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` UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MICROSOFT CORPORATION, )
`
`) Nos.
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`) IPR2018-01605,
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`Petitioner, ) IPR2018-01606,
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`) and
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`) IPR2018-01607
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`)
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`vs. ) Patent No.
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`) 7,620,800
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`)
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`DIRECTSTREAM, LLC, )
`
`Patent Owner. )
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`)
`
`-----------------------------)
`
`VIDEOTAPED DEPOSITION OF HAROLD S. STONE, Ph.D.
`
`Bellevue, Washington
`
`Thursday, June 13, 2019
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`Reported by:
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`Connie Recob, CCR 2631, RMR, CRR
`
`JOB NO. 160993
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`TSG Reporting - Worldwide
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`877-702-9580
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2063, p. 1
`
`

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`A P P E A R A N C E S:
`
` SIDLEY AUSTIN
` Attorneys for Petitioner
` 1501 K Street NW
` Washington, D.C. 20005
` BY: JOSEPH MICALLEF, ESQ.
`
` JANIK VINNAKOTA
` Attorneys for Patent Owner
` 8111 LBJ Freeway
` Dallas, Texas 75251
` BY: SEAN HSU, ESQ.
` DONALD PUCKETT, ESQ.
`
`ALSO PRESENT:
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` JOHN REIDT - VIDEOGRAPHER
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` June 13, 2019
` 9:07 a.m.
`
` Deposition of HAROLD S. STONE,
`Ph.D., held at the offices of Perkins Coie,
`10885 Northeast Fourth Street, Suite 700,
`Bellevue, Washington, before Connie Recob,
`CCR 2631, RMR, CRR, a Notary Public of the
`State of Washington.
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` STONE, Ph.D.
` THE VIDEOGRAPHER: We're on the
` record. The time on my video monitor is
` 9:07 a.m. This is the videotaped portion
` in the deposition of Dr. Harold S. Stone,
` Ph.D.
` This deposition is being recorded
` this 13th day of June, 2019. All counsel
` present will be noted on the transcript.
` The court reporter will now swear in the
` witness and you may proceed.
`HAROLD S. STONE, Ph.D.,
`called as a witness, having been duly sworn by
`a Notary Public, was examined and testified as
`follows:
`EXAMINATION
`BY MR. HSU:
` Q. Good morning -- excuse me.
` Good morning, Dr. Stone. Thank you
`for joining us today. So we're doing an
`additional deposition, and I think last time we
`went over some of the, kind of ground rules,
`but just since it's been a -- about two weeks,
`I'll go through them again if you'll indulge me
`for a little bit.
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` STONE, Ph.D.
` So you recall that there's a PTAB
`regulation on depositions that until we pass
`the witness and basically end our side of the
`questioning, there's a regulation restricting
`conversations between you and counsel on the
`substance of the conversations in the
`deposition.
` Do you recall that?
` A. I do recall that.
` Q. Okay. All right. And so I think
`for logistics purposes, we're technically
`scheduled for two days. We'll kind of play it
`by ear and see how far we get today, but in the
`off chance we do have to go a little bit longer
`and it goes into a second day, that will span
`the -- I guess the period of our questioning.
`So even though we will end for the day, we
`haven't yet concluded the questioning.
` Does that kind of make sense?
` A. That's all right.
` Q. So for the evening part, technically
`the questioning is still open from our side.
` A. That's right, and I can't discuss
`the case with counsel.
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`TSG Reporting - Worldwide 877-702-9580
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`2
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2063, p. 2
`
`

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` STONE, Ph.D.
` Q. Right, right.
` A. I understand.
` Q. Yeah, so I'm just asking that you
`continue that through the evening if we need to
`go into the second day.
` A. I understand.
` Q. Okay. And also as last time, any
`time that you need to take a break, just feel
`free to let me know. If we're in the middle of
`a line of questioning, I will ask that I try to
`finish it up within a couple questions or so,
`so I may not be able to go onto break
`immediately, but I'll try to wrap it up as soon
`as I can. But yes, please let me know if you
`need to go on a break.
