BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
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` ________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ________________
`
` APPLE INC.,
`
` HTC CORPORATION AND HTC AMERICA, INC.,
`
` ZTE (USA) INC.,
`
` Petitioners
`
` v.
`
` INVT SPE LLC,
`
` Patent Owner
`
` ________________
`
` Case No. IPR2018-01473
`
` U.S. Patent No. 6,611,676
`
` Deposition of BRANIMIR VOJCIC, D.SC., A
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`witness herein, called for examination by counsel
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`for Apple Inc. in the above-entitled matter,
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`pursuant to notice, the witness being duly sworn by
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`KAREN YOUNG, a Notary Public in and for the
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`Commonwealth of Virginia, taken at the Hilton
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`Garden Inn, 8301 Boone Boulevard, Vienna, Virginia,
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`at 10:38 a.m. on Wednesday, October 23, 2019, and
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`the proceedings being taken down by Stenotype by
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`KAREN YOUNG, and transcribed under her direction.
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`www.alaris.us
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 1
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`
`
`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` ________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ________________
`
` APPLE INC.,
`
` HTC CORPORATION AND HTC AMERICA, INC.,
`
` ZTE (USA) INC.,
`
` Petitioners
`
` v.
`
` INVT SPE LLC,
`
` Patent Owner
`
` ________________
`
` Case No. IPR2018-01473
`
` U.S. Patent No. 6,611,676
`
` Deposition of BRANIMIR VOJCIC, D.SC., A
`
`witness herein, called for examination by counsel
`
`for Apple Inc. in the above-entitled matter,
`
`pursuant to notice, the witness being duly sworn by
`
`KAREN YOUNG, a Notary Public in and for the
`
`Commonwealth of Virginia, taken at the Hilton
`
`Garden Inn, 8301 Boone Boulevard, Vienna, Virginia,
`
`at 10:38 a.m. on Wednesday, October 23, 2019, and
`
`the proceedings being taken down by Stenotype by
`
`KAREN YOUNG, and transcribed under her direction.
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`www.alaris.us
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 1
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`
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 2
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`APPEARANCES:
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` On Behalf of the Apple Inc.:
`
` PAUL R. HART, ESQ.
`
` Erise IP
`
` 7015 College Boulevard
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` Suite 700
`
` Overland Park, Kansas 66211
`
` paul.hart@eriseIP.com
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` (913) 777-5600
`
`
`
` On Behalf of HTC Corporation and
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` HTC America, Inc.:
`
` (by telephone)
`
` ERIC GILL, ESQ.
`
` Sheppard, Mullin, Richter & Hampton LLP
`
` 12275 El Camino Real
`
` Suite 200
`
` San Diego, California 92130
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` egill@sheppardmullin.com
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` (858) 720-8900
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 2
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 3
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` On Behalf of INVT SPE LLC:
`
` JOHN K. HARTING, ESQ.
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` CYRUS A. MORTON, ESQ.
`
` Robins Kaplan LLP
`
` 800 LaSalle Avenue
`
` Suite 2800
`
` Minneapolis, Minnesota 55402
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` CMORTON@ROBINSKAPLAN.COM
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` JHARTING@ROBINSKAPLAN.COM
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` (612) 349-8500
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`IPR2018-01473
`Apple Inc. EX1012 Page 3
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` C O N T E N T S
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`THE WITNESS:
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`BRANIMIR VOJCIC, D.SC.
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` By Mr. Hart.............................. 5
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` By Mr. Harting........................... 63
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` E X H I B I T S
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`EXHIBIT NO. PAGE NO.
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`Paper 10 Decision, 3/29/19.............. 6
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`Exhibit 1001 U.S. Patent No. 6,611,676...... 5
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`Exhibit 1004 World Intellectual Property
`
` Organization, Publication No. WO
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` 95/10145................................ 5
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`Exhibit 1005 U.S. Patent No. 5,524,275...... 56
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`Exhibit 2002 Declaration of Branimir Vojcic. 6
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`Exhibit 2006 Supplemental Declaration of
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` Branimir Vojcic......................... 6
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`
`
` - - -
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` (Exhibits attached to the original transcript)
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`www.alaris.us
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 4
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 5
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` (WHEREIN, Exhibits 1001, 1004, 2002,
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`2006, and Paper 10 were premarked by counsel.)
