of a
`challenged patent was valid?
` A I think in all of the IPR cases that I've
`worked on with the patents, I've only offered opinion
`for some of the claims in these patents. I've never
`offered opinions on all of the claims in the patents.
` Q Okay. But for all the claims that you've
`offered opinions, have you ever offered an opinion that
`one of those claims was valid?
` A Like I said, I think in all of the patents
`that I've worked on, I've offered opinions on which
`claims that I thought were invalid.
` Q But sitting here today, you don't recall ever
`submitting an opinion that any claim of a challenged
`patent was valid; correct?
` A As I said, I've offered only opinions about
`why they're invalid only for some of the claims within
`the patent. For the other claims that I didn't offer
`an opinion about not being valid, I -- I cannot tell
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`INTEL EX. 1456.014
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`Page 15
`you exactly which one, but I've looked at them and I
`saw some of them to be valid.
` Q Okay. And have you ever worked on a
`district court patent litigation before?
` A I believe so, yes.
` Q And how many different district court patent
`litigations have you worked on?
` A I don't remember. One went to trial, and the
`other cases, I don't remember exactly how many.
` Q Okay. In the case that went to trial, do you
`remember the parties of that case?
` A Yes. I was representing on behalf of
`Ruckus Wireless. Ruckus, R-u-c-k-u-s, I believe. And
`the other -- the opposing party was Netgear.
` Q And was Ruckus Wireless the plaintiff or
`defendant?
` A Defendant.
` Q So, again, that would be the party accused of
`infringement; correct?
` A Yes.
` Q And in that matter, did you submit opinions on
`both noninfringement and invalidity?
` A Only on noninfringement. And, again, only for
`some of the claims in the patent.
` Q And do you recall what -- what court or venue
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`INTEL EX. 1456.015
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`the Ruckus Wireless case was in?
` A Delaware.
` Q And what year was that?
` A I think -- I'm not 100 percent sure. I think
`around 2013.
` Q Have your opinions or expert opinions ever
`been subject to a Daubert motion? Do you know what a
`Daubert motion is?
` A I don't believe it has because I'm not
`aware what it -- I'm not sure what it is, so I don't
`think so.
` Q Okay. Have your expert opinions ever been
`stricken by any court that you are aware of?
` A Not that I'm aware of.
` Q And, Dr. Lin, what did you do to prepare for
`today's deposition?
` A I reviewed my declarations. I reviewed the
`prior art that I rely upon for my opinions. I reviewed
`the board decisions. I've reviewed the patent
`response -- owner response, and I've reviewed the file
`history.
` Q And in addition to the file history, you
`included reviewing the specification of the patents
`that we're going to be talking about today; correct?
` A Yes. Thank you.
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`INTEL EX. 1456.016
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` Q And when did you start preparing for today's
`deposition?
` A Maybe, already, a week or two ago.
` Q And how much time did you spend preparing for
`today's deposition?
` A I don't know exactly.
` Q In total on this matter, approximately how
`many hours have you billed?
` A Maybe -- maybe 300 hours or so.
` Q And that's across the two '880 petitions plus
`the '205 petition?
` A Yes.
` Q And is the 300 hours -- is that across all
`three parties, Dell, Cavium, and Intel?
` A No. The 300-and-some hours is on behalf of
`Intel.
` Q Okay. And how many hours have you billed to
`Cavium in connection with this matter?
` A The declarations I submitted on behalf of
`Cavium were substantively the same as the ones I
`submitted for Intel, and I mainly edited for typos. So
`I spent about an hour and a half to two hours.
` Q Okay. And is -- will that be the same for
`Dell, an hour and a half to two hours?
` A Correct.
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`INTEL EX. 1456.017
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` Q Okay. And you said -- you said they were
`substantively the same. Sitting here today, are you
`aware of any substantive -- substantive differences
`between the declarations you submitted for Intel and
`the ones that you submitted for Dell and Cavium?
` A Apart from --
` MR. ANSLEY: Objection. Form.
` Go ahead.
` THE WITNESS: Apart from typos, they -- they
`should be the same. They are the same.
`BY MR. MACK:
` Q And in connection with your preparation for
`today's deposition, did you meet with counsel?
` A I did.
` Q And when did you meet with counsel?
` A I met with counsel on Wednesday and a half day
`yesterday.
` Q And with whom did you meet?
` A I met with Sutton Ansley and Amanda Branch.
` Q And approximately how long did you meet on the
`first day?
` A Maybe eight hours with some lunch break in
`between.
` Q And approximately how long did you meet on day
`number two?
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`INTEL EX. 1456.018
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` A Maybe four or five hours.
` Q In connection with your preparation for
`today's deposition, did you speak with any Intel
`engineers?
` A No.
` Q How about any former Intel employees?
` A No.
` Q Did you speak with any Cavium or Dell
`employees or former employees?
` A No.
` Q Did you speak with any -- any nonlawyers in
`connection with your preparation for today's
`deposition?
` A No.
` Q And the declarations that you submitted, the
`three declarations that we're going to be talking about
`today, did you perform all of your own analysis in
`those declarations, or did you -- did you utilize any
`colleagues or assistants?