` And then if there's any questions
`that I ask that you're unclear about, feel free
`to ask for clarification. And then I think
`like last time, counsel may have some
`objections, so just to keep the transcript
`clear, try to not talk over each other and I'll
`try to do likewise.
` And then one other quick note, since
`it's being transcribed, the yeses are
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` STONE, Ph.D.
`preferable to uh-huhs or obviously nonverbal.
`So I don't know if we went over that last time.
` A. I don't know, but I will answer
`verbally so it's on the record.
` Q. Yeah. Much appreciated.
` Okay. So I guess let's -- let's
`start with -- so did you have a chance to look
`at the petitions in the IPRs for 1601 through
`1603 and then 1605 through 1607?
` Have you seen any of the petitions?
` A. I have not read any of the
`petitions. I don't recognize them by those
`numbers. I recognize them by the patent
`numbers.
` Q. Patent number. Okay. So one thing
`I just wanted to clear up. I think we touched
`on it earlier.
` So in terms of the number of
`declarations you prepared, was it two
`declarations from your perspective, one for
`each of the two patents?
` A. I prepared three declarations that I
`signed.
` Q. Right.
`
`Page 9
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` STONE, Ph.D.
` A. Okay.
` Q. Yes. So yes, the last time was
`the -- the one ending in I think '687, and then
`the two that we're here for today is '324 and
`'800. Does that sound familiar?
` A. That's correct.
` Q. Okay. So I just wanted to clear up
`that since you haven't seen the -- the way that
`your declarations were used in the petition,
`that there were -- there ended up being six, I
`guess, declarations from you, and it sounds
`like three of them for the '324 were
`essentially duplicates with maybe some
`formatting or cover document changes.
` But as far as you're aware, were you
`involved in that at all?
` A. I wasn't involved in that. I've
`never seen them.
` Q. Okay. Okay. But I guess from your
`recollection, you've got two declarations that
`we're discussing here today one for the '324
`and one for the '800; is that correct?
` A. That's correct.
` Q. Let me see if... okay. So let me
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` STONE, Ph.D.
`show you one of the declarations. Let me get
`my sea legs here for a little bit. This should
`have already been designated as 1003, and this
`is in the case IPR 2018-01601. And I -- I
`guess for recordkeeping purposes, we're going
`to refer to this declaration, so the '324
`declaration, we're going to refer to it as the
`1003 exhibit.
` And my understanding is, and I'll
`just state on the record that this declaration
`in substance is the same as the ones for 1602
`and 1603. And then there's the second
`declaration that you prepared. Since it's also
`labeled Exhibit 1003 on the IPR proceedings,
`we're going to add a little A to that one, so
`that one will be 1003a.
` A. I understand that, but I can't
`attest to that -- this being the same as 1601
`and 02 and 03. I've never seen those
`documents, so I don't -- I can't -- I don't
`know.
` Q. Okay. I guess we can do this.
`We'll stipulate that --
` MR. HSU: I think, Counsel, can we
`
`TSG Reporting - Worldwide 877-702-9580
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`3
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2063, p. 3
`
`

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` STONE, Ph.D.
` just stipulate to the witness that those
` are supposed to be identical in substance?
` MR. MICALLEF: I believe they are
` identical.
` MR. HSU: Okay.
`BY MR. HSU:
` Q. Yeah. And I've got paper copies if,
`you know, during one of the breaks, just for
`your own edification, if you want to flip
`through it, we can do that then.
` A. Okay. I don't think I need to do
`that, but I'll reserve judgment and I'll call
`for them as -- if I see a need for it.
` Q. Okay. Sure. Okay. So this one is
`Exhibit 1003 for the '324 patent, and on Page 2
`here, do you see the signature there?
` A. I see that.
` Q. Is -- is that your signature?
