UNITED STATES PATENT AND TRADEMARK OFFICE
` _______________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _______________
`
`Page 1
`
` APPLE INC.
` Petitioner
` v.
` QUALCOMM INCORPORATED
` Patent Owner
` _______________
` Case No. IPR2018-01279
` Patent 7,844,037
` _______________
`
` DEPOSITION OF DR. NARAYAN B. MANDAYAM
` Washington, DC
` May 29, 2019
`
`Reported by: John L. Harmonson, RPR
`Job No. 161231
`
`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm Exhibit 2006
`Apple v. Qualcomm, IPR2018-01279
`Page 1
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` _______________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _______________
`
`Page 1
`
` APPLE INC.
` Petitioner
` v.
` QUALCOMM INCORPORATED
` Patent Owner
` _______________
` Case No. IPR2018-01279
` Patent 7,844,037
` _______________
`
` DEPOSITION OF DR. NARAYAN B. MANDAYAM
` Washington, DC
` May 29, 2019
`
`Reported by: John L. Harmonson, RPR
`Job No. 161231
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`TSG Reporting - Worldwide 877-702-9580
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`Apple v. Qualcomm, IPR2018-01279
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` May 29, 2019
` 9:03 a.m.
`
` Deposition of DR. NARAYAN B. MANDAYAM, held
`at the offices of Fish & Richardson PC, 1000
`Maine Avenue, SW, Washington, DC, pursuant to
`Notice, before John L. Harmonson, a Registered
`Professional Reporter and Notary Public of the
`District of Columbia, who officiated in
`administering the oath to the witness.
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`Apple v. Qualcomm, IPR2018-01279
`Page 2
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`
` A P P E A R A N C E S
`
`Page 3
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`On Behalf of the Petitioner:
` FISH & RICHARDSON
` 1180 Peachtree Street, NE
` Atlanta, GA 30309
` BY: THAD KODISH, ESQ.
` SARA FISH, ESQ.
`
` FISH & RICHARDSON
` 1717 Main Street
` Dallas, TX 75201
` BY: DAN SMITH, ESQ.
` (via telephone)
`
`On Behalf of Patent Owner:
` BAKER BOTTS
` 98 San Jacinto Boulevard
` Austin, TX 78701
` BY: PUNEET KOHLI, Ph.D.
` BRIAN OAKS, ESQ.
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`Apple v. Qualcomm, IPR2018-01279
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`ALSO PRESENT:
` MIKE TAVEIRA, Qualcomm (via telephone)
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` E X A M I N A T I O N I N D E X
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`WITNESS PAGE
`NARAYAN B. MANDAYAM, Ph.D.
` Examination by Mr. Kohli 7
` * * *
`
` E X H I B I T I N D E X
` PAGE
`Exhibit 1001 . . . . . . . . . . . . . . . 26
` U.S. Patent 7,844,037 (Champlin)
`Exhibit 1003 . . . . . . . . . . . . . . . 15
` Declaration of Dr. Narayan Mandayam
`Exhibit 1004 . . . . . . . . . . . . . . . 66
` U.S. Patent 6,301,338 (Mäkelä)
`Exhibit 1006 . . . . . . . . . . . . . . . 83
` U.S. Patent Application 2003/0104827
` (Moran)
`Exhibit 1007 . . . . . . . . . . . . . . . 84
` U.S. Patent Application 2004/0203956
` (Tsampalis)
`Exhibit 2004 . . . . . . . . . . . . . . . 134
` Excerpt from The Facts on File Dictionary
` of Computer Science
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`Apple v. Qualcomm, IPR2018-01279
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` EXHIBIT INDEX (Cont.'d)
` PAGE
`Exhibit 2005 . . . . . . . . . . . . . . . 135
` Excerpt from Microsoft Computer
` Dictionary, Fourth Edition
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` N. MANDAYAM
`-------------------------------------------------
` P R O C E E D I N G S
` 9:03 a.m.
`-------------------------------------------------
`Whereupon,
` NARAYAN B. MANDAYAM, Ph.D.,
`after having been first duly sworn or affirmed,
`was examined and did testify under oath as
`follows:
` EXAMINATION
`BY MR. KOHLI:
` Q. Puneet Kohli from Baker Botts for the
`patent owner Qualcomm. With me is Brian Oaks,
`also from Baker Botts.
` Could you state your name for the
`record?
` A. Sure. My name is Narayan Mandayam.
