Deposition of:
`John M. Strawn , Ph.D.
`
`June 13, 2019
`
`In the Matter of:
`Panasonic Corp. Of North America, Et
`Al. Vs. Cellspin Soft, Inc.
`
`Veritext Legal Solutions
`800.808.4958 | calendar-atl@veritext.com | 770.343.9696
`
`CELLSPIN
`EX. 2030, Page 1
`
`
`John M. Strawn , Ph.D.
`
`June 13, 2019
`
`In the Matter of:
`Panasonic Corp. Of North America, Et
`Al. Vs. Cellspin Soft, Inc.
`
`Veritext Legal Solutions
`800.808.4958 | calendar-atl@veritext.com | 770.343.9696
`
`CELLSPIN
`EX. 2030, Page 1
`
`
`
`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
`
`June 13, 2019
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ______________________________
` )
` PANASONIC CORPORATION OF )
` NORTH AMERICA, et al., )
` )
` Petitioner, )
` ) Case No:
` vs. ) IPR 2019-00131
` ) Patent No. 9,258,698
` CELLSPIN SOFT, INC., )
` )
` Patent Owner. )
` ______________________________)
`
` DEPOSITION OF JOHN M. STRAWN, PH.D.
` San Francisco, California
` Thursday, June 13, 2019
` Volume I
`
`Reported by: SUZANNE F. GUDELJ
`CSR No. 5111
`Job No. 3386832
`PAGES 1 - 50
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`800.808.4958
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`CELLSPIN
`EX. 2030, Page 2
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`
`
`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
`
`June 13, 2019
`
`Page 2
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ______________________________
` )
` PANASONIC CORPORATION OF )
` NORTH AMERICA, et al., )
` )
` Petitioner, )
` ) Case No:
` vs. ) IPR 2019-00131
` ) Patent No. 9,258,698
` CELLSPIN SOFT, INC., )
` )
` Patent Owner. )
` ______________________________)
`
` Deposition of JOHN M. STRAWN, PH.D.,
` Volume I, taken on behalf of Patent Owner,
` Cellspin Soft, Inc., at 405 Howard Street, San
` Francisco, California, beginning at 8:59 a.m.
` and ending at 10:43 a.m., on Thursday,
` June 13, 2019, before SUZANNE F. GUDELJ,
` Certified Shorthand Reporter No. 5111.
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`CELLSPIN
`EX. 2030, Page 3
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`
`
`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
`
`June 13, 2019
`
`Page 3
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`A P P E A R A N C E S :
`
`F o r P e t i t i o n e r :
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` O R R I C K , H E R R I N G T O N & S U T C L I F F E L L P
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` B Y : T . V A N N P E A R C E , J R . , E S Q .
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` 1 1 5 2 1 5 t h S t r e e t , N . W .
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` W a s h i n g t o n , D C 2 0 0 0 5 - 1 7 0 6
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` ( 2 0 2 ) 3 3 9 - 8 6 9 6
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` v p e a r c e @ o r r i c k . c o m
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`F o r P a t e n t O w n e r C e l l s p i n S o f t , I n c .
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` E D M O N D S & S C H L A T H E R P L L C
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` B Y : J O H N J . E D M O N D S , E S Q .
`
` 1 6 1 6 S o u t h V o s s R o a d , S u i t e 1 2 5
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` H o u s t o n , T e x a s 7 7 0 5 7
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` ( 7 1 3 ) 3 6 4 - 5 2 9 1
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` j e d m o n d s @ j p - l i t . c o m
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`A l s o P r e s e n t :
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` G U R V I N D E R S I N G H
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`CELLSPIN
`EX. 2030, Page 4
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`
`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
`
`June 13, 2019
`
`Page 4
`
` INDEX
`WITNESS: EXAMINATION PAGE
`JOHN M. STRAWN, PH.D.