` MR. ANSLEY: Objection. Form.
` THE WITNESS: They're -- they're my analysis.
` MR. MACK: I'll mark --
` Your CV has been already marked as
`Exhibit 1004.
` Sorry. I only have one copy.
`
`TSG Reporting - Worldwide 877-702-9580
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`INTEL EX. 1456.019
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` MR. ANSLEY: Thanks. That's okay.
` (Exhibit 1004 was referenced.)
`BY MR. MACK:
` Q Do you recognize Exhibit 1004?
` A I do.
` Q All right. And is this a copy of your CV?
` A It is.
` Q And is this -- is this an up-to-date copy of
`your CV?
` A Yes.
` Q And does -- is everything on the CV accurate
`as of today?
` A Yes.
` Q Let's start with the -- let's go through some
`of the -- some of the items on your CV briefly.
` Your education, at the top of page 1 of
`Exhibit 1004, you hold a PhD in electrical engineering
`and computer science; correct?
` A Yes.
` Q And that's from University of California
`Berkeley; right?
` A Yes.
` Q And what was your PhD thesis?
` A My PhD thesis was on tools for doing chip
`design.
`
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` Q So fair to say your PhD thesis didn't relate
`to any network protocol offloading; correct?
` MR. ANSLEY: Objection to form.
` THE WITNESS: My PhD was on tools for -- for
`chip designs for which networking chips are chip
`designs.
`BY MR. MACK:
` Q Okay. But my question was a little more
`specific.
` Your -- your PhD thesis didn't relate to
`protocol offloading, did it? Offloading and networking
`protocol from a -- from a host protocol stack to a
`network interface device?
` MR. ANSLEY: Objection. Form.
` THE WITNESS: Can you repeat the question?
`BY MR. MACK:
` Q Sure. Did your --
` Your PhD thesis didn't relate to any network
`protocol offloading, did it?
` A My PhD thesis, the work is applicable to -- to
`designing of chips that does protocol offloading.
` Q Okay. Does your PhD thesis reference protocol
`offloading?
` A I don't believe so.
` Q And does your PhD thesis reference,
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`specifically, TCP/IP protocol offloading?
` A I don't recall.
` Q And your PhD in electrical engineering and
`computer science, would you say -- was it more on the
`hardware or software side?
` A On both. I was in the -- at Berkeley, the
`department of electrical engineering and computer
`science is the same department, and my -- my research
`spans both areas.
` Q So, today, do you write or understand any
`programming languages?
` A Yes.
` Q And which -- which languages do you understand
`today?
` A Many. Just some examples: On the software
`side, I'm -- I'm capable of writing and understanding
`programs in C, C++, Java, Python, PHP, JavaScript, at
`least those.
` And on the hardware side, Verilog,
`SystemVerilog, VHDL.
` Q And did you rely on any of your understanding
`of these programming languages in rendering the
`opinions contained in your expert declarations?
` MR. ANSLEY: Objection. Form.
` THE WITNESS: I don't understand the
`
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`question.
`BY MR. MACK:
` Q Did you review any -- any source code in
`connection with rendering any of your opinions?
` A I did not.
` Q You also received a master's degree from
`Berkeley in 1988; is that right?
` A Yes.
` Q And was your -- was -- did you prepare a
`master's thesis?
` A I did --
` Did I? I -- I did prepare a pro- -- a project
`report for my master's project. I did.
` Q Okay. And what was your project report for
`your -- for your master's degree?
` A It was also on tools for doing chip designs.
` Q And was it related to the work that you
`performed in connection with your PhD?
` A Yes.
` Q And your master's thesis or project report,
`did that refer to any protocol offloading?
` A I don't recall, but in the course of my
`graduate studies in both my master's and PhD, I've
`taken many courses, including courses in computer
`networks and computer architecture.
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` Q Okay. And did any of those courses have a
`specific subject of protocol offloading?
` MR. ANSLEY: Objection to form.
` THE WITNESS: Computer networking and
`operating system courses would -- did cover the
`standard protocol stacks using networking.
`BY MR. MACK:
` Q My question was a little different.
` Did those -- any of those courses cover
`protocol offloading?
` A I don't recall.
` Q And, Dr. Lin, you've been a professor, either
`adjunct or full professor, since 1997; is that right?
` A Yes. But before then, I worked at a
`laboratory called IMEC in -- in Belgium for nearly five
`years.
` Q Right. Okay. I see that.
` Your -- your experience as a professor since
`1997, has it always been in the electrical and computer
`engineering department?
` A When I joined UCSD, I became a professor in
`the electrical and computer engineering department, and
`later on, I also had an -- I also got an appointment in
`the computer science and engineering department.
` Q And have you ever taught any classes where
`
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`there was a specific topic relating to protocol
`offloading?
` MR. ANSLEY: Objection. Form.
` THE WITNESS: So the -- I should qualify.
`When I was in Belgium, working there, my research
`transitioned from design tools for chip design to
`actually doing chip design. And so, during my nearly
`five years there, I worked on several projects
`involving networking and -- and -- network processing
`and protocol offloads.