` Q. Have you ever been deposed before?
` A. Yes.
` Q. How many times?
` A. I want to say maybe seven or eight.
` Q. What kinds of technology have you
`testified about?
` A. So my expertise is in broadly the area
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` N. MANDAYAM
`of wireless networking, all aspects of it. So
`I've testified on, you know, applications, core
`technologies, systems, methods broadly related to
`various aspects of wireless networking.
` Q. Okay. Do you understand you've sworn
`to testify truthfully to the best of your ability
`today?
` A. Yes.
` Q. If you don't understand a question,
`please let me know and I'll try to clarify it.
`Otherwise I'll assume you've understood the
`question. Is that fair?
` A. Yes, fair enough.
` Q. Because there is a court reporter
`taking down what we say or what's being said,
`it's important that only one person speaks at a
`time, and it's also very important for you to
`respond verbally rather than uh-huhs and nods.
`Is that clear?
` A. Yes, it is clear.
` Q. In the same spirit, please let me
`finish my question before you answer it, and I'll
`do the same; in other words, I'll let you finish
`your answers before asking additional questions.
`
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` N. MANDAYAM
`Is that okay?
` A. Yes.
` Q. From time to time your attorney may
`object, but you should still answer my questions
`unless specifically instructed not to answer. Do
`you understand that?
` A. Yes.
` Q. Is there any reason why you would not
`be able to answer my questions fully and
`truthfully today?
` A. Not that I can think of.
` Q. So you mentioned that you've been
`deposed about seven or eight times before. Have
`you ever testified in a court?
` A. No, I have not. No, these are all in
`depositions in settings like this.
` Q. Have you ever consulted on any other
`cases in which Apple was a party?
` A. Yes. Again, my memory is sketchy on
`this. Yes. It was many years ago. I was a -- I
`started off essentially as one of the main
`experts, and I think there was a lot of
`consolidation of patents and various litigations
`that were going on.
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` N. MANDAYAM
` So eventually I became essentially a
`consulting witness. So I didn't do a deposition
`in that case, or whatever the set of litigations
`going on was. That is my recollection in terms
`of serving as an expert consultant.
` Q. What time frame was this, roughly?
` A. You know, I don't remember the exact
`time frame but roughly, I would say, around 2009,
`2010, maybe later.
` Just so you know, broadly the cases
`were related to Apple versus at the time -- at
`some point it became Google, but maybe Motorola
`Mobility. Again, it's way too back. I don't
`remember exactly.
` Q. Okay. When were you first engaged in
`this particular case?
` A. I'm so sorry. My guess is probably
`sometime last year or I don't know if it was
`towards the end of the previous year. I'm sorry,
`I don't recall.
` Q. No worries.
` Do you understand that there was a
`district court litigation involving some of the
`same patents including the patent that you've
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` N. MANDAYAM
`opined on that has settled since actually you
`filed the declaration in this IPR?
` MR. KODISH: Objection; form.
` THE WITNESS: Yes, I am broadly given
` to understand that there has been some kind
` of resolution. I've also read some in the
` popular press or news. But again, I don't
` know the details of it.
`BY MR. KOHLI:
` Q. Were you ever engaged in anything
`related to the district court litigation?
` A. No, I don't believe so. My only
`engagement has been related to the IPR
`proceedings. No.
` Q. Have you reviewed any materials filed
`in the district court litigation in preparation
`for the IPR?
` A. No. Everything that I've reviewed is
`basically listed in my declaration. And since my
`declaration, the only things I've reviewed are
`the patent owner's preliminary response and the
`decision from the board itself.
` Q. Who first contacted you to work on
`this IPR?
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` N. MANDAYAM
` A. I want to say it's Thad Kodish, but I
`may be wrong. I just don't remember. Sorry.
` Q. How much time in total have you spent
`on this matter? An estimate is fine.
` A. You know, I really don't have a very
`good estimate because, if you'll recall, the
`declaration that I did was, I think, last year.
`And I really don't have sort of a, you know -- I
`never heard anything after the declaration for a
`long time until recently when I found out that
`there will be some activity related to the IPR
`proceedings.
` Q. Have you recently reviewed the
`declaration?
` A. Yes.
` Q. So could you then just come up with an
`estimate of how many hours you would have spent
`in preparing such an extensive document?
` A. Several hours. Again, I don't
`remember. I have to go -- if you want an exact
`number, I can go look at my billing records. But
`I don't have an exact number, at least not off
`the top of my head.
