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` B. VOJCIC
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________________________
` HTC CORPORATION, HTC AMERICA, INC.
` and APPLE INC.,
` Petitioner
` v.
` INVT SPE LLC,
` Patent Owner
` _____________________________
` Case No. IPR2018-01555
` Case No. IPR2018-01581
` Patent No. 7,848,439 B2
` _____________________________
`
` DEPOSITION OF DR. BRANIMIR VOJCIC
` Washington, D.C.
` October 3, 2019
`
`Reported by: Mary Ann Payonk
`Job No: 164179
`
`TSG Reporting - Worldwide - 877-702-9580
`
`HTC Corp., HTC America, Inc. - Ex. 1017, Page 1
`IPR2018-01555 and IPR2018-01581 (HTC and Apple v. INVT SPE)
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` B. VOJCIC
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________________________
` HTC CORPORATION, HTC AMERICA, INC.
` and APPLE INC.,
` Petitioner
` v.
` INVT SPE LLC,
` Patent Owner
` _____________________________
` Case No. IPR2018-01555
` Case No. IPR2018-01581
` Patent No. 7,848,439 B2
` _____________________________
`
` DEPOSITION OF DR. BRANIMIR VOJCIC
` Washington, D.C.
` October 3, 2019
`
`Reported by: Mary Ann Payonk
`Job No: 164179
`
`TSG Reporting - Worldwide - 877-702-9580
`
`HTC Corp., HTC America, Inc. - Ex. 1017, Page 1
`IPR2018-01555 and IPR2018-01581 (HTC and Apple v. INVT SPE)
`
`
`
` B. VOJCIC
`
`Page 2
`
` October 3, 2019
` 9:00 a.m.
`
` Deposition of DR. BRANIMIR VOJCIC, held
` at the offices of Sheppard Mullin, 2099
` Pennsylvania Avenue, N.W.,Washington, D.C.,
` pursuant to Notice before Mary Ann Payonk,
` Nationally Certified Realtime Reporter and
` Notary Public of the District of Columbia,
` Commonwealth of Virginia, and State of New
` York.
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`TSG Reporting - Worldwide - 877-702-9580
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` B. VOJCIC
` APPEARANCES:
` ON BEHALF OF HTC:
` DARREN FRANKLIN, ESQ.
` SHEPPARD MULLIN RICHTER & HAMPTON
` 333 South Hope Street
` Los Angeles, CA 90071
`
` ON BEHALF OF APPLE INC.:
` PAUL HART, ESQ.
` ERISE IP
` 5600 Greenwood Plaza Boulevard
` Greenwood Village, CO 80111
`
` ON BEHALF OF INVT SPE LLC:
` CYRUS MORTON, ESQ.
` ROBINS KAPLAN
` 800 Lasalle Avenue
` Minneapolis, MN 55402
`
` ALSO PRESENT:
` Ryan Marshall, legal video specialist
`
`TSG Reporting - Worldwide - 877-702-9580
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` B. VOJCIC
` THE VIDEOGRAPHER: All right, this
` is the start of tape labeled number 1 in 09:12
` the videotaped deposition of 09:12
` Dr. Branimir Vojcic in the US Patent and 09:12
` Trademark Office before the Patent Trial 09:12
` and Appeal Board, Case Numbers 09:12
` IPR2018-01555 and IPR2018-01581, 09:12
` US Patent Number 7,848,439. 09:12
` This deposition is being held at 09:13
` 2099 Pennsylvania Avenue Northwest, 09:13
` Washington, D.C., on October 3, 2019, at 09:13
` approximately 9:13 a.m. 09:13
` My name is Ryan Marshall from 09:13
` TSG Reporting, and I'm the legal video 09:13
` specialist. The court reporter today is 09:13
` Mary Ann Payonk, also in association 09:13
` with TSG Reporting. 09:13
` Would counsel please introduce 09:13
` yourselves and state whom you represent. 09:13
` (Whereupon, counsel placed their 09:13
` appearances on the video record.) 09:13
` THE REPORTER: I'll swear the 09:13
` witness. 09:13
`
`TSG Reporting - Worldwide - 877-702-9580
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`HTC Corp., HTC America, Inc. - Ex. 1017, Page 4
`IPR2018-01555 and IPR2018-01581 (HTC and Apple v. INVT SPE)
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` B. VOJCIC
` BRANIMIR VOJCIC, 09:13