`Volume I
`
` BY MR. EDMONDS 5
`
` ---o0o---
`
` INSTRUCTION NOT TO ANSWER
`
` PAGE LINE PAGE LINE
`
` 6 18 7 2
`
` ---o0o---
` EXHIBITS
`NO. DESCRIPTION PAGE
`Exhibit 1 Master Table of Contents & 18
` Compliance Requirements,
` prior Exhibit Cellspin
` 2006
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`CELLSPIN
`EX. 2030, Page 5
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`
`
`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
`
`June 13, 2019
`
`Page 5
`
` San Francisco, California; Thursday, June 13, 2019
`
` 8:59 a.m.
`
` ---o0o---
`
` JOHN M. STRAWN, PH.D.,
`
`having been administered an oath, was examined and
`
`testified as follows:
`
` EXAMINATION
`
`BY MR. EDMONDS:
`
` Q Please state your name for the record.
`
` A John Michael Strawn.
`
` Q And you are an expert witness for Panasonic in
`
`this matter; is that correct?
`
` A Yes, sir.
`
` Q Is there anything about your health or wellness
`
`that would prevent you from giving full, complete and
`
`accurate testimony today?
`
` A No, sir.
`
` Q Sitting before you are two notebooks; is that
`
`correct?
`
` A Three-ring binders, yes, sir.
`
` Q Three-ring binders. And I was told that those
`
`are your report and other exhibits from the proceeding.
`
`Is that your understanding as well?
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`CELLSPIN
`EX. 2030, Page 6
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`
`
`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
`
`June 13, 2019
`
`Page 6
`
` A The one binder contains my report, the
`
`petition, and the exhibits that I rely on, and the other
`
`binder contains the preliminary response and associated
`
`exhibits.
`
` Q In preparing for today's deposition, did you
`
`get any information about what occurred at a deposition
`
`yesterday in a parallel proceeding?
`
` A I was --
`
` MR. PEARCE: I'm going to instruct the witness
`
`not to answer. I think that's getting into work
`
`product.
`
`BY MR. EDMONDS:
`
` Q Did you receive any information -- well, first
`
`of all, yes or no, did you receive any information --
`
`without getting into it, yes or no, did you receive any
`
`information about -- from what happened at the
`
`deposition yesterday?
`
` MR. PEARCE: I don't think he can answer that
`
`yes or no. Same instruction.
`
`BY MR. EDMONDS:
`
` Q Are you going to follow your counsel's
`
`instruction?
`
` A Yes, sir.
`
` Q And just so we have a complete record, what --
`
`what were you told about what happened at the deposition
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`CELLSPIN
`EX. 2030, Page 7
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
`
`June 13, 2019
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`Page 7
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`yesterday?
`
` MR. PEARCE: No, the same instruction.
`
`Instruct the witness not to answer. It's work product.
`
`BY MR. EDMONDS:
`
` Q Who did you have the conversation with?
`
` Oh, let me go back. I'm sorry. Are you
`
`following your counsel's instruction?
`
` A Yes, sir.
`
` Q And who have you spoken with in the last day to
`
`prepare for this deposition?
`
` A My wife, Mr. Pearce and -- and attorney named
`
`Olamide Olusesi.
`
` Q Is that somebody who works for Panasonic?
`
` A That is a lawyer who's part of the Orrick law
`
`firm.
`
` Q Okay. Is there anything about what you learned
`
`from yesterday's deposition that informs your expert
`
`opinions in this case?
`
` MR. PEARCE: Objection. Foundation. You can
`
`answer that question.
`
` THE WITNESS: Let me explain that I subscribe
`
`to a service called Docket Navigator, and it informs me
`
`with -- when various things happen. So it informed me
`
`that there was something that happened yesterday in the
`
`Canon case. I didn't take the time to look up what. So
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`CELLSPIN
`EX. 2030, Page 8
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`
`
`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
`
`June 13, 2019
`
`Page 8
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`that's the extent of what I know about what happened
`
`yesterday.