` Q. Have you ever received any funding
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` N. MANDAYAM
`from Apple?
` A. So just so you know, I work at WINLAB.
`I'm a distinguished professor at Rutgers, and I
`also am the associate director of a center at
`Rutgers called WINLAB, which stands for the
`Wireless Information Network Laboratory. So we
`do pre-competitive research on various aspects
`of, you know, broadly again, as I said, wireless
`networking, all aspects of it.
` So we have had sponsor companies at
`various times. WINLAB has been around since, I
`want to say, 1989, and I got there in 1994. So
`at various times we've had sponsor companies, you
`know, take your pick, people who are players in
`wireless. But I don't ever recall that Apple was
`involved in funding any research at WINLAB. I
`don't have any recollection of that.
` Q. In addition to WINLAB, has Apple
`funded any other project that you are aware of
`that you were working on?
` A. No. No. No, I don't believe so.
` Q. How did you prepare for today's
`deposition?
` A. I reviewed all the materials that I
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` N. MANDAYAM
`had considered in my declaration. Then I had
`also reviewed the patent owner's preliminary
`response. The decision. And I also met with
`plaintiff's counsel. Plaintiff's counsel, that's
`the right term?
` Q. Petitioner's.
` A. Petitioner's counsel. And we sort of
`broadly reviewed matters yesterday. That's it.
` Q. You did not review any document that
`you -- sorry. Strike it.
` In addition to the patent owner's
`preliminary response --
` A. Yes.
` Q. -- and the board's institution
`decision --
` A. Yes.
` Q. -- you did not review any documents
`that were not identified in your declaration. Is
`that correct?
` A. So there was in the patent owner's
`response, preliminary response, there was this
`one patent that was discussed. I reviewed that
`recently. If you're asking -- I'm not sure if I
`answered your question.
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` N. MANDAYAM
` Q. Yeah, I think you answered it. Okay.
` A. If I miss something, I will -- if I
`think of something, I will come back and tell
`you. But at least broadly these are sort of what
`I reviewed.
` MR. KOHLI: So Exhibit 1 is the
` declaration that you provided in support of
` Apple's petition on the '037 patent.
` Exhibit 1.
` (Exhibit 1003 marked for
` identification and attached hereto.)
` MR. KOHLI: We'll use the premarked
` exhibit number, so it's APPLE-1003.
`BY MR. KOHLI:
` Q. Did you draft this report yourself --
`this declaration yourself?
` A. So this is my declaration, and the
`opinions here are mine. In sort of coming up
`with the final version, you know, there were
`multiple people I worked with. You know, there
`were phone calls, there were drafts, there were
`edits. And sometimes there were phone calls with
`multiple people, and I don't think I was aware of
`exactly who all were on the call.
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` N. MANDAYAM
` But, you know -- and again, to rely on
`essentially some of the legal aspects of it, I
`clearly relied on my understanding of what it
`means from the petitioner's counsel, so in terms
`of legal standards. But it is my declaration.
`It's mine, and these are my opinions.
` Q. Would you say you authored this
`declaration?
` A. Yes, it is my declaration. Yes, it is
`my declaration.
` Q. Did you author the declaration?
` A. I'm not sure what you mean by "author
`the declaration." This is a declaration by
`Narayan Mandayam, and that's me. So as I said,
`there are various parts of this declaration which
`I relied on others who are more of an expert than
`me.
` As I said, I've done this many times,
`and even though I relied on expert advice on the
`legal standards from the petitioner's counsel, I
`still am familiar with it and understand what
`they mean. And yes, this is definitely my
`declaration.
` Q. Did you author this declaration, yes
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` N. MANDAYAM
`or no?
` MR. KODISH: Objection; form.
` THE WITNESS: I am the author of this
` declaration. I have signed it. It is my
` declaration, yes.
` Does that answer it?
`BY MR. KOHLI:
` Q. I just want to be sure. So you agree
`that you authored this declaration?
` A. Yes, this is my declaration. If you
`want -- yes, I am the author of this declaration.
`Yes.
` Q. Does it contain the full scope of your
`opinions regarding the '037 patent in this IPR
`proceeding?
` MR. KODISH: Objection; form.
` THE WITNESS: I'm not sure what you
` mean by "full scope of opinions." Yes, it
` is my, essentially, analysis of the '037
` patent in light of the prior art and my own
` understanding of the various issues
` pertaining to this. And yes, it is. It is.