` A. That is.
` Q. Okay. And do you recall, I guess,
`the preparation process for this declaration?
` A. To a limited extent because it's so
`long ago.
` Q. Yeah. I guess kind of getting into
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` STONE, Ph.D.
`some of the details, do you recall about how
`long ago it was that you would have started on
`this?
` A. My recollection is that it was on --
`in the spring of 2018 at some point. I
`don't -- it may have been June. It may have
`been May. I don't -- I really don't remember.
` Q. Okay. A ballpark is fine.
` And so do you see how the -- next to
`your signature, there's a date, September 4th,
`2018?
` A. I see that, yes.
` Q. Okay. So kind of a rough ballpark,
`would you say that it was about six months or
`so from when you started to when you completed
`the declaration?
` A. It could be three to six months,
`something on that order.
` Q. Okay. And do you have a ballpark
`rough estimate of how long you spent on the
`declaration?
` A. I -- I just -- it's been so long, I
`don't recall.
` Q. Okay. So earlier you mentioned that
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` STONE, Ph.D.
`in total you had prepared three declarations
`for the -- I guess the concurrent IPRs.
` Do you recall if you spent roughly
`the same amount of time, more time or less time
`on this declaration versus the other two?
` A. It's -- I -- I'd have to speculate
`on that. I -- I don't really recall. It could
`be more or less. I don't really remember.
` Q. Okay. I'm going to turn really
`quick to -- here it is.
` So this is Page 6 of your report.
`In Paragraph 12, there's a reference to
`Attachment B to the petition. And do you see
`where that is?
` A. I see that.
` Q. It's kind of the -- the last part of
`that Paragraph 12.
` Do you recall kind of assembling a
`list of documents that you had looked at?
` A. I -- I prepared all of the exhibits
`and I -- the answer is, I do recall preparing
`the exhibits.
` Q. Okay. And I can pull that up in a
`little bit, but just kind of logistics on the
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` STONE, Ph.D.
`preparation of those exhibits, do you recall if
`those were provided to you, or did you look for
`them on your own or was there kind of a mix
`between the two?
` A. There was a mix between the two.
`Every exhibit I used, I -- I'm relying on
`because I understand it and use it regardless
`of the source. Okay.
` Q. Yeah. And I guess -- so kind of
`asking from a different angle: So you did have
`an opportunity to look for sources or exhibits
`that you felt were important to this IPR
`declaration?
` A. Would you repeat your question?
` Q. Sure. Yeah.
` So asking from a different angle:
`You did have an opportunity to look for sources
`or exhibits that you felt were important to
`this IPR declaration?
` A. Yes, I did a search and I found
`exhibits.
` Q. And that -- did you feel that you
`had enough time to look for supporting
`documents that you would want to or would you
`
`TSG Reporting - Worldwide 877-702-9580
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`4
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2063, p. 4
`
`

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` STONE, Ph.D.
`have wanted more time?
` A. I had sufficient time.
` Q. And were there any documents that
`you wanted to look at or wanted to locate but
`were not able to in the course of preparing for
`this declaration?
` A. Yeah, there may have been. I just
`don't recall.
` Q. I guess as you sit here today and
`kind of recalling the preparation of your
`declaration, do you feel that there's any topic
`or subject matter that you needed additional
`time to research?
` A. No. I'm satisfied that I had
`sufficient time to research what I needed.
` Q. And since you signed the declaration
`on September 4th, 2018, have you had a chance
`to review the declaration again?
` A. I have.
` Q. And I guess after that signature
`date, did you make any additional edits or
`anything to the declaration after you signed
`it?
` A. I did not.
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` STONE, Ph.D.
` Q. And since that -- the date that you
`signed it, have you identified any mistakes or
`areas of the declaration that you would want to
`correct right now?
` A. There may be a typo or two. There's
`a broken reference, but these were all minor.