`
`BY MR. EDMONDS:
`
` Q And so shifting to your report. In your report
`
`you use the word "paired" correct?
`
` A I use various forms of the verb "pair."
`
` Q And in the context of your report, what does it
`
`mean to pair?
`
` MR. PEARCE: Objection. Form.
`
` THE WITNESS: I'm sorry, I didn't hear.
`
` MR. PEARCE: I said objection. Form. But you
`
`may answer.
`
` THE WITNESS: Well, in the context of the
`
`report, pairing includes receiving what's called a PIN
`
`that's entered by a user on two different devices.
`
`BY MR. EDMONDS:
`
` Q As the word "pair" is used in your report, what
`
`does that word mean?
`
` MR. PEARCE: Objection to form.
`
` THE WITNESS: I don't understand the difference
`
`from the previous question, so the answer is -- so far
`
`is the same.
`
`BY MR. EDMONDS:
`
` Q You didn't answer the previous question.
`
` MR. EDMONDS: Could you repeat the second
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`CELLSPIN
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
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`June 13, 2019
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`Page 9
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`question?
`
` (Record read as follows:
`
` "QUESTION: And in the context of
`
` your report, what does it mean to
`
` pair?")
`
` MR. PEARCE: Same objection.
`
` THE WITNESS: All right. In the world of
`
`Bluetooth, to pair two devices means, among other
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`things, to enter a PIN number on each of the devices,
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`and it's meant to be the same PIN number.
`
`BY MR. EDMONDS:
`
` Q And so in the example you just gave when a PIN
`
`is entered in Bluetooth, what is the sequence of steps
`
`that takes place?
`
` A Well, I haven't memorized the entire Bluetooth
`
`specification, but I can point you at diagrams in my own
`
`report and its exhibits that talk about that, if you
`
`wish.
`
` Q Yeah, let's start with the diagram in your
`
`report, diagram or diagrams. Do you have it in front of
`
`you?
`
` A Yes, sir.
`
` Q Okay. Just let us know what page you're on
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`when you get to it, please.
`
` A All right. The first answer is on page 40
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`CELLSPIN
`EX. 2030, Page 10
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`
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
`
`June 13, 2019
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`Page 10
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`where Mashita discloses that:
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` "An identical personal
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` identification code is input to both
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` devices."
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` And then I go on to say that:
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` "A person of ordinary skill in the
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` art would understand that establishing a
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` link and inputting the same PIN into
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` both the cellular phone and the digital
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` camera results in a paired connection."
`
` I want to point you at a diagram in my
`
`exhibits.
`
` Q Which exhibit are you looking at?
`
` A I -- okay. I'm looking at my Exhibit 1017.
`
` Q 1A17 --
`
` A 1017.
`
` Q Okay. Hold on. Let me get to it. Let's --
`
`let's -- okay. Go ahead.
`
` A Right. And in Exhibit 1017, I'm at its
`
`page 29, which is numbered page 251 of 814, section
`
`4.2.2 Pairing. So this says:
`
` "When two devices do not have a
`
` common link key, an initialization key
`
` shall be created based on a PIN, a
`
` random number, and a BD_ADDR."
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`CELLSPIN
`EX. 2030, Page 11
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`
`
`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
`
`June 13, 2019
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`Page 11
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` The BD_ADDR is the address of the respective
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`device. So pairing involves a PIN being entered, and if
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`a PIN is entered, then pairing happens. And this
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`pairing sequence is part of a larger Bluetooth sequence.
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`And I can -- I don't have duplicated here, because I
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`didn't think it was necessary, the respective pages of
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`this particular specification.
`
` Q What -- what's your understanding of the larger
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`Bluetooth sequence that's accompanied by the exchange of
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`PINs in Bluetooth?
`
` A So I'd like in this instance, because I didn't
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`review -- I didn't reproduce the respective pages, I'd
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`like to turn to your Exhibit 2006.
