BRANIMIR VOJCIC, D.SC. 10/23/2019
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` On Behalf of INVT SPE LLC:
` JOHN K. HARTING, ESQ.
` CYRUS A. MORTON, ESQ.
` Robins Kaplan LLP
` 800 LaSalle Avenue
` Suite 2800
` Minneapolis, Minnesota 55402
` CMORTON@ROBINSKAPLAN.COM
` JHARTING@ROBINSKAPLAN.COM
`(612) 349-8500
`
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` C O N T E N T S
`THE WITNESS:
`BRANIMIR VOJCIC, D.SC.
` By Mr. Hart.............................. 5
`
` E X H I B I T S
` PAGE NO.
`EXHIBIT NO.
`Exhibit 1001 U.S. Patent No. 7,764,711...... 5
`Exhibit 1005 U.S. Patent No. 6,067,290...... 5
`Exhibit 2001 Joint Disputed Proposed Claim
` Terms for Construction.................. 18
`Exhibit 2002 Declaration of Branimir Vojcic. 6
`
`- - -
`
` (Exhibits attached to the original transcript)
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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. IPR2018-01476
` U.S. Patent No. 7,764,711
`
` 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 9:05 a.m. on Wednesday, October 23, 2019, and
`the proceedings being taken down by Stenotype and
`transcribed by KAREN YOUNG.
`
`Page 2
`
`APPEARANCES:
` On Behalf of the Apple Inc.:
` PAUL R. HART, ESQ.
` Erise IP
` 7015 College Boulevard
` Suite 700
` Overland Park, Kansas 66211
` paul.hart@eriseIP.com
`(913) 777-5600
`
` On Behalf of HTC Corporation and
` HTC America, INC.:
` (by telephone)
` ERIC GILL, ESQ.
` Sheppard, Mullin, Richter & Hampton LLP
` 12275 El Camino Real
` Suite 200
` San Diego, California 92130
` egill@sheppardmullin.com
`(858) 720-8900
`
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`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`1 (Pages 1 to 4)
`
`Fax: 314.644.1334
`
`IPR2018-01476
`Apple Inc. EX1020 Page 1
`
`

`

` BRANIMIR VOJCIC, D.SC. 10/23/2019
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` P R O C E E D I N G S
` (WHEREIN, Exhibits 1001, 1005, 2001 and
`2002 were premarked for identification by counsel.)
`Whereupon,
` BRANIMIR VOJCIC, D.SC.,
` called for examination by counsel for
` Apple Inc. and having been duly
` sworn by the Notary Public, was examined
` and testified as follows:
` - - -
` EXAMINATION BY COUNSEL FOR APPLE INC.
`QUESTIONS BY MR. HART:
` Q. Good morning, Dr. Vojcic.
` A. Good morning, Counsel.
` Q. Can you please state your full name for
`the record?
` A. Branimir Vojcic.
` Q. Are there any medical or other reasons
`you would be unable to answer my questions fully
`and honestly today?
` A. No.
` Q. I'm going to hand you a few exhibits I've
`pre-marked. The first is Exhibit 1001. That is
`the '711 patent challenged in this matter. The
`second is Exhibit 1005, Paulraj prior art reference
`
`Page 6
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`issue in this matter, and the third is Exhibit
`2002. That is your declaration submitted in this
`matter. You're familiar with all three of these
`pre-marked exhibits, correct?
` A. Yes, I am.
` Q. Let's start with the '711 patent, Exhibit
`1001, and let's go to claim 1. All right. I'd
`like to walk through the three limitations of claim
`1 in the '711 patent. So let's start with mapping
`section. Claim 1 limitation that we've referred to
`as 1A reads, "A mapping section that maps the
`plurality of data items to at least one of the
`plurality of antennas." Do you see that?
` A. I do.
` Q. So this first limitation requires both a
`plurality of data items and a plurality of
`antennas; is that correct?
` A. That's correct.
` Q. And it also requires the plurality of
`data items are mapped to at least one of the
`plurality of antennas, correct?
` A. That's correct.
` Q. Does this limitation require any data
`items mapped to different antennas?
` A. No, at least one of the plurality.
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` Q. Let's go to the next limitation, which
`states, "A transmitting section that transmits the
`plurality of data items using the at least one of
`the plurality of antennas to the receiving
`apparatus." Do you see that?
` A. Yes, I do.
` Q. Okay. So this second limitation requires
`transmitting the plurality of data from whichever
`antennas data was mapped to in the first
`limitation; is that correct?
` A. Just a moment.
` Q. Sure.
` A. That's correct.
` Q. So this limitation also doesn't require
`any data items transmitted from different antennas,
`does it?
` A. It doesn't, but allow -- allows.
` Q. Understood. Moving on to the third
`limitation, which I'll read in for the record,
`states, "Wherein the mapping section generates a
`replica data item by replicating a specific data
`item of the plurality of data items and maps the
`plurality of data items to the at least one of the
`plurality of antennas such that the specific data
`item and the replica data item are transmitted from
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`Page 8
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`different antennas at the same time." Do you see
`that?
` A. I do.
` Q. So this final limitation introduces a
`specific data item; is that correct?
` A. That's correct.
` Q. And that is part of the plurality of data
`items we've seen from earlier in the claim; is that
`right?
` A. That's correct.
` Q. And this final limitation also states
`that the specific data item is replicated; is that
`right?
` A. That is correct.
` Q. And it requires that the specific data
`item and its replica are transmitted simultaneously
`from different antennas, correct?
` A. That's correct.
` Q. Now, in your declaration submitted in
`this matter, I believe you refer to that concept as
`transmit diversity. Am I correct about that?
` A. Probably.
` Q. Okay.
` A. I'm familiar with that concept. I'm not
`sure if I mentioned in the declaration, but yes, if
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`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`2 (Pages 5 to 8)
`
`Fax: 314.644.1334
`
`IPR2018-01476
`Apple Inc. EX1020 Page 2
`
`