` And again, subsequent to this I have also
` seen, as I said, new documents that were
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` N. MANDAYAM
` made available to me. So...
`BY MR. KOHLI:
` Q. Have any of your opinions changed
`since you signed this declaration?
` A. No. No, none of my opinions have
`changed. I stand by the opinions in this
`declaration, even after seeing the additional
`documents.
` Q. How did you decide on the references
`that you used in this declaration?
` A. So as I said, you know, broadly my
`area of work is in wireless networking, various
`aspects related to voice, integrating data. And
`I've also sort of worked at various times, going
`back to in fact the mid '90s, on messaging,
`various aspects related to messaging.
` So when the subject matter of the '037
`patent was, you know -- when I sort of became
`familiar with it, so the -- some of the
`references that were provided were clearly
`provided by the petitioner's counsel. But again,
`as I said, I was familiar with the state of the
`art. I've written papers on this as early as
`1995, 1996. And in fact, the very first time I
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` N. MANDAYAM
`started looking into this notion of messaging was
`in the context of how you use messaging in an
`analog amp system. There was a technology called
`CDPD; I believe it stood for cellular digital
`packet data. So anyway, this is an area that
`I've worked on and am quite familiar with.
` In terms of your question about
`references, many of the references were provided
`by the petitioner's counsel, and I looked at them
`and they seemed, essentially, relevant to this.
` Q. Were there any references that you
`identified by yourself that were used in the IPR?
` A. No, I don't believe so. I think the
`references were, as I said, they were -- I mean,
`I was aware of other art, but I think these
`seemed relevant for, essentially, the matter
`related to the '037 patent.
` Q. So all the references relied upon in
`your declaration were references that were
`identified by the petitioner's counsel. Is that
`correct?
` A. Yes. As I said, I know this matter
`well. I worked on it. But to answer your
`specific question, the references that were
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` N. MANDAYAM
`identified and actually used to support the
`opinions in my declaration I believe were all
`presented by the -- or at least revealed to me or
`shown to me by the petitioner's counsel.
` Q. What about the specific combinations
`of these references? Were the combinations also
`identified by the petitioner's counsel?
` A. No. As I said, the combinations and
`how to sort of make the arguments as I have sort
`of laid down very clearly in my declaration were
`essentially -- it's my opinion. I mean, there
`may have been some discussions and some
`back-and-forth at various times. But yeah, this
`clearly is my sort of declaration and my
`opinion -- my opinions rather, on what the prior
`art means to the '037 patent.
` Q. So just to be clear, the question I'm
`asking is, were the specific combinations that
`you relied on in the declaration, were those
`combinations first identified by the petitioner's
`counsel?
` MR. KODISH: Objection; form.
` THE WITNESS: So I'm not sure what you
` mean by "first identified." There was a set
`
`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm Exhibit 2006
`Apple v. Qualcomm, IPR2018-01279
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` N. MANDAYAM
` of prior art, so I had to do an analysis of
` how to essentially address the issue related
` to invalidity of the '037 patent. And so
` again, as I said, there were many steps in
` this process. But no, the combinations --
` this declaration says the combinations and
` everything else in there, these are mine.
`BY MR. KOHLI:
` Q. Okay. So I understand. I understand
`that the declaration was authored by you.
` A. Yeah.
` Q. I understand it's your position, at
`least, that the declaration was authored by you.
`The opinions in the declaration are your
`opinions. But my question is -- sorry. Strike
`it.
` You've stated on the record that the
`specific references relied upon in the
`declaration were first identified or revealed to
`you by the petitioner's counsel.
` A. Yes.
` Q. Similarly, were the specific
`combinations based on those identified references
`also first revealed to you or presented to you by
`
`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm Exhibit 2006
`Apple v. Qualcomm, IPR2018-01279
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` N. MANDAYAM
`the petitioner's counsel?
` A. No.
` MR. KODISH: Objection to form.
` THE WITNESS: No.
`BY MR. KOHLI:
` Q. So the specific combinations of the
`prior art references relied upon in your
`declaration were references that you had
`identified -- the combinations that you had
`identified?
` MR. KODISH: Objection; form.
` THE WITNESS: Yeah, I think I answered
` your question already. Yes, these
` combinations that I've put forth in my
` declaration were identified by me. Yes.
`BY MR. KOHLI:
` Q. So let's talk about the legal
`standards that you applied.
` A. Okay.