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` P R O C E E D I N G S
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`Whereupon,
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` BRANIMIR VOJCIC, D.SC.,
`
` called for examination by counsel for
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` Apple Inc. and having been duly
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` sworn by the Notary Public, was examined
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` and testified as follows:
`
` - - -
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` EXAMINATION BY COUNSEL FOR APPLE INC.
`
`QUESTIONS BY MR. HART:
`
` Q. Welcome back, Dr. Vojcic, for round 2
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`today. Since this is a new record, we'll just go
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`through the introductory stuff one more time. Can
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`you please state your full name for the record?
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` A. Branimir Vojcic.
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` Q. And are there any medical or other
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`reasons you would be unable to answer my questions
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`fully and honestly today?
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` A. No, sir.
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` Q. I have pre-marked a number of exhibits
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`that I will hand to you now. First is Exhibit
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`1001, the '676 patent at issue in this case. The
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`second is Exhibit 1004, the Keskitalo prior art
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`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 5
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 6
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`reference at issue in this case. The third is
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`Exhibit 2002, your first declaration submitted in
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`this proceeding. Next is Exhibit 2006. That is
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`your supplemental declaration submitted in this
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`proceeding.
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` A. Thank you.
`
` Q. Finally, I'm going to hand you a copy of
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`Paper 10, the institution decision in this
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`proceeding. Let me break these up. All the
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`exhibits I handed you with the exception of the
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`institution decision, are you familiar with those
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`documents?
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` A. Yes, yes, I am.
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` Q. And the institution decision, have you
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`reviewed the institution decision in this
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`proceeding?
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` A. I'm not sure. Not sure.
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` Q. In a prior deposition, you and I walked
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`through a number of means plus function claim
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`limitations and proposed structures for those claim
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`limitations. That was I believe in the '563 patent
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`IPR that you're also an expert in. Do you recall
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`that? It's okay if you don't.
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` A. Vaguely, yeah.
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` Q. We have a similar issue here where I'd
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`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 6
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 7
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`like to walk through some of the means plus
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`function limitations for the '676 patent and the
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`proposed structures for those limitations to get
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`your understanding of the language used and whether
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`one of skill in the art would have been familiar
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`with the language used, in other words, to get your
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`opinion as to whether one of skill in the art at
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`the time would have understood what these functions
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`and structures are saying and what they mean.
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` A. Okay.
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` Q. So let's turn to page 10 in the
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`institution decision, Paper 10.
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` A. I'm there.
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` Q. Halfway down page 10, there's the
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`beginning of a chart, two-column chart. Do you see
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`that?
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` A. I do.
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` Q. Okay, the first limitation on the left
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`side of that chart recites a means for increasing
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`or decreasing transmission power of said
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`transmitting means according to transmission power
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`control information received by said receiving
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`means. Do you see that?
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` A. I do.
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` Q. The corresponding structure on the right
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`www.alaris.us
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
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`IPR2018-01473
`Apple Inc. EX1012 Page 7
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 8
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`states, "A circuit programmed or designed to
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`increase or decrease transmission power based on a
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`transmission power control signal." Do you see
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`that?
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` A. I do.
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` Q. At the time of the '676 patent, was it
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`well known to adjust transmission power based on a
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`transmission power control signal?
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` A. Yes, it was.
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` Q. Okay. Would a POSITA have understood the
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`terms used in this proposed construction, the
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`quoted portion on the right side that I read into
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`the record?
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` A. Yes, he would.
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` Q. Those are all terms and phrases that a
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`POSITA would have been familiar with at the time of
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`the '676 patent?
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` A. Definitely.
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` Q. Okay. Let's turn to the next page, page
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`11 in Paper 10, the institution decision. At the
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`top, there's a means for calculating an average
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`value of the transmission power of said
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`transmission means. Do you see that?
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` A. I do.
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` Q. And on the right, a proposed
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`www.alaris.us
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`IPR2018-01473
`Apple Inc. EX1012 Page 8
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 9
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`corresponding structure is, quote, "A processor or
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`other circuitry programmed or designed to calculate
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`an average value of transmission power." Do you
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`see that?
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` A. I do.
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` Q. Was it well known at the time of the '676
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`patent that average transmission power of a device
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`could be calculated?
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` MR. HARTING: So I just want to make --
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`on the record, I don't believe that Dr. Vojcic's
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`declarations address the means plus function
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`aspect, so I think it's outside the scope of his
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`direct. Is there anything you had in mind that
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`tied it to his direct?