` called as a witness, having been duly 09:13
` sworn, was examined and testified as 09:13
` follows: 09:13
` EXAMINATION 09:13
` BY MR. FRANKLIN: 09:13
` Q. Good morning. Would you kindly state 09:13
` your name for the record. 09:14
` A. Branimir Vojcic. 09:14
` Q. Is there any reason at all why you 09:14
` feel you might not be able to testify fully and 09:14
` accurately today? 09:14
` A. No. 09:14
` Q. Are you aware of any physical or 09:14
` mental conditions that could interfere with 09:14
` your ability to testify today? 09:14
` A. No. 09:14
` Q. Are you taking any prescription 09:14
` medications that could interfere with your 09:14
` ability to testify today? 09:14
` A. No, sir. 09:14
` Q. Do you have any questions about the 09:14
` procedures we will follow today? 09:14
` A. No, I don't. 09:14
`
`TSG Reporting - Worldwide - 877-702-9580
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`HTC Corp., HTC America, Inc. - Ex. 1017, Page 5
`IPR2018-01555 and IPR2018-01581 (HTC and Apple v. INVT SPE)
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` B. VOJCIC
` MR. FRANKLIN: I'm going to be 09:14
` handing you a bunch of premarked 09:14
` exhibits. I'm first handing you 09:14
` Exhibit 1001. 09:14
` (Exhibit No. 1001 was marked for 09:14
` identification.) 09:14
` BY MR. FRANKLIN: 09:14
` Q. Do you recognize Exhibit 1001? 09:14
` A. Yes, I do. 09:14
` Q. This is United States Patent Number 09:14
` 7,848,439; correct? 09:14
` A. Correct. 09:14
` MR. FRANKLIN: I'm now handing you 09:15
` Exhibit 1003. 09:15
` (Exhibit No. 1003 was marked for 09:15
` identification.) 09:15
` BY MR. FRANKLIN: 09:15
` Q. Do you recognize Exhibit 1003? 09:15
` A. Yes, I do. 09:15
` Q. This is United States Patent Number 09:15
` 6,904,293 to Li et al.; correct? 09:15
` A. That's correct. 09:15
` MR. FRANKLIN: I'm now handing you 09:15
` Exhibit 1004. 09:15
`
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`HTC Corp., HTC America, Inc. - Ex. 1017, Page 6
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` B. VOJCIC
` (Exhibit No. 1004 was marked for 09:15
` identification.) 09:15
` BY MR. FRANKLIN: 09:15
` Q. Do you recognize Exhibit 1004? 09:15
` A. Yes, I do. 09:15
` Q. This is United States Patent Number 09:15
` 7,221,680 to Vijayan et al.; correct? 09:15
` A. Correct. 09:15
` MR. FRANKLIN: I am now handing you 09:16
` Exhibit 1005. 09:16
` (Exhibit No. 1005 was marked for 09:16
` identification.) 09:16
` BY MR. FRANKLIN: 09:16
` Q. Do you recognize Exhibit 1005? 09:16
` A. Yes, I do. 09:16
` Q. This is United States Patent Number 09:16
` 6,721,569 to Hashem et al. correct? 09:16
` A. That's correct. 09:16
` MR. FRANKLIN: I am now handing you 09:16
` Exhibit 1006. 09:16
` (Exhibit No. 1006 was marked for 09:16
` identification.) 09:16
` BY MR. FRANKLIN: 09:16
` Q. Do you recognize Exhibit 1006? 09:16
`
`TSG Reporting - Worldwide - 877-702-9580
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`HTC Corp., HTC America, Inc. - Ex. 1017, Page 7
`IPR2018-01555 and IPR2018-01581 (HTC and Apple v. INVT SPE)
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` B. VOJCIC
` A. Yes, I do. 09:16
` Q. This is United States Patent Number 09:16
` 5,596,604 to Cioffi et al.; correct? 09:16
` A. Is that correct. 09:16
` MR. FRANKLIN: I'm now handing you 09:17
` Exhibit 2001. 09:17
` (Exhibit No. 2001 was marked for 09:17
` identification.) 09:17
` BY MR. FRANKLIN: 09:17
` Q. This is a copy of your declaration 09:17
` filed with the patent owner's preliminary 09:17
` response in this proceeding; is that correct? 09:17
` A. I don't recall exact name, but it's 09:17
` my first declaration I think for this. 09:17