`

` BRANIMIR VOJCIC, D.SC. 10/23/2019
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`you transmit a replica of one data item on another
`antenna, that's definitely considered in the art
`transmit diversity.
` Q. Great. Does this final limitation in
`claim 1 require any data other than the specific
`data item and its replica be transmitted in any
`particular way?
` A. Could you repeat the question please?
` Q. Sure. Does this final limitation in
`claim 1 require any data other than the specific
`data item and its replica be transmitted in any
`particular way?
` A. Not beyond what was required in the
`previous limitation.
` Q. And just for clarity, the final
`limitation, to the extent it imposes specific
`limitations on how data is transmitted, it's just
`with respect to the specific data item and its
`replica; is that correct?
` A. I wouldn't phrase it exactly like that,
`but I would say it -- it further specifies how one
`of the specific data item out of the multiple data
`items is transmitted in relation to its replica and
`previous limitations as you could transmit those
`data items on at least one of the antennas.
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`Page 10
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` Q. Okay. Are data items other than the
`specific data item and its replica addressed by the
`final limitation of claim 1?
` A. No.
` Q. Okay. Can I have you reference your
`declaration in this matter, Exhibit 2002, and
`specifically paragraph 30? In paragraph 30, you
`discuss a concept referred to as spatial
`multiplexing. Do you see that?
` A. Yes, I do.
` Q. Okay, and you state that spatial
`multiplexing involves utilizing different antennas
`to transmit different data through multiple
`antennas in parallel; is that correct?
` A. That's -- I don't see that here. Yes,
`yes, that's I guess from the -- from the preamble.
`Let me see. That's how generally it's understood
`in the art, but I think that's part of phrasing the
`preamble.
` Q. Okay, so the sentence I read is the
`general understanding of spatial multiplexing in
`the art; is that correct?
` A. Correct.
` Q. And spatial multiplexing is different
`from transmit diversity, correct?
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` A. It is considered to be different.
` Q. Transmit diversity is not a subset of
`spatial multiplexing, is it?
` A. Yeah, I don't know what you mean by
`subset. They're different.
` Q. Okay. When you say transmit different
`data through multiple antennas in parallel, does
`this mean transmitting different data using
`different antennas at the same time?
` A. Yes, they're using different antennas at
`the same time, and I would say also at the same --
`in the same resources, frequency resources.
` Q. So spatial multiplexing involves energy
`representing bits from one data item radiated from
`a first antenna at the same time energy
`representing bits from a second data item are
`radiated from a second antenna; is that correct?
` A. That -- that could be, yes, that could be
`one typical way of doing spatial multiplexing.
` Q. If we go back one paragraph in your
`declaration, Exhibit 2002, to paragraph 29, the
`first sentence states, "The claims of the '711
`patent impose spatial multiplexing transmission and
`transmit diversity at the same time." Do you see
`that?
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` A. Yes, I do, first sentence, yeah.
` Q. Is it your opinion that additional data
`that is not the specific data item or its replica
`must be transmitted simultaneously with the
`specific data item and its replica to satisfy the
`claims of the '711 patent?
` A. I'm sorry, you need to repeat again.
` Q. Sure. So we've talked about how the
`final limitation of claim 1 requires a specific
`data item and its replica simultaneously
`transmitted across different antennas, correct?
` A. That's correct.
` Q. Does claim 1 require transmitting other
`data simultaneously with the transmission of the
`specific data item and its replica?
` A. Yes, that's my understanding.
` Q. So you believe that at least claim 1 of
`the '711 patent requires at least three data items
`transmitted simultaneously, the specific data item,
`its replica and something else.
` A. And one or more other data items, yes.
` Q. What claim limitation in claim 1 sets
`forth that requirement, that at least three things
`are transmitted simultaneously?
` A. I think -- well, multiple limitations. I
`
`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`3 (Pages 9 to 12)
`
`Fax: 314.644.1334
`
`IPR2018-01476
`Apple Inc. EX1020 Page 3
`
`