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` MR. HART: Well, he's analyzed the claim,
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`he's ascribed meaning to the claims, and he has
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`opined on whether the prior art applies to the
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`claim. He's implicitly adopted some meaning for
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`each limitation in the challenged claims of the
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`'676 patent. I'm simply walking through those
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`limitations that he has analyzed and opined on to
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`confirm that there is a concrete meaning for each
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`of these limitations that we can apply in this
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`proceeding.
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` MR. HARTING: Yeah, so I think his
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`www.alaris.us
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
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`IPR2018-01473
`Apple Inc. EX1012 Page 9
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 10
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`declaration -- so his direct testimony goes to
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`claim 7. I understand the relationship between
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`claim 7 and claim 1, so I just -- I'll note it on
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`the record that I think it's outside the direct --
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`scope of the direct. I'll let the testimony
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`continue for now.
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` MR. HART: Okay.
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` MR. HARTING: I'm not going to instruct
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`him not to answer, but put that on the record.
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` MR. HART: Yeah, just to be clear, you
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`know, I believe claim 7 was used as a
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`representative claim, but it's my understanding
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`that your critiques of claim 7 also apply to claim
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`1 in your papers in this matter. Is that fair?
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` MR. HARTING: That is fair. I think
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`there is a distinction in, you know, where means
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`plus function claims are at issue and structure and
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`specification and all that where it's a separate
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`legal analysis, but you know, for now I'm not going
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`to instruct him not to answer.
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`BY MR. HART:
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` Q. Okay. So the question I asked before the
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`sidebar with counsel is was it well known at the
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`time of the '676 patent that average transmission
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`power of a device could be calculated.
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`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 10
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` A. I'm thinking.
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` Q. Uh-huh.
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` A. I couldn't recall any references that
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`would have done that. Theoretically, I think one
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`could argue that could be possible, could be
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`designed. I'm not aware of references that they're
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`doing that.
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` Q. Okay, and I suppose I want to make a
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`clarification that I'm not -- I'm not asking you
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`specifically if these concepts were in a particular
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`reference. I'm trying to get whether the language
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`used on the right side of the column here is
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`understandable to a POSITA and would have been
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`known -- or a POSITA would have understood what
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`this language is describing. So let me ask you
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`another question. A processor or other circuitry
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`programmed or designed to calculate an average
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`value of transmission power, does that language
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`have meaning to one of skill in the art at the time
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`of the '676 patent?
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` A. Yeah, yeah, it has meaning. It's plain
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`English, some of the terms that are very standard.
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` Q. Okay, and are there any ambiguous terms
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`or phrases in that quoted portion that would --
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`that a POSITA would question, that would lead a
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`www.alaris.us
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
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`IPR2018-01473
`Apple Inc. EX1012 Page 11
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`POSITA to question the scope of that quoted
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`portion?
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` A. I mean, there are -- it's a fairly
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`general statement, so there are a bunch of
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`questions that could be asked there as to how to do
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`it or what it means, calculated versus measured. I
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`don't know that "calculate" is the best word to use
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`there. Probably "measured" is better, and you
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`know, on what time scale to measure, et cetera et
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`cetera. So it's fairly general statement, and I
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`would say only question, word "calculate," but
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`maybe that implies that there was measurement
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`behind it. I don't know what -- what it meant.
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` Q. Okay. Would you have interpreted a
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`processor or other circuitry programmed or designed
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`to calculate an average value of transmission power
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`to mean the average value of transmission power is
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`being measured?
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` A. Yeah.
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` Q. Okay. And aside from that, you
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`understand what this --
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` A. Sure.
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` Q. -- phrase is saying. The next
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`limitation, means for holding a predetermined
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`allowable transmission power value. Do you see
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`IPR2018-01473
`Apple Inc. EX1012 Page 12
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`that?
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` A. Yes, I do.
`
` Q. On the right side, the proposed
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`corresponding structure is, quote, "A processor or
`
`other circuitry programmed or designed to hold a
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`predetermined allowable transmission power value."
`
`Is this proposed structure -- does this proposed
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`structure also use language that would have been
`
`understood by a POSITA at the time of the '676
`
`patent?
`
` A. I couldn't talk about -- I don't know
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`what you mean by the structure. I think the
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`structure is what's disclosed below that sentence,
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`so I think this is really a function that you're
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`mention.