` MR. FRANKLIN: And finally, I'm 09:17
` handing you what I'm going to be asked 09:17
` to be marked Exhibit 2101. 09:18
` (Exhibit No. 2101 was marked for 09:18
` identification.) 09:18
` BY MR. FRANKLIN: 09:18
` Q. This is a copy of your most recent 09:18
` declaration in support of patent owner's 09:18
` response in this proceeding; correct? 09:18
` A. I believe so, yes. 09:18
`
`TSG Reporting - Worldwide - 877-702-9580
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`HTC Corp., HTC America, Inc. - Ex. 1017, Page 8
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` B. VOJCIC
` Q. The '439 patent relates to adaptive 09:18
` modulation and coding in an OFDM system; right? 09:18
` A. That's one of the main aspects, 09:18
` correct. 09:18
` Q. The '439 patent does not purport to 09:18
` have invented adaptive modulation and coding; 09:18
` right? 09:19
` A. That's correct. 09:19
` Q. The '439 patent does not purport to 09:19
` be the first example of adaptive modulation and 09:19
` coding in an OFDM system; right? 09:19
` A. That's correct. 09:19
` Q. Adaptive modulation and coding 09:19
` entails estimating channel quality and then 09:19
` using that channel estimation in deciding 09:19
` modulation and coding parameters; right? 09:19
` A. That's generally correct. 09:19
` Q. Before the priority date of the '439 09:19
` patent it was known that a person could perform 09:19
` that channel estimation on individual 09:19
` subcarriers and then select modulation and 09:19
` coding parameters individually for those 09:19
` subcarriers; right? 09:19
` A. That's correct. 09:19
`
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` B. VOJCIC
` Q. Also known before the priority date 09:19
` of the '439 patent was performing adaptive 09:19
` modulation and coding on a sub-band basis; 09:19
` right? 09:20
` A. That's correct, if you -- if you 09:20
` assume that sub-band is as it is defined in the 09:20
` '439 patent as a group of subcarriers. 09:20
` Q. Before the priority date of the '439 09:20
` patent it was known that a person could 09:20
` individually select modulation and coding 09:20
` parameters for each sub-band; right? 09:20
` A. That's correct. 09:20
` Q. According to the '439 patent, the 09:20
` main addition that the '439 patent makes to the 09:20
` prior art is that a person can select and apply 09:20
` modulation and coding parameters on a 09:20
` per-sub-band group basis; right? 09:20
` A. That's what the patent clearly 09:21
` states, that that's one of the main 09:21
` enhancements relative to the prior art. 09:21
` Q. A sub-band group in the '439 patent 09:21
` is a group of sub-bands; correct? 09:21
` A. That's correct. 09:21
` Q. The '439 patent says a person can do 09:21
`
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` B. VOJCIC
` modulation and coding per sub-band group; 09:21
` right? 09:21
` A. That's correct. 09:21
` Q. In some embodiments the '439 patent 09:21
` suggests having sub-band groups where the 09:21
` sub-bands are contiguous; right? 09:21
` A. That's correct. 09:21
` Q. In other embodiments, the '439 patent 09:21
` suggests having sub-band groups where the 09:21
` sub-bands are noncontiguous; right? 09:21
` A. That's correct. 09:21
` Q. You have heard of a sub-band group 09:21
` being called coherent when the sub-bands are 09:21
` contiguous or close together in frequency; 09:21
` right? 09:22
` A. Yes, I heard that term, not sure that 09:22
` it's in '439 or from some other patent, but I 09:22
` did. 09:22
` Q. And you've heard of a sub-band group 09:22
` being called diverse when the sub-bands are 09:22