`
` Q Please do. When you get to a page, just let us
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`know what page you're at, please.
`
` A Yes, sir. Let's start in my Exhibit 1017 on
`
`exhibit page 27, which is page 249 of the document. And
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`I draw your attention to sequence 22 where a link key
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`exists -- exists. And here we show that from the one
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`device to the other there are two messages sent. First
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`the message LMP_AU_RAND is sent. And then the message
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`LMP_SRES is sent. Turning then to your Exhibit 2006,
`
`exhibit page 866.
`
` Let me know when you're there, please.
`
` Q Thank you. I have it. Thank you.
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`CELLSPIN
`EX. 2030, Page 12
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`
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
`
`June 13, 2019
`
`Page 12
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` A Okay. Now, this shows some larger context of
`
`what Bluetooth calls an authentication procedure. And
`
`in the text at the top, the second sentence starts:
`
` "The LM" -- which is a layer of the
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` software in Bluetooth -- "will have
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` requested a link key from the host for
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` this connection."
`
` And the host is, we'll call it the main
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`processor of the device.
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` "If there is a negative reply, then
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` a PIN code will be requested. This PIN
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` code will be requested on both sides of
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` the connection and authentication
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` performed based on this PIN code."
`
` Then in the diagram you can see on the left
`
`side for the one device, it says "user inputs PIN code,"
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`and on the right side you can see for the other device
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`"user inputs PIN code." And then toward the bottom in
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`the middle you can see a sequence that matches the
`
`sequence from my Exhibit 1017, which is LMP_AU_RAND and
`
`LMP_SRES. And that sequence happens twice.
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` So this is pairing, and pairing requires a PIN
`
`code. And conversely if there's a PIN code input on
`
`both devices successfully, then pairing happens.
`
` Q Bluetooth --
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`CELLSPIN
`EX. 2030, Page 13
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`
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
`
`June 13, 2019
`
`Page 13
`
` A That's -- one more sentence.
`
` Q Sorry.
`
` A There's even more context, if you need it, but
`
`that's the first stage.
`
` Q Are you --
`
` A Please proceed.
`
` Q Are you saying that Bluetooth pairing requires
`
`only a PIN code or that it requires a PIN code in
`
`addition to other steps?
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` THE WITNESS: Read me the question, please.
`
`BY MR. EDMONDS:
`
` Q I'll repeat it. Are you saying that pairing
`
`requires -- are you saying that Bluetooth pairing
`
`requires only a PIN code or that it requires a PIN code
`
`and other steps?
`
` A Bluetooth pairing requires many, many steps of
`
`which inputting a PIN is one.
`
` Q Do you -- so we started this line of
`
`questioning with asking you about what it means to pair.
`
`Do you have a definition of "pair" that you're using for
`
`purposes of your testimony?
`
` MR. PEARCE: Objection to form.
`
` THE WITNESS: The definition of the phrase
`
`within which "paired" occurs is in my report on pages 33
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`and 34. Does that answer the question?
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
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`June 13, 2019
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`BY MR. EDMONDS:
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` Q Thank you, but it does not. Where on pages 33
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`and 34 are you pointing to where you presented a
`
`definition of "paired"?
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` A I don't present a separate definition of
`
`"paired," and I wasn't asked to. But I do understand
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`that pairing involves, as it says:
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` "Authenticating the identity of the
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` cellphone using some form of security or
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` encryption including by use of a shared
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` passkey on the digital camera device and
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` the cellular phone."
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`BY MR. EDMONDS:
`
` Q That's your definition for "cryptographically
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`authenticated," correct?
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` A No, sir. What I was suggesting was that the
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`definition of "paired" is embedded within the definition
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`of this whole phrase "wherein establishing," etc.
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` Q So just so we have a clean record, and feel
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`free to read if you need to, the question is "the
`
`definition of 'paired' is," and hopefully you can answer
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`it by saying "the definition of 'paired' that I'm
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`following is," and just read us that or state it.