` Q. Sure. Yeah. So I guess in terms of
`subject matter, there's nothing substantive
`that you feel you -- you need to correct right
`now?
` A. I do not need to correct the subject
`matter.
` Q. And then for the preparation of your
`declaration, were there -- excluding counsel,
`was there anyone else who assisted you in the
`preparation of the declaration? This could be
`helping you with typing or locating references
`or gathering materials?
` A. No, no.
` Q. And do you recall in the course of
`preparing your declaration, did you have
`multiple drafts or did you kind of have one
`working draft that you continually revised?
` A. I had one living, working draft.
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` STONE, Ph.D.
` Q. And other than the documents that --
`that you -- either that you collected or that
`were provided to you to review, did you rely on
`any other sources outside of those documents,
`such as conversations with people or any
`materials that would not have been in printed
`form?
` A. Everything I relied on is indicated
`in the -- in the declaration. I don't recall
`relying on any conversations.
` What -- what else did you ask about?
` Q. Oh, I guess just if there were any
`other sources that may not be in written form,
`so it may just be something that's difficult to
`kind of capture in a references considered type
`of table.
` A. If I had relied on anything else, it
`would be in this declaration. I don't recall
`having anything in the declaration regarding
`these other kinds of sources.
` Q. Okay. And that's fair. I'm just
`kind of covering bases on your preparation
`process.
` So in terms of, other than counsel,
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` STONE, Ph.D.
`other individuals that you may have spoken to
`in order to prepare for your declaration, you
`don't recall speaking to anyone; is that
`correct?
` A. That's correct. I spoke to no one
`regarding the preparation of this declaration
`except possibly with counsel.
` Q. Right, right. Yeah.
` And so there were a couple names
`that I wanted to run through with you and
`then -- you may recall this from last time, but
`specifically for this declaration 1003 and then
`also the declaration for the '800 patent.
` So kind of treating those two in
`tandem, do you recall speaking with a gentleman
`by the name of Stephen Trimberger?
` A. I don't know Stephen Trimberger. I
`never spoke with him.
` Q. What about an individual named, I
`think it's -- actually I forget his first name.
`Do you know a gentleman Mr. Hauck?
` A. Can you spell that.
` Q. Yeah, Scott Hauck, H-A-U-C-K?
` A. I don't know that individual. I
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`TSG Reporting - Worldwide 877-702-9580
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`5
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2063, p. 5
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`

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` STONE, Ph.D.
`never spoke with him.
` Q. And then how about a gentleman, last
`name Halverson?
` A. Can you spell that? H-A-L-B, is
`that...
` Q. Yes, H-A-L-V-E-R-S-O-N.
` A. I don't know that individual.
` Q. So then safe to say you don't recall
`speaking to any of those individuals either --
` A. I don't recall speaking to any of
`those individuals.
` Q. -- to prepare for this declaration?
` And then did you speak to anybody at
`Microsoft as part of preparing your
`declaration?
` A. No.
` Q. How about anyone at the company
`Xilinx?
` A. Yep.
` Q. Xilinx. It's X-I-L-I-N-X.
` A. Oh, Xilinx?
` Q. Yes.
` A. I'm sorry. No, I did not speak to
`anybody at Xilinx.
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` MR. HSU: Joe, I've got a -- maybe a
` procedural question on, if you have a
` preference on how we do this. So I was
` trying to think how to grab the Exhibit B
` from the petition.
` I could just put the whole paper in,
` and whether you want to put a sticker on
` it. I mean, it -- it's part of the record.
` MR. MICALLEF: Why would you --
` MR. PUCKETT: It's probably --
` MR. HSU: Yeah.
` MR. MICALLEF: It's already been --
` MR. PUCKETT: Yeah, yeah. Yeah.
` MR. MICALLEF: No.
` MR. HSU: Yeah. Okay. So I just
` wanted to verify that you're okay if I
` don't sticker this and we just use the
` paper.
` MR. MICALLEF: Okay.