`

` BRANIMIR VOJCIC, D.SC. 10/23/2019
`
`Page 13
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`think there is plurality of data items that needs
`to be transmitted from one or more antennas from
`the preamble in limitation 1, and maybe -- and also
`limitation 2, transmitting limitation, and so
`that's at least two data items. And then the
`mapping section further generates a replica data
`item of one of the -- of one of the plurality of
`data items, so that's the third one.
` Q. So when we first talked about the
`limitation A in claim 1 and limitation B in claim
`1, I believe you testified that those limitations
`did not require the plurality of data items to be
`sent on more than one antenna. Rather, those
`limitations simply require that multiple items are
`sent on at least one antenna; is that correct?
` A. That's correct.
` Q. And the -- I believe you testified that
`the specific data item is part of the plurality of
`data items; is that correct?
` A. If I said that, I didn't mean that. I --
`oh, specific data item, yes.
` Q. Specific --
` A. Specific data item, yes, correct.
` Q. So can you explain to me again how claim
`1 requires the specific data item, its replica and
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`Page 14
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`something else be transmitted simultaneously?
` A. Okay, let me read the whole claim once
`again. So could you repeat the question please?
` Q. Sure. Can you explain to me again how
`claim 1 requires the specific data item, its
`replica and something else be transmitted
`simultaneously?
` A. The first -- first we explain how
`preamble is defining this minor system,
`transmitting a plurality of data items in parallel
`from multiple antennas in parallel of plurality of
`antennas. Then the next section says mapping the
`plurality of those data items to at least one of
`the plurality of antennas. So we have at least two
`data items now.
` Then further -- further, the mapping
`section has an additional function that it performs
`that it generates in addition to those data items
`that it mapped, generates a replica data item, so
`that means that's at least three, and further, it
`clarifies, even though previous limitations said
`that those data -- plurality of data items are
`transmitted in parallel, which I think a POSITA
`would understand at the same time on the same
`resources, now the third limitation also says that
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`even if additional replica data item is transmitted
`at the same time its specific data item from which
`it's replicated. I think it's -- that particular
`arrangement is consistent with one of the -- with
`one of the embodiments. Yeah, for example,
`embodiment of figure 4, we have the first antenna
`and the first time interval data 1, while on -- on
`antenna 2, we have data 2. That's not necessarily
`required by a claim, but -- but it's allowed by the
`claim such an arrangement, and -- and then we also
`have transmission data on -- on these antennas in
`addition.
` Q. So I'd like to walk back through the
`limitations of claim 1. Let's set aside the
`preamble for now.
` A. Okay.
` Q. The first limitation, 1. A, mapping
`section that maps the plurality of data items to at
`least one of the plurality of antennas. If I have
`a stream of multiple data items transmitted from
`one of two antennas, have I satisfied the first
`limitation and the second limitation?
` A. I don't know what you mean by if you have
`a stream of plurality of data items from one
`antenna. What do you mean by stream?
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` Q. In series, data items.
` A. Oh, one -- one after the other.
` Q. Correct.
` A. Serially.
` Q. Separated in time.
` A. If you consider that limitation in
`isolation, which I don't believe is a proper way to
`read limitations in isolation, a lot of claim
`limitations and perhaps preamble, if it is so
`limiting, then it would be correct, but -- but I
`don't think it's very meaningful to consider just
`one claim limitation in isolation.
` Q. I'm trying to make sure we're on the same
`page with respect to the specific words used in the
`claim, and we can come back and talk about what
`impact the preamble may have on the claim, but for
`now I want to make sure we have an understanding as
`to what the claim language actually says. So just
`to be clear, the first two limitations, the mapping
`section and the transmitting section, if we have a
`stream of -- serial stream of data items
`transmitted one after the other on one of two
`antennas, we have satisfied the express language of
`those first two limitations, correct?
` A. I'm not sure about that. Let me think
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`www.alaris.us
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`4 (Pages 13 to 16)
`
`Fax: 314.644.1334
`
`IPR2018-01476
`Apple Inc. EX1020 Page 4
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`