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` A Right. I'm going to go back to your
`
`Exhibit 2006.
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
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`June 13, 2019
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` So your Exhibit 2006, exhibit page 92:
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` "Paired device, a Bluetooth device
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` with which a link key has been exchanged
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` either before connection establishment
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` was requested or during the connecting
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` phase."
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` Q Are you saying that's the definition of "paired
`
`device" in Bluetooth or that's the definition of
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`"paired" that you have been using for your report?
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` A I use this definition of paired device from the
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`Bluetooth specification to inform me what "paired"
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`means.
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` Q What's a "link key"?
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` A Bluetooth has half a dozen keys, and I haven't
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`memorized exactly which key is the link key, but in
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`general, it's a key that's established during
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`authentication so that devices can recognize each other.
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` Q Is it cryptographic?
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` A From memory, the link key is established using
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`a secret key, so it's therefore cryptographic. And the
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`link key then feeds into from memory the establishment
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`of cryptographic procedures in Bluetooth.
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` Q And what cryptographic procedures are you
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`referring to?
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` A I draw your attention to your Exhibit 2006,
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`CELLSPIN
`EX. 2030, Page 16
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
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`June 13, 2019
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`exhibit page 861.
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` Q What's the page again? Sorry.
`
` A 861.
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` Q Okay.
`
` A And in the diagram, this is the various steps
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`in general as a very high level overview of how
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`connection happens. And you can see there that step 7A
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`is the pairing, step 7B is authentication, and step 8 is
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`the encryption. And when I used cryptographic in my
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`previous answer, I was referring to this encryption step
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`that the link key ultimately feeds into.
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` Q So the question is -- still stands: What is
`
`the definition of "pair" that you have used for purposes
`
`of your report?
`
` MR. PEARCE: Objection to form.
`
` THE WITNESS: I use the Bluetooth definition
`
`that I cited earlier. And I can find it again if you
`
`want me to.
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`BY MR. EDMONDS:
`
` Q I'm saying what -- I'm not saying which one you
`
`consulted or which one informed you, I'm saying which
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`one did you actually use, in other words operate under?
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` A And that was --
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` MR. PEARCE: Objection to form. Go ahead.
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` THE WITNESS: Right. And it's the same answer.
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
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`June 13, 2019
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`It's not only that I consulted it, but because Bluetooth
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`defines it, and the dispute here resolves around
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`Bluetooth, I used the Bluetooth definition.
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`BY MR. EDMONDS:
`
` Q Okay. And so did you use other definitions, or
`
`is the Bluetooth definition the definition that you used
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`for purposes of your report for the word "pair"?
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` A I used the Bluetooth definition when I was
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`analyzing Mashita, for example, and what he does.
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` Q Did you use any other definition than the
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`Bluetooth definition for the word "pair" in your report?
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` A For the word "pair." Not from memory.
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` Q What's the difference between paired
`
`connections and non-paired connections?
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` MR. PEARCE: Objection to form.
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` THE WITNESS: Are we talking just about
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`Bluetooth here?
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`BY MR. EDMONDS:
`
` Q As you've used "paired" in your declaration.
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` A Well, for the most part, I've used "paired" in
`
`my declaration in the context of Bluetooth, so I'll
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`restrict myself to that.
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` As I showed in the figure that I just cited, a
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`Bluetooth connection can exist at a very primitive level
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`that pairing happened -- happening, but the two devices
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`CELLSPIN
`EX. 2030, Page 18
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
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`June 13, 2019
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`Page 18
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`can't do much at that level. So there can be a
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`connection that's not paired, but it's not very good for
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`much.
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` Q In the situation of -- and is that -- so were
`
`you -- were you referring to step 7A where it says
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`"optional pairing" in that Figure 31 in Exhibit 2006?
`
` MR. PEARCE: Objection. Form.