`BY MR. HSU:
` Q. All right. So I'm going to show you
`another exhibit, and this is Paper 1 in the
`IPR -- Paper No. 1 in the IPR proceeding
`2018-01601.
`
`Page 21
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` STONE, Ph.D.
` Do you see that?
` A. I see that.
` Q. Okay. So I believe it starts on
`Page 89 or somewhere thereabouts. Actually,
`no, it's 87 of 92. Actually I'll start on Page
`86. It's listed Attachment B, "List of
`Evidence and Exhibits Relied Upon in Petition."
` Do you see that page?
` A. I see it. This is the one you're
`presenting to me on the --
` Q. Yes.
` A. Okay. I see that page, yes.
` Q. And it's about five, six pages if
`you want to kind of scroll through the list
`there. I think there's in total a list of
`about 70 items -- or, I'm sorry, 56 items or
`something.
` But do you recall the -- kind of
`generally the listing of items in there? Do
`you recall reviewing these as part of preparing
`your declaration?
` A. Let me look through the list that's
`here.
` Q. Yeah, take your time.
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` STONE, Ph.D.
` A. I haven't seen this list before
`today.
` Q. Okay.
` A. Okay. On this list, the exhibit
`numbers go up to 1070.
` Q. That's right. Yes.
` A. Okay.
` Q. Yes, 1070.
` A. I have never seen any of the
`material with exhibit numbers 1065 to 1070.
` Q. Okay.
` A. To the best of my knowledge, I've
`seen all the others.
` Q. Okay. And if you can take a look at
`this page, the listing for Exhibit No. 1014, do
`you see it's U.S. Patent 6,434,687 to
`Huppenthal?
` A. Yes, I see it.
` Q. So do you recall that that's the
`other patent that you prepared a declaration
`on?
` A. Are you asking is this one that I
`prepared a declaration on?
` Q. Yes. Does that -- I'm asking if you
`
`TSG Reporting - Worldwide 877-702-9580
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`6
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2063, p. 6
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`

`

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` STONE, Ph.D.
`recognize that patent number as being the same
`one that you had prepared another declaration
`for?
` A. Yes, I do.
` Q. And so as part of preparing these
`two declarations for the '324 and the '800
`patent, do you recall reviewing the '687
`patent?
` A. I do.
` Q. And how about the file history for
`the '687 patent?
` A. I have reviewed the file history for
`the '687 patent. If you're asking that, the
`answer is yes.
` Q. And do you recall if you relied on
`it at all for your declaration for the '324 or
`the '800 patent? And I -- it's -- it is a
`little bit, you know, hard to separate because
`it sounds like you were probably preparing the
`three declarations maybe simultaneously.
` But just to kind of think about the
`file history for the '687, do you recall if you
`used that in preparing the '324 and the '800
`patent declarations?
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` A. I'm looking at my declaration for
`the '324 patent.
` Q. Okay. That's fine. That -- so that
`should be a paper copy of this Exhibit 1003.
` And actually, at the risk of
`inundating you with paper, I'm going to go
`ahead and also enter Exhibit 1003a. This is
`the declaration for the '800 patent, and
`then -- I don't know if you have a paper copy
`of that as well.
` A. I do. I do.
` Q. I've got a copy here as well if you
`want to take a look at that.
` A. Okay. I will.
` MR. MICALLEF: And the question was
` whether he relied on the '687 prosecution
` history --
` MR. HSU: Yes. Yeah.
` MR. MICALLEF: -- for purposes of
` the '324?
` MR. HSU: Right.
` MR. MICALLEF: Okay.
`BY MR. HSU:
` Q. I guess while you're looking, if you
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` STONE, Ph.D.
`want to take a look for the parent patents for
`the '687 patent, if you recall looking at those
`or the file history for those as well.
` MR. MICALLEF: Can we do one
` question at a time?
` MR. HSU: Sure. I just figured
` since he was flipping. Yeah, I'm happy to
` break it up.