` Q. You mentioned that you are not an
`attorney. Is that correct?
` A. Yes. I'm a professor, yes.
` Q. In your understanding, what standard
`is applied in construing claim language in an IPR
`
`TSG Reporting - Worldwide 877-702-9580
`
`Qualcomm Exhibit 2006
`Apple v. Qualcomm, IPR2018-01279
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` N. MANDAYAM
`proceeding?
` A. Yeah, so -- so in my experience with
`IPR proceedings and the declarations I've done at
`various times, the claim construction, the terms
`that are construed, the claim terms should have
`their plain and ordinary meaning in light of the
`specification of the patent that is in question.
` So this is what I have tried to do --
`I've done actually in my declaration in
`construing the various terms.
` Q. Are you familiar with the concept or
`the term "broadest reasonable interpretation"?
` A. Yes. Yes, I am. I mean, again, as I
`said, there's probably some fine-tuned legal
`interpretation of that, but I do understand what
`the broadest reasonable interpretation of terms
`are, yes.
` Q. Could you describe your understanding.
` A. So it should not be restrictive or
`constraining of the term to something very
`specific. So that's my understanding. And
`again, as I said, the idea behind -- at least my
`understanding and my practice of construing terms
`is that they should have their plain and ordinary
`
`TSG Reporting - Worldwide 877-702-9580
`
`Qualcomm Exhibit 2006
`Apple v. Qualcomm, IPR2018-01279
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` N. MANDAYAM
`meaning in light of the specification.
` Q. Would there be instances when the
`specification would justify limiting the plain
`and ordinary meaning?
` MR. KODISH: Objection; form.
` THE WITNESS: So my take is that the
` terms should really reflect what the
` specification intends for the terms to be.
` So as I said, even the terms that I have
` construed, they are using their plain and
` ordinary meaning in light of the
` specification. If you read through my
` declaration, you will see that also.
`BY MR. KOHLI:
` Q. Do you agree that there can be
`instances where the specification would lead you
`to limit the plain and ordinary meaning of the
`term?
` MR. KODISH: Objection; form.
` THE WITNESS: So as I said, if the
` specification has no ambiguity about the use
` of a term, then I suppose one could -- one
` could make the case for that. However, my
` understanding of claim construction is that
`
`TSG Reporting - Worldwide 877-702-9580
`
`Qualcomm Exhibit 2006
`Apple v. Qualcomm, IPR2018-01279
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` N. MANDAYAM
` it's really the plain and ordinary meaning
` in light of the specification. So...
`BY MR. KOHLI:
` Q. When you say it's the plain and
`ordinary meaning in light of the specification,
`could you explain what you mean by that?
` A. Yeah. So let's take an example. For
`instance, say a voice exchange session. So if
`you look at, essentially, the construction that I
`have offered, I have said, referring to the '037
`specification, it is to mean data transfer in
`which a user's speech or utterance is transferred
`across a network to the location of another
`device or user in realtime. An example,
`instantaneous or near realtime. Example, less
`than three seconds such as a telephone call.
` And these essentially are sentences
`taken directly out of the '037 patent, and I've
`cited references. I don't have the patent in
`front of me, but if you give it to me I can point
`them out to you. But they are cited directly
`from there.
` MR. KOHLI: This is Exhibit 1001,
` APPLE-1001. That's the patent at issue.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Qualcomm Exhibit 2006
`Apple v. Qualcomm, IPR2018-01279
`Page 25
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` N. MANDAYAM
` (Exhibit 1001 marked for
` identification and attached hereto.)
` MR. KODISH: Do you want him writing
` on the exhibits? I suspect not.
` THE WITNESS: Oh, I'm sorry. I do
` this so that I can keep it all straight
` after a while. Sorry.
` MR. KOHLI: That's okay.
` THE WITNESS: Thank you.
`BY MR. KOHLI:
` Q. You are familiar with the concept of a
`person of ordinary skill?
` A. Yes, I am familiar with what it means
`for a person of ordinary skill in the art.
` Q. Just as a shorthand I'll refer to such
`a person as a POSA. Is that okay?
` A. POSA?
` Q. Yeah. If that is something that will
`confuse you, I will stick with person of ordinary
`skill. That's just POSA.
` A. Okay.
` Q. In Paragraph 13 of your declaration
`you opine on the level of a person of ordinary
`skill.