`BY MR. MACK:
` Q Okay. But my question related to teaching
`classes, so I don't -- I don't understand that answer.
` A You're getting there.
` So when I joined UCSD, I continued my research
`on computer networking, which I started while I was in
`Belgium, and I did teach courses -- graduate courses
`on -- on specialized processors, and one of the courses
`I taught included lectures on protocol offload.
` Q And do you have copies of any of these
`lectures today?
` A No.
` Q And the protocol offload that were part of
`these courses, what -- what protocol -- what protocol
`were you describing being offloaded?
`
`TSG Reporting - Worldwide 877-702-9580
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`INTEL EX. 1456.025
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` A We -- I had some lectures, but I don't have
`copies of the slides with me. They were on TCP
`offloads.
` Q And have you -- at UCSD, have you supervised
`any students who were working on protocol offloading?
` A I supervised several PhD students working on
`packet processing at network interfaces.
` Q But my question was a little bit different.
` My question was: Have you supervised any
`students working specifically on protocol offloading?
` So maybe we can take a step back.
` How would you define protocol offloading?
` A Taking a protocol and offloading.
` Q Okay. What does it mean to offload a
`protocol?
` A Can you be more specific?
` Q Sure. So I've been asking you some questions
`about protocol offloading, but do you have a general
`sense of what it means to offload a networking
`protocol?
` A Yes, I do.
` Q Okay. And what is it -- what is your
`understanding of what it means to offload a networking
`protocol?
` A In the context of my declaration, I talk about
`
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`Page 27
`offloading protocol from the host to -- to the network
`interface or to hardware.
` Q Okay. And why might someone want to offload a
`networking protocol from the host to the network
`interface or to hardware?
` MR. ANSLEY: Objection. Form.
` THE WITNESS: So I'm here today to off- -- to
`answer questions about my declaration, so is there
`something specifically about my declaration you want to
`ask?
`BY MR. MACK:
` Q No. I'm just trying to understand. I've been
`asking you some questions about protocol offloading,
`and you seem to respond with general networking or
`packet processing. So I'm just trying to understand
`your --
` Is there a difference in your mind between
`packet processing and protocol offloading --
` MR. ANSLEY: Objection --
`BY MR. MACK:
` Q -- or are they synonymous to you?
` MR. ANSLEY: Objection. Form.
` THE WITNESS: I -- in my declaration, I -- I
`give examples of protocol offloading in my "Background"
`section.
`
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`BY MR. MACK:
` Q Okay. So what are some examples of protocol
`offloading?
` A Some examples would be implementing, in parts
`or all, of TCP/IP protocol stack onto hardware.
` Q And are you familiar with a technology known
`as TCP offload engine, or TOE, T-O-E?
` MR. ANSLEY: Objection. Form. Scope.
` THE WITNESS: Yes.
`BY MR. MACK:
` Q And what is -- what is TOE, T-O-E?
` A I don't think there's a specific definition.
`I offer examples of protocol offloading in my
`"Background" section.
` Q And the "Background" section that you're
`referencing, did you write that section, the entirety
`of that section?
` MR. ANSLEY: Objection. Form.
` THE WITNESS: I -- I -- I wrote the entirety
`of that section. I -- as I stated in my declarations,
`I -- I read the background section of Dr. Horst. And
`for the parts that I -- I incorporated in my
`declaration, I've read through the references and --
`thoroughly, and I -- I agree with the characterization.
`And so I didn't feel the need to
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`reinvent those parts.
` But there were other parts in my declarations
`that I added that were not part of the "Background"
`section of Dr. Horst.
`BY MR. MACK:
` Q Okay. The parts of Dr. Horst's "Background"
`section that you incorporated into your declaration,
`did you agree with the entirety of those -- those
`opinions?
` A Can I get a copy of my declaration?
` Q Sure. Let's start with the --
` So since all of the declarations are
`Exhibit 1003, we marked them -- this is Exhibit -- what
`has been premarked as Exhibit 205-1003.
` MR. ANSLEY: Thanks.
` (Exhibit 205-1003 was referenced.)
`BY MR. MACK:
` Q So this -- do you recognize this document?
` A Yes, I do.
` Q And what is Exhibit 205-1003?
` A This -- this is my declaration for the '205
`patent.
` Q And you wrote -- you prepared this
`declaration; correct?
` A Yes.
`
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` Q And did anyone assist you in writing this
`declaration?
` A Part of the -- the word processing was done
`with the assistance of the attorneys.
` Q And when you say "part of the word
`processing," what -- what part of the word processing
`are you referring to?
` A I don't remember specifically, but the -- some
`of the word -- some of the sentences were entered by
`the attorneys, but I reviewed all of them and edited
`them, and they represent my opinions.
` Q Okay. And the opinions in this declaration,
`Exhibit 205-1003, are these opinions consistent with
`the opinions you intend to offer at your deposition
`today?
` A Yes.
` Q And approximately how many hours did you spend
`preparing this particular declaration,
`Exhibit 205-1003?
` A I don't remember.
` Q Could it have been more than 100 hours?
` A I spent the -- the -- I spent the dura
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