` MR. MICALLEF: Yeah.
` THE WITNESS: Okay. I completed
` looking at the material in the '324
` declaration regarding the file history. I
` did not look at the file history of the
` '687 and I did not rely on it in the
` preparation of this declaration.
`BY MR. HSU:
` Q. Okay.
` A. Okay. I'll look at the '800 patent
`now.
` Q. Okay.
` A. In the '800 patent declaration, I
`did not rely on the file history of the '687
`patent.
` Q. How about the parent patents for the
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`'687 patent? Do you recall looking at those as
`part of preparing these declarations?
` A. I do recall looking through the
`declaration. What's your question though?
` Q. Sorry. So the '687 patent, do you
`recall that there is, I guess, two parents
`patents?
` A. I do recall.
` Q. And do you recall looking at those
`as part of preparing the '324 and the '800
`declarations?
` A. I do.
` Q. Okay. And I didn't recall seeing
`that listed on your Exhibit B. Do you remember
`if you had that listed in Exhibit B?
` A. I did not.
` Q. Okay. And do you recall why you
`would have left that off?
` A. I did not rely on them.
` Q. Okay. So you may have reviewed it,
`but it did not influence any of the opinions.
`You didn't rely on it for any of the opinions
`in your declarations; is that correct?
` A. That's correct.
`
`TSG Reporting - Worldwide 877-702-9580
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2063, p. 7
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`

`

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` Q. Okay. Do you recall looking at the
`file histories for those parent patents as
`well?
` A. For those patents?
` Q. Yes.
` A. I did not.
` Q. Okay. Really quick, if you could
`turn with me, let me get back to Exhibit 1003,
`on Page 27 in Paragraph 61, as kind of a
`procedural cleanup, okay. So it should be on
`the iPad as well if you need it there.
` MR. HSU: And Joe, if you can see
` that. It should be Paragraph 61.
` THE WITNESS: Yes. Just to give me
` some context, it says --
`BY MR. HSU:
` Q. Yes.
` A. -- "This petition challenges the
`following claims."
` Q. Yes.
` A. Okay. I'm there.
` Q. So the statement is referencing a
`singular petition, and so just to, I guess,
`again kind of reiterate in the record, your
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`understanding when you were preparing the
`declaration here for the '324, that was for the
`petitions, petition or petitions relating to
`that '324 patent; is that correct?
` A. That's correct.
` Q. Okay. And so the -- the reference
`there ultimately should point to however many
`IPR petitions there are on the '324 patent; is
`that correct?
` A. That's correct.
` Q. All right. And then the same for
`the '800 patent. I believe it's going to be in
`the same paragraph number. Let me see. No.
` A. Oh, here.
` Q. It is not the same paragraph number.
`It's Page 23, Paragraph 53.
` A. Again, this reads: "This petition
`challenges the following claims."
` Q. Okay. And so your understanding was
`that your declaration was for whatever
`petitions related to the '800 patent, and
`that's the petition that you're referencing
`there?
` A. That's correct.
`
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` STONE, Ph.D.
` Q. Okay. Then since preparing your
`declaration, are you aware that the patent
`owner has filed a preliminary response in both
`of the -- or I guess all six of the IPRs that
`your declaration was entered into?
` A. I guess I'm aware, but I have not
`seen it.
` Q. Okay. That -- that answers my
`follow up.
` Then are you also aware that there
`is an institution decision from the Patent
`Trial and Appeal Board for those IPRs?
` A. I am aware.
` Q. And have you had a chance to review
`that institution decision?
` A. I have not seen it.
` Q. Okay. So as you're sitting here
`right now, you're not aware of any, I guess,
`rebuttal arguments or any determinations
`regarding the validity of your opinions; is
`that correct?
` A. I -- I have not -- I don't know
`those.
` Q. So my recollection was that you
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`participated in a number of other IPRs in other
`unrelated cases; is that right?
` A. That's correct.