`
`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm Exhibit 2006
`Apple v. Qualcomm, IPR2018-01279
`Page 26
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` N. MANDAYAM
` A. Yes.
` Q. And in Paragraph 12 you mention the
`earliest priority date reported by the '037
`patent as August 8, 2005. Is that correct?
` A. Yes, that is correct. The critical
`date, yes.
` Q. So you agree that the critical date of
`the '037 patent is August 8, 2005?
` MR. KODISH: Objection; form.
` THE WITNESS: Yes.
`BY MR. KOHLI:
` Q. So when I describe a person of
`ordinary skill at the time of the '037 patent,
`you understand that I mean that such a person
`would have the level of ordinary skill you
`described prior to or as of August 8, 2005?
` A. Yes, that is my understanding. So the
`POSITA, the POSA, would have this level of skill
`at the time -- at the critical date.
` Q. Were you a person of ordinary skill as
`of August 8, 2005?
` A. No. I was more than that. So I got
`my Ph.D. in 1994, and as I had said, I had been
`working at WINLAB, the Wireless Information
`
`TSG Reporting - Worldwide 877-702-9580
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`Qualcomm Exhibit 2006
`Apple v. Qualcomm, IPR2018-01279
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` N. MANDAYAM
`Network Laboratory, since then. And I had worked
`on some of these topics. As I said, we do
`pre-competitive research. So we work things five
`to perhaps ten years ahead of time.
` So in 2005, I was working on more
`advanced concepts related to wireless networks,
`wireless data networks. In fact, I was working
`on aspects related to cognitive radios, dynamic
`spectrum access. So these are concepts that are
`used now in what we call 4G and perhaps will be
`used again in systems that we reference as 5G.
` So no, the POSITA is not -- I'm not
`talking about me when I talk about the POSITA or
`the POSA.
` Q. So you were doing cutting-edge
`research at the time?
` A. Yes, I was.
` Q. And you would not consider yourself as
`a POSITA?
` A. I think I'm -- at that time I would
`say I would not consider myself as a POSITA. I
`would think I am more perhaps extraordinary skill
`in the art as opposed to ordinary skill in the
`art, yes.
`
`TSG Reporting - Worldwide 877-702-9580
`
`Qualcomm Exhibit 2006
`Apple v. Qualcomm, IPR2018-01279
`Page 28
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` N. MANDAYAM
` Q. So in drafting your opinions, you have
`applied that extraordinary ability as opposed to
`just ordinary skill?
` MR. KODISH: Objection to form.
` THE WITNESS: No. So therefore I
` think we're talking about a POSITA. Right?
` And Paragraph 13 where I have described,
` essentially, the attributes of a POSITA are
` exactly what I think they are. And this is
` based on my extensive experience over 25
` years of working with faculty colleagues,
` students, people in industry, recent
` graduates, people who have graduated and
` spent some time.
` And one of the nice things about
` WINLAB, as I said, is it is an
` industry/university cooperative research
` center. And one of the things that affords
` us is the ability to sort of interact
` closely with industry. So we oftentimes
` have people from industry who would come
` spend some time at WINLAB, three to six
` months, from various companies. And
` oftentimes they're interested in sort of
`
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`Apple v. Qualcomm, IPR2018-01279
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` N. MANDAYAM
` finding out about forward-looking work that
` their own companies may not have the time or
` the luxury to work on. They're more
` interested in looking at what is happening
` three months from now as opposed to a few
` years from now. So as I said, I have
` extensive experience.
` And also the other thing about WINLAB,
` a nice thing that I've been exposed to,
` oftentimes when these industry sponsors
` visit us and come and see the kind of work
` we are doing, because we are ourselves do
` not have the bandwidth to go to standards
` bodies, so oftentimes they may take ideas
` from our research and say that we would like
` to make a presentation on this to the
` standards body. And eventually some of them
` get into patents.
` So therefore my sort of
` characterization of what would be a POSITA
` is essentially based on -- based on this
` vast experience I've had at WINLAB.
`BY MR. KOHLI:
` Q. Your experience certainly sounds like
`
`TSG Reporting - Worldwide 877-702-9580
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`Apple v. Qualcomm, IPR2018-01279
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` N. MANDAYAM
`an extraordinarily cutting-edge experience and
`expertise, given everything you've stated. It
`seems like you've been doing -- you've been
`dealing with cutting-edge technologies, you've
`been involved with a lot of research, even at the
`time of the filing of the '037 patent. Is that
`correct?
` A.
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