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`about that. I don't think -- because it already
`defines -- it's already using antecedent basis by
`saying the plurality of data items. So I couldn't
`-- I don't think POSITA would consider that in
`isolation of what was already -- what has been
`already defined in the preamble, and -- and in the
`preamble, it says that these plurality of data
`items are transmitted in parallel. So by having
`that in mind, I don't -- I think POSITA would not
`understand that these are in serial.
` Q. Am I correct that the final limitation of
`claim 1 does require the specific data item and its
`replica transmitted in parallel?
` A. I think, if I understood your question
`correctly, the answer would be yes, the specific
`data item and its replica are transmitted in
`parallel, yes.
` Q. And the claim allows for multiple pieces
`of data to be considered specific data items over
`time, correct?
` A. I don't know. Let me -- what do you
`mean, over time?
` Q. So if a transmitting apparatus consistent
`with claim 1 of the '711 patent is transmitting a
`variety of data over time, does the claim allow for
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`different data items to be characterized as
`specific data items such that they are replicated
`and sent in parallel with their replicas?
` A. I don't think claim -- claim considers
`what could generally be done over time. It's
`really I think directed to what's -- what's done or
`what's the apparatus arrangement at a given time,
`so -- and at a given time, it's -- we have to
`elaborate how it's done.
` Q. I'm going to hand you what's been marked
`in this proceeding as Exhibit 2001.
` A. Thank you.
` Q. This is the joint disputed proposed claim
`terms for construction in the parallel ITC
`investigation. Counsel, I don't have an extra copy
`of this. We're just looking at the agreed-upon
`construction for the preamble.
` MR. HARTING: Preamble.
`BY MR. HART:
` Q. Yeah, if you don't mind sharing with
`Dr. Vojcic, that would be great. Dr. Vojcic, could
`you turn to page what's labeled 1 of 9, the very
`beginning of the chart in Exhibit 2001?
` A. I'm there.
` Q. Okay. Are you familiar with this
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`document?
` A. I'm not hundred percent sure. I mean, I
`know I saw some claim construction before, so not
`sure if it's exactly the same, but I was
`familiarized with claim construction regarding this
`at some point.
` Q. The second row of the chart on page 1 of
`9 in this exhibit, it lists the preamble from
`claims 1, 2 and 4 of the '711 patent. Do you see
`that?
` A. You mean first row?
` Q. Well, first row under the heading.
` A. Yeah, yeah, yeah.
` Q. The title row.
` A. I understand.
` Q. Okay. And in the right column, it notes
`that there's an agreed construction for that
`preamble. Do you see that? Specifically, quote,
`"Multiple antenna apparatus which transmits
`multiple data items," paren, "transmission data,"
`end paren, "at the same time and at the same
`frequency using multiple antennas," end quote?
` A. I do.
` Q. Do you agree with that interpretation of
`the preamble, the claims of the '711 patent?
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` A. Yeah, generally I do. I mean, I agree
`that's how MIMO would be understood in the art
`where this essentially at the same time and the
`same frequency question depends on the context of
`the system and specific realization, system
`realization, doesn't necessarily mean to be hundred
`percent at the same time or hundred percent on the
`same frequencies, but there is a transmission at
`the same time and on the same frequencies in that
`arrangement.
` Q. And just so -- make sure I understood
`your answer correctly, are you saying that the
`preamble doesn't require the claim device to
`transmit multiple data items at the same time 100
`percent of the time?
` A. That too could be the case. MIMO
`apparatus -- you know, POSITA treats that he
`considers everything that's available in the part,
`how -- you know, how to understand the term, and it
`is true that there were MIMO apparata that are
`capable of doing multiple data items from different
`antennas at the same time, but sometimes they --
`for some reason, they might not. They would just
`do one data item. There is no more to transmit,
`for example, whatever it is.
`
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`
`ALARIS LITIGATION SERVICES
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`