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` Q. Well, it's -- sure, there's some nuance
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`there on the patent side, but let's just talk about
`
`the quoted portion that I read into the record.
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` A. Yeah.
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` Q. Is that quoted -- does that quoted
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`portion use language that would have been
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`understood by a POSITA at the time of the '676
`
`patent?
`
` A. Yes, it's understandable.
`
` Q. And the last on page 11 is a means for
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`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 13
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 14
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`comparing the average value with the allowable
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`transmission power value. Do you see that?
`
` A. Yes, I do.
`
` Q. Okay, and on the right side in the quoted
`
`portion, it states, "A processor or other circuitry
`
`programmed or designed to compare the average
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`transmission power value with the predetermined
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`allowable transmission power value." Do you see
`
`that?
`
` A. I do.
`
` Q. And does that quoted portion use language
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`that would have been understood by a POSITA at the
`
`time of the '676 patent?
`
` A. Yes.
`
` Q. The last means plus function limitation
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`is on page 12 of Paper 10, states, "Means for
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`changing a transmission rate according to the
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`comparison result in said comparing means." Do you
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`see that?
`
` A. I do.
`
` Q. Okay. And on the right, the quoted
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`portion is, "A processor or other circuitry
`
`programmed or designed to change a transmission
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`rate according to a comparison between the average
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`transmission power value and the predetermined
`
`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 14
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 15
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`allowable transmission power value." Do you see
`
`that?
`
` A. I do.
`
` Q. Does this quoted portion also use
`
`language a POSITA would have understood at the time
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`of the '676 patent?
`
` A. It's logically in English. It's on
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`technical terms. I think a POSITA would understand
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`if -- what this means if you read the patent.
`
` Q. Okay. Was changing the transmission rate
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`of a device known, understood at the time of the
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`'676 patent?
`
` A. Couldn't recall references from top of my
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`head, but generally, conceptualy, yes.
`
` Q. We can set aside Paper 10. Let's turn
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`next to your original declaration submitted in this
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`proceeding, Exhibit 2002, and specifically
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`paragraph 22, which begins on page 6. So you
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`discuss in the bottom of page 6 a concept called
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`signal-to-interference ratio that you abbreviated
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`as SIR. Do you see that?
`
` A. I do.
`
` Q. In the last sentence beginning on page 6
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`over to page 7 states, "SIR is the quotient between
`
`the average received signal power and the average
`
`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 15
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 16
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`received interference," paren, "co-channel and/or
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`from adjacent channels," end paren, "i.e,
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`cross-talk from other transmitters and/or channels
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`than the useful signal." Do you see that?
`
` A. Yes, I do.
`
` Q. Why do you describe the SIR as one
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`involving average power and average interference
`
`measurements?
`
` A. Sorry, I didn't understand the question.
`
` Q. Why is it that an SIR involves average
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`power and average interference measurements rather
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`than instantaneous power and instantaneous
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`interference measurements?
`
` A. I was referring to some exhibit here, I
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`guess the patent, so maybe I was describing how the
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`patent was interpreting that, but to answer
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`unrelated to the patent description, to answer your
`
`question is in general, sure, could be -- we could
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`have a notion of instantaneous and average. The
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`problem with instantaneous, it's hard to measure,
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`so to measure something with accuracy, whatever
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`defined level of accuracy, you would have to
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`measure over some time interval, which will give
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`you average over some time interval. So even when
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`people in the art use "instantaneous," it's still
`
`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 16
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 17
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`an average, but over some short time interval.
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` Q. So technically the concept of an
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`instantaneous power measurement is not a thing --
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`is impossible?
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` A. It's -- strictly speaking, theoretically,
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`it's impossible to measure. It's possible to exist
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`as a -- as a concept but it's almost impossible to
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`measure, so it's would be always averaged over some
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`time interval, but when people in the art refer to
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`it, you know, instantaneous versus average, they
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`have some notions there of time scales, you know,
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`one for instantaneous is fairly short and not very
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`accurately estimated and the average is over longer
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`time scale and more accurate estimate.
`
` Q. Are you familiar with the concept of a
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`signal-to-noise ratio?
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` A. Yes, I am.
`
` Q. Is that similar to a signal-to-
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`interference ratio that you've abbreviated SIR?