` noncontiguous or spaced far apart in frequency; 09:22
` right? 09:22
` A. That's correct, and it's meant really 09:22
` frequency diverse. 09:22
`
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`HTC Corp., HTC America, Inc. - Ex. 1017, Page 11
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` B. VOJCIC
` Q. The '439 patent discloses both 09:22
` coherent sub-band groups and diverse sub-band 09:22
` groups; right? 09:22
` A. That's correct. 09:22
` MR. HART: Object. That 09:22
` mischaracterizes his prior testimony. 09:22
` Q. Li discloses an OFDM system; right? 09:22
` A. That's correct. 09:22
` Q. Li discloses the use of subcarriers; 09:23
` right? 09:23
` A. That's correct. 09:23
` Q. Li also discloses groups of 09:23
` subcarriers which Li calls clusters; right? 09:23
` A. That's correct. 09:23
` Q. Take a look at figure 1A of Li. In 09:23
` figure 1A, the cluster 102 is shown as a group 09:23
` of four subcarriers; right? 09:23
` A. Oh, sorry, just a moment. So figure 09:23
` 1A? 09:23
` Q. Yes. 09:23
` A. Oh, yeah. Okay. 09:23
` Q. In figure 1A the cluster 102 is shown 09:23
` as a group of four subcarriers; right? 09:23
` A. That's correct in this illustration. 09:24
`
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` B. VOJCIC
` Q. And in one embodiment of Li there are 09:24
` 128 clusters of 512 subcarriers with each 09:24
` cluster including four consecutive subcarriers; 09:24
` correct? 09:24
` A. I don't recall. 09:24
` Q. Li discloses grouping the clusters 09:24
` together; right? 09:24
` A. I don't recall. Li has many 09:24
` different embodiments. It has some embodiments 09:24
` where subcarriers are together, but I recall 09:24
` that what I analyzed in my response is really 09:24
` frequency diverse clusters in Li. I think 09:25
` that's what petition was relying on. 09:25
` Q. Let's take a look at figure 6 of Li. 09:25
` Figure 6 shows four groups of sub -- excuse me, 09:25
` four groups of clusters; right? 09:25
` A. That's correct. 09:25
` Q. Each cluster group includes multiple 09:25
` clusters; right? 09:25
` A. That's correct. 09:25
` Q. So Li teaches subcarriers; correct? 09:25
` A. Correct. 09:25
` Q. Li teaches a group of subcarriers 09:25
` called a cluster; right? 09:25
`
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` B. VOJCIC
` A. Correct. 09:25
` Q. And Li teaches groups of clusters; 09:25
` right? 09:25
` A. That's correct. 09:25
` Q. Li teaches reporting SINR for each 09:26
` cluster; right? 09:26
` A. That's correct. 09:26
` Q. What do you understand SINR to be? 09:26
` A. Signal-to-interference-plus-noise 09:26
` ratio. 09:26
` Q. SINR is a channel estimate that is 09:26
` reported for each cluster; right? 09:26
` A. Sorry, I missed the question. 09:26
` Q. SINR is a channel estimate that is 09:26
` reported for each cluster; right? 09:26
` A. In some of the embodiments, yes, yes. 09:26
` Q. Those channel estimates are reported 09:26
` as a group; right? 09:26
` A. What do you mean, those channel 09:26
` estimates are reported as a group? 09:26
` Q. The channel estimates that are taught 09:26
` in Li are reported to the base station as a 09:26
` group of channel estimates; right? 09:26
` A. Which embodiment are you referring 09:26
`
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` B. VOJCIC
` to? 09:26
` Q. Let's take a look at figure 7 of Li. 09:26
` In figure 7, the channel estimates, the SINR 09:27
` values are reported as a group to the base 09:27
` station; right? 09:27
` A. No, I wouldn't phrase it that way. 09:27
` At least that's confusing language to me. For 09:27
` the whole group of clusters, channel 09:27