`
`BY MR. EDMONDS:
`
` Q Here, let's -- you can pull that out. I
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`actually have a smaller copy to kind of work with here,
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`if that helps. It's just a subset of the pages. So you
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`can feel free to consult either one, but we'll mark that
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`as Exhibit No. 1.
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` (Deposition Exhibit 1 marked by the court
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` reporter.)
`
`BY MR. EDMONDS:
`
` Q So for this one, the same diagram should be --
`
`you just have to follow the pages. It's the same
`
`page 861. It's a little more than half way through this
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`one.
`
` Do you have it?
`
` A Yes, sir, I see that also.
`
` Q Okay. So is -- when you were referring to that
`
`in Bluetooth you can have connections that are unpaired,
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`were you referring back to this step 7A where it says
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
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`June 13, 2019
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`"optional pairing"?
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` A Well, in general. In other words, there can be
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`a connection in step 1, and I suppose two devices could
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`stop there. There can be a connection preceding in step
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`3, but -- and if a PIN is put in, then pairing happens
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`in step 7A. So it's -- it's not just pairing, it's
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`authentication. Do the two devices really trust each
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`other.
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` So you may be asking is there such a thing as
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`a -- as an unauthenticated connection, and as opposed to
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`an authenticated question -- connection.
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` Q So following the flow of this diagram, is --
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`for Bluetooth communications, is pairing optional?
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` A Well, in order to establish an authenticated
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`connection, there has to be the link key. And if the
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`host doesn't have the link key, then pairing explicitly
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`happens. Then the keys that result are stored so that
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`when the two devices talk to each other later, they
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`don't have to go through the step of entering the PIN
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`again.
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` Q Is that a "yes" to my question the pairing is
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`optional?
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` MR. PEARCE: Objection to form.
`
` THE WITNESS: If the devices want to
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`authenticate, then at some point pairing has to have
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`EX. 2030, Page 20
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
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`June 13, 2019
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`happened because the user has to have identified the two
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`devices to each other.
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`BY MR. EDMONDS:
`
` Q Well, it says "optional pairing." Are you
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`saying the pairing is not optional?
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` A I'm saying that pairing happens as a
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`predecessor to full authentication happening inside
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`Bluetooth.
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` Q Is pairing optional in Bluetooth, yes or no?
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` MR. PEARCE: Objection to form.
`
` THE WITNESS: Well, the question doesn't admit
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`of a yes or no answer. The diagram on the face says
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`that pairing is optional, but it's in the context of
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`authentication.
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`BY MR. EDMONDS:
`
` Q Can you have an authentic -- can you have an
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`authenticated connection in Bluetooth without pairing?
`
` A Only -- as I understand it, only if a link key
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`has been previously established.
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` Q Can you have a secure connection in Bluetooth
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`without pairing?
`
` A You may be trying to distinguish between a
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`secure connection and an authenticated connection. Or
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`you may be invoking the simple secure pairing that's a
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`new feature of this particular version of this spec. So
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`EX. 2030, Page 21
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
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`June 13, 2019
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`I'm -- I'm not sure what you're asking here.
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` Q When you say "this particular version," you're
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`talking about version 2.1 from July 2007, or are you
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`talking about a different version?
`
` A I'm talking about this version of 2006. I'm
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`sorry, this version of Exhibit 2006.
`
` Q Anywhere within Bluetooth, can you have a
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`secure connection without pairing?
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` MR. PEARCE: Objection to form.
`
`BY MR. EDMONDS:
`
` Q And let's just, to be more clear, any --
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`anywhere within this Bluetooth 2.1 from 2007 we're
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`looking at here.
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` A Well, this is what, a thousand page document,
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`1,300 page document. I haven't memorized it. I've been
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`focusing in my work on authentication because pairing is
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`part of authentication. And I do know that Bluetooth
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`has considered an authenticated connection to be a
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`secure one even if it wasn't -- even if the security
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`wasn't very good.
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` So I will say that I understand pairing to be
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`part of authentication, but I don't want to go on record
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`as to saying that's known to be a secure connection yet.