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` Q. Is your understanding of the '711 claims
`that they require multiple data items transmitted
`in parallel at the same time some of the time but
`not all of the time?
` MR. HARTING: Objection, misstates the
`testimony.
` A. No, what I was trying to say, that --
`that MIMO requires multiple data items at the same
`time, but I was trying to explain that it's -- MIMO
`apparatus in some real-world realization may not
`always implement multiple data items, but normally
`it's intended to do that.
` Q. Is the preamble in the claims of the '711
`patent the language that you believe describes
`spatial diversity?
` A. Here, when you say spatial diversity, you
`mean transmit diversity as you mentioned it earlier
`or something else?
` Q. I believe we used the term "spatial
`multiplexing," and that's what I meant.
` A. Oh, okay, so --
` Q. So let me rephrase my question using the
`correct phrase from your declaration. Is the
`preamble in the claims of the '711 patent the claim
`language that you believe describes spatial
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`Page 22
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`multiplexing?
` A. Yes, that should be one -- if you talk
`about how POSITA would understand it, that would be
`a correct understanding.
` Q. Is there any other language after the
`preamble that describes spatial multiplexing?
` A. That requires spatial?
` Q. Yes.
` A. No, other limitations don't require, but
`they allow, and -- which is consistent to the
`specification. There are examples in the
`specification, for example, where I -- from memory,
`you could transmit multiple -- two, for example,
`data items from one antenna, if you separate them
`by some other means, like in the example of code
`separation, that's another possibility, which is --
`so the claim is written very broadly to accommodate
`multiple combinations of MIMO schemes.
` Q. Let's turn to the Paulraj reference next,
`Exhibit 1005, and specifically to figure 9A in
`Paulraj.
` A. I'm there, Counsel.
` Q. You are familiar with figure 9A from the
`Paulraj reference, correct?
` A. Yes, I am familiar.
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` Q. You discuss figure 9A from Paulraj in
`paragraph 36 of your declaration, Exhibit 2002.
`Can I have you pull up that exhibit? I think it
`might be easiest to walk through your description
`of 9A.
` A. Yes, I'm there.
` Q. Okay. Your first sentence in paragraph
`36, you note that in its institution decision,
`paper 9, the board cites to the petition, paper 1,
`a description on figure 9 embodiment to show that
`Paulraj discloses one data stream, 176, i.e., data
`item, can be transmitted by breaking it up into two
`substreams, 456 and 458, that could be transmitted
`by two antenna, 136T and 134T. Do you see that
`sentence?
` A. Yes, I do.
` Q. So do you agree that the two -- before I
`ask my question, looking at figure 9, I believe
`there was a typo in your declaration.
` A. Yeah, it should be 456 and 454.
` Q. Okay, great.
` A. Yeah.
` Q. So I will try to correct that in my
`questions to keep things easy to understand in the
`record. Do you agree that Paulraj teaches two data
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`substreams, 454 and 456, that are transmitted
`simultaneously from antennas 136T and 134T?
` A. That's -- I mean, it's a little bit
`confusing in the figure because these time
`intervals are not aligned, but as you said, it's
`actually even -- a person of ordinary skill in the
`art would understand that even if they're not
`perfect hundred percent aligned, it still would be
`substantively the same time, so I would agree.
` Q. Would you agree that this arrangement
`that we just discussed in Paulraj figure 9A depicts
`a spatial diversity scenario which distinct data
`streams are transmitted from multiple antennas?
` A. No, I don't.
` Q. And why's that?
` A. Because I guess maybe you're making the
`same mistake as five minutes ago, calling spatial
`multiplexing spatial diversity.
` Q. Let me rephrase my question. I believe I
`have that wrong throughout my outline, so bear with
`me today. Would you agree that Paulraj figure 9
`depicts a spatial multiplexing scenario in which
`distinct data streams are transmitted from multiple
`antennas?
` A. Yes, I would agree that these are two
`
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`Apple Inc. EX1020 Page 6
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`

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`distinct streams of symbols or data.
` Q. Turning back to your declaration, in the
`next sentence, paragraph 36, you note that
`additional block 314A could be used to add
`diversity as well as some other features.
`Continuing on the next page, and facilitate
`transmission of substreams via a form of diversity
`on additional antennas 942 and 940. Do you see
`that?
` A. Yes, I do.
` Q. Would this be transmit diversity if
`substreams 454 and 456 were also transmitted on
`antennas 942 and 940?
` A. It's a sort of broad characterization
`there of, you know, several different schemes that
`could -- and one -- one is mentioned as diversity,
`so I would -- I don't recall exactly how Paulraj
`described the arrangement, but I would agree that
`the assumption or block when it's employed would