` measurement is reported for each cluster in the 09:27
` group. That would be, I guess, accurate 09:27
` description. 09:27
` Q. You would say that the channel 09:27
` estimates for each cluster in a cluster group 09:27
` are reported as a group to the base station; 09:27
` right? 09:27
` A. No, I don't know what you mean, they 09:27
` are reported as a group. They are reporting 09:27
` each SNR for each group is reported as a part 09:28
` of report for the whole group. So in other 09:28
` words, group ID is reported that says, okay, 09:28
` I'm reporting for a group ID where that defines 09:28
` which clusters are involved in some way and 09:28
` then for each cluster separately SINR is 09:28
` reported. So there is no SNR per group or for 09:28
`
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` B. VOJCIC
` a group. It's for each cluster individually. 09:28
` Q. So -- 09:28
` A. It's maybe just the language clarity. 09:28
` Q. So in figure 7 of Li the channel 09:29
` estimates for the individual clusters in each 09:29
` group are grouped together as they are reported 09:29
` to the base station? 09:29
` A. That's correct. 09:29
` Q. In figure 7 the group ID is sent, 09:29
` followed by the SINR values for all the 09:29
` clusters in the group; right? 09:29
` A. That's correct. 09:29
` Q. Li sends the group ID instead of 09:29
` identifying each cluster in the group in order 09:29
` to reduce the feedback overhead; right? 09:29
` A. That's correct. 09:29
` Q. Li also discloses that the SINR 09:29
` values that are reported could take the form of 09:29
` an index to indicate a particular coding and 09:29
` modulation rate that the subscriber desires to 09:29
` use; right? 09:29
` A. I don't recall if he used exact 09:29
` wording that you are mentioning, but he did say 09:30
` that SINR could be related to modulation and 09:30
`
`TSG Reporting - Worldwide - 877-702-9580
`
`HTC Corp., HTC America, Inc. - Ex. 1017, Page 16
`IPR2018-01555 and IPR2018-01581 (HTC and Apple v. INVT SPE)
`
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` B. VOJCIC
` coding scheme, I just don't recall whether it 09:30
` was the same wording that you used. 09:30
` Q. Let's take a look at column 8, lines 09:30
` 1 through 3. Li states: 09:30
` "By using an appropriate SINR 09:30
` indexing scheme, an SINR index may 09:30
` also indicate a particular coding and 09:30
` modulation rate that a subscriber 09:30
` desires to use." 09:30
` Did I read that correctly? 09:30
` A. I couldn't find it. Which lines are 09:30
` you saying? From column 8? 09:30
` Q. Column 8, lines 1 through 3. 09:30
` A. Oh, sorry. I was looking at the 09:31
` wrong patent. 09:31
` Q. At column 8, lines 1 through 3, Li 09:31
` states that: 09:31
` "By using an appropriate SINR 09:31
` indexing scheme, an SINR index may 09:31
` also indicate a particular coding and 09:31
` modulation rate that a subscriber 09:31
` desires to use." 09:31
` Did I read that correctly? 09:31
` A. Yes, that's correct. 09:31
`
`TSG Reporting - Worldwide - 877-702-9580
`
`HTC Corp., HTC America, Inc. - Ex. 1017, Page 17
`IPR2018-01555 and IPR2018-01581 (HTC and Apple v. INVT SPE)
`
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` B. VOJCIC
` Q. Li is disclosing that the SINR values 09:31
` that are reported could take the form of an 09:31
` index to indicate a particular coding and 09:31
` modulation rate that the subscriber desires to 09:31
` use; right? 09:31
` A. That's correct. 09:31
` Q. And you're familiar with the Vijayan 09:31
` reference; right? 09:32
` A. Yes, I am. 09:32
` Q. In Vijayan, a sub-band means the same 09:32