` Q. And my recollection is also that in
`those IPRs, you submitted declarations; is that
`right?
` A. That's correct.
` Q. And were you deposed in all of
`those?
` A. Yes. Every declaration submitted, I
`was deposed.
` Q. Okay. And in preparation for your
`depositions in those cases, do you recall if
`you reviewed the preliminary response or the
`board institution decisions in those cases
`before your deposition?
` A. I don't recall in every case. I
`believe in at least some I had.
` Q. And comparing that experience
`with -- with this case here, do you feel that
`the preliminary response or the board decisions
`would be something that you would have wanted
`to review as part of your preparation for this
`deposition?
`
`TSG Reporting - Worldwide 877-702-9580
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`8
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`PATENT OWNER DIRECTSTREAM, LLC
`EX. 2063, p. 8
`
`

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` A. It's possible. Since I haven't seen
`it, I don't know.
` Q. Do you recall about how long you --
`you've spent preparing for this deposition?
` A. Yes.
` Q. And do you have a ballpark estimate
`of how long that was?
` A. About three days.
` Q. Three days, okay.
` And in preparing for this
`deposition, did you meet with anyone other than
`counsel?
` A. No.
` Q. And excluding counsel, did you speak
`with anyone to prepare for this deposition,
`excluding counsel?
` A. No.
` Q. And in preparing for this
`deposition, other than the materials that we
`went through in that Exhibit B in the Paper No.
`1 if you recall, other than those listed there
`and your declarations, have you reviewed any
`other materials to prepare for this deposition?
`Let me see if I can ask that in maybe a little
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`bit more succinct way.
` Setting aside your declaration and
`those materials listed in Exhibit B, have you
`looked at any other materials to prepare for
`this deposition?
` A. Yes.
` Q. Okay. And do you recall what those
`materials are?
` A. It was one paper. It was a paper --
`here, I'll tell you what the paper was. I have
`the '324 patent in front of me.
` Q. Okay. Actually I can go ahead and
`enter that as an exhibit as well.
` A. In Column 4, at Lines 59 and
`following, there is a reference to a paper by
`D. Caliga, C-A-L-I-G-A, who is a co-inventor.
`And it says, this paper, it incorporates a
`reference. It's not something I relied on, but
`I decided to look -- review it in preparation
`for this deposition just in case.
` Q. Okay. And just for the record, I
`just entered that exhibit, so that was 1001 in
`the IPR exhibits.
` A. That's correct.
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` Q. On your screen there as well. So
`you reviewed a reference, but you did not --
`sorry. Let me make sure I'm understanding your
`testimony just now.
` Okay. So obviously you didn't rely
`on it for your declaration?
` A. That's correct.
` Q. Right, okay. And then since
`reviewing it, has it altered or made any impact
`whatsoever on the opinions that you had in your
`'324 and '800 declarations?
` A. No.
` Q. And did you recall -- do you recall
`the reason that you wanted to review this
`document?
` A. Well, yes.
` Q. And what was that reason?
` A. It was incorporated by reference, so
`it's part of the patent that's being examined,
`so I felt I should refresh my memory on what it
`contained.
` Q. So thinking back on the preparation
`of your declaration, if I understand correctly,
`you did look at at least the parent patents for
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`the '687 patent, but did not rely on it for
`your opinions; is that correct?
` A. That's correct.
` Q. Okay. Were there any other
`documents that you can think of that -- or that
`you can recall looking at that you did not rely
`on for your opinions as part of preparing the
`'324 and the '800 declaration?
` A. Well, yeah, there were many
`documents. I don't recall what they were. I
`mean, I looked at many documents, and the ones
`that I relied on are in the report.
` Q. And when you reviewed those
`documents, were there any that were
`inconsistent with the opinions that you are
`presenting in the '324 and the '800 patent
`declarations?
` A. That's a long question. Let me --
`can you...
` Q. Yeah, sorry. So those additional