`
` A. It's -- strictly speaking, it's different
`
`because it's signal power over noise, meaning
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`thermal noise inside the receiver. Sometimes
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`people use the language interchangeably, and you
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`know, just say SNR, but that means SNR and
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`interference, or there is another term in the art
`
`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 17
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 18
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`used, SINR, signal to interference plus noise
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`ratio. So you could have three different
`
`definitions there. Each have -- each has very
`
`specific meaning, but sometimes people use them
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`sort of loosely, meaning that one could accommodate
`
`all three notions.
`
` Q. So am I understanding you correctly that
`
`SIR, SNR and SINR are commonly used to describe the
`
`quality of a reception?
`
` A. That's correct.
`
` Q. Even though there may be some technical
`
`distinctions between the three as to what
`
`specifically they're measuring.
`
` A. That's correct.
`
` Q. Okay. For all three, SIR, SNR and SINR,
`
`is it true that they will always be based on an
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`average power measurement rather than a strictly
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`instantaneous measurement for the reason you
`
`described earlier?
`
` A. Yes, and with -- with caveats that I
`
`explained earlier.
`
` Q. That that time period could be different
`
`depending on the specific value you're looking for?
`
` A. No, what I meant is that that
`
`instantaneous would still require some time
`
`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 18
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 19
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`averaging over some short time interval.
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` Q. Sure, and I suppose that was my question.
`
`For all three, SIR, SNR and SINR, there will always
`
`be some time period over which they're measured,
`
`correct?
`
` A. Correct.
`
` Q. So I believe you noted that the SIR
`
`discussion in paragraph 22 is in relation to the
`
`'676 patent, correct?
`
` A. Yeah, I believe so.
`
` Q. Okay. If we look at claim 7 of the '676
`
`patent, Exhibit 1001 --
`
` MR. HARTING: Sorry, Counsel, did you say
`
`claim 7?
`
`BY MR. HART:
`
` Q. Claim 7. And I'll let you read through
`
`it before I ask a question.
`
` A. Sure.
`
` Q. Let me know when you're ready.
`
` A. I read it, yes.
`
` Q. So in claim 7, starting with the second
`
`limitation, there's a concept of average value.
`
`Specifically the claim states, "Average
`
`transmission power calculation circuitry that
`
`calculates average value of the transmission
`
`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 19
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`
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 20
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`power." Then there's a concept of holding a
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`predetermined allowable transmission power value,
`
`and then finally, comparing the average value with
`
`the allowable transmission power value. Do you see
`
`that?
`
` A. I do.
`
` Q. What's the reason that the claims of the
`
`'676 patent use an average power?
`
` A. I think the reason is -- I don't recall
`
`all the reasons now. I don't recall how
`
`specification, but I think the main motivation when
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`patentee used this average is that in the radio
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`communications in general, there is channel changes
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`for different reasons and different time scales.
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`So if you move through the medium, through the
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`environment walking or by your car, the distance
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`between transmitter and receiver changes --
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`changes, and as a concept, the path of loss or
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`signal -- average signal strength changes, but
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`that's fairly slow compared to some other
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`variations.
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` The other variation occurs as a result of
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`multipath radio propagation. In other words,
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`signal could travel between transmitter and
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`receiver through multiple spatial paths, you know,
`
`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 20
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 21
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`reflections of the ground, buildings, of hills,
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`direct path and so on, so when all of these signals
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`arrive at the receiver, we have a super position of
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`same signal with different delays that result in
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`so-called multipath fading, and as a consequence,
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`there is a constructive or destructive super
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`position, signal enhancement or signal fading or
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`degradation, and that happens on a much much
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`shorter time scale than, you know, just by motion
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`through environment.
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` So why the patentee considered here
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`average, he wanted to consider some longer term
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`aspects, not to react immediately on these
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`short-term variations that could occur over a
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`couple of signals or several signals, but what
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`could happen on the scale of whole data packets or
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`multiple data packets.
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` Q. So using average transmission power in
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`the '676 invention prevents changes due to very
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`small time scale events; is that correct?
`
` A. That's correct, very small time events
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`that would be within a fraction of a packet.
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` Q. But ensures that larger time scale events
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`are captured and responded to appropriately.
`
` A. That's correct.
`
`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2018-01473
`Apple Inc. EX1012 Page 21
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` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`Page 22
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` Q. Do the claims of the '676 patent require
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`any p
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