` thing as a subcarrier in the '439 patent; 09:32
` right? 09:32
` A. From memory, I believe so. 09:32
` Q. And in Vijayan, a sub-band group 09:32
` means the same thing as a sub-band in the '439 09:32
` patent; right? 09:32
` A. I believe so. Let me double check. 09:32
` Is there a specific place in Vijayan that you 09:33
` used for this definition the sub-band group 09:33
` consists of multiple subcarriers? 09:33
` Q. Let's take a look at figure 9B of 09:33
` Vijayan. 09:33
` A. I'm there. 09:33
` Q. You see that it has the tag "sub-band 09:33
`
`TSG Reporting - Worldwide - 877-702-9580
`
`HTC Corp., HTC America, Inc. - Ex. 1017, Page 18
`IPR2018-01555 and IPR2018-01581 (HTC and Apple v. INVT SPE)
`
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` B. VOJCIC
` group" on the left side? 09:33
` A. Yes, I do. 09:33
` Q. Does this refresh your recollection 09:33
` that a sub-band group means the same thing as a 09:33
` sub-band in the '439 patent? 09:33
` A. It sounds plausible, I just don't 09:34
` recall. I mean, if you just look at figure 9, 09:34
` could be -- so sub-band group. Hold on. Let 09:34
` me just think about it. There is nothing in 09:34
` the description of figure 9B that defines 09:35
` sub-band group, just mentions sub-band groups. 09:35
` But there may be somewhere else they define 09:35
` that, I just -- I think it's correct, just 09:35
` don't want to say from memory. Yeah, yeah, it 09:35
` does -- it does define that group is a set of 09:39
` sub-bands. I mean, Vijayan, yeah. 09:39
` Q. So in figure 9B of Vijayan, does a 09:39
` sub-band group correspond to a sub-band as used 09:40
` in the '439 patent? 09:40
` A. Yes, it could be read that way. 09:40
` Q. In Vijayan, a sub-band group includes 09:40
` multiple Vijayan sub-bands or multiple 09:40
` subcarriers in the terminology of the '439 09:40
` patent; right? 09:40
`
`TSG Reporting - Worldwide - 877-702-9580
`
`HTC Corp., HTC America, Inc. - Ex. 1017, Page 19
`IPR2018-01555 and IPR2018-01581 (HTC and Apple v. INVT SPE)
`
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` B. VOJCIC
` A. That's correct. 09:40
` Q. Now, in figure 9B of Vijayan, the 09:40
` Y axis is labeled "sub-band group"; right? 09:40
` A. That's correct. 09:40
` Q. And the Y axis is also numbered 09:41
` vertically 1 through 6; right? 09:41
` A. That's correct. 09:41
` Q. In symbol period 1 of mode 1 there 09:41
` are four Vijayan sub-band groups or four 09:41
` sub-bands in the terminology of the '439 09:41
` patent; right? 09:41
` A. That's correct. 09:41
` Q. In symbol period 5 of mode 2 there 09:41
` are also four Vijayan sub-band groups or four 09:41
` sub-bands in the terminology of the '439 09:41
` patent; right? 09:41
` A. Correct. 09:41
` Q. In figure 9B, each of mode 1 and mode 09:41
` 2 includes multiple Vijayan sub-band groups or 09:41
` multiple sub-bands in the terminology of the 09:41
` '439 patent; right? 09:41
` A. Sorry, could you repeat the question, 09:41
` please? 09:41
` Q. Yes. In figure 9B, each of mode 1 09:42
`
`TSG Reporting - Worldwide - 877-702-9580
`
`HTC Corp., HTC America, Inc. - Ex. 1017, Page 20
`IPR2018-01555 and IPR2018-01581 (HTC and Apple v. INVT SPE)
`
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` B. VOJCIC
` and mode 2 includes multiple Vijayan sub-band 09:42
` groups or multiple sub-bands in the terminology 09:42
` of the '439 patent; right? 09:42
` A. Correct. 09:42
` Q. Please look at column 14 of Vijayan. 09:42
` Starting at line 41, Vijayan says: 09:42
` "Figure 9B shows assignment of 09:42
` slots in a superframe for one code 09:42
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