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` Maybe I'll review the spec during the break and
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`we can come back to that.
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`CELLSPIN
`EX. 2030, Page 22
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`
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
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`June 13, 2019
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`Page 22
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` Q Okay. But as you -- maybe we will, maybe we
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`won't. As you sit here today answering this question
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`now, do you know one way or the other as to whether you
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`can have a secure connection within Bluetooth 2.1
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`without pairing?
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` A As I understand it, a link key has to be in
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`place for a Bluetooth connection to be considered secure
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`in any way.
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` Q So if you'd turn to paragraph 77 and 78 of your
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`report --
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` A By the way, I'd like to clarify that the
`
`diagrams and the definition I've pointed out exist also
`
`in the version of the Bluetooth spec from which I
`
`extracted my Bluetooth specification exhibit.
`
` Q Okay.
`
` A All right, page which, please?
`
` Q Let's see. It would be 41 -- 78 is on page 41.
`
` A Yes, sir, I'm at paragraph 78.
`
` Q And -- yeah, okay. So the last sentence in
`
`paragraph 77 says:
`
` "A POSITA would understand that
`
` Bluetooth provides a short-range paired
`
` wireless connection."
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` Correct?
`
` A You read the sentence correctly, yes, sir.
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
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`June 13, 2019
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`Page 23
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` Q And that same sentence is at the end of
`
`paragraph 78 as well, correct?
`
` A Yes, sir. That's correct.
`
` Q And the one in paragraph 77 is referring to the
`
`Onishi reference, and the one in 78 is referring to the
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`Hiraishi reference, correct?
`
` A Yes, sir.
`
` Q Okay. The -- are -- as part of that statement,
`
`are you assuming that Onishi and Hiraishi are using a
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`PIN?
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` A I'm not assuming that Hiraishi and Onishi use a
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`PIN, but it was common practice at the time to use a PIN
`
`to pair two Bluetooth devices.
`
` Q As you stated before, to use a PIN and take
`
`other steps, correct?
`
` A Surely, to use a PIN and take other steps.
`
` Q In Bluetooth 2.1, what happens when you
`
`terminate a Bluetooth link?
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` MR. PEARCE: Objection to form.
`
` THE WITNESS: Sir, honestly, I'm underinformed
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`the exact steps that Bluetooth does to terminate a link
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`beyond what one would understand of such links in such
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`situations.
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`BY MR. EDMONDS:
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` Q Whatever understanding you have, what is it?
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`EX. 2030, Page 24
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
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`June 13, 2019
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` A Well, for example --
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` MR. PEARCE: Same objection.
`
` THE WITNESS: -- briefly, in the world of
`
`networking and communications, there are layers of
`
`software. For example, in Bluetooth there's the LM
`
`layer, and above that is the L2CAP layer. And after
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`various steps, those layers are established between the
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`two devices. And those layers allow things to happen.
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`For example, data to be transferred in an efficient and
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`convenient manner between the two devices.
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` When a termination -- when a connection is
`
`terminated, then those layers of software also uncouple
`
`from each other. So if I'm listening to YouTube on my
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`Bluetooth headset and then I terminate the connection to
`
`my Bluetooth headset, I can't hear any audio anymore.
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`So that's an example of what happens when a connection
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`is terminated.
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`BY MR. EDMONDS:
`
` Q What -- I asked you about when a link is
`
`terminated, and you answered by saying a connection is
`
`terminated. Are you referring to something different,
`
`or are you using those two words interchangeably?
`
` A For that answer, interchangeably.
`
` Q Are there places in your declaration that
`
`you've used a link as -- in a manner that's -- wouldn't
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`CELLSPIN
`EX. 2030, Page 25
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`
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`John M. Strawn , Ph.D.
`Panasonic Corp. Of North America, Et Al. Vs. Cellspin Soft, Inc.
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`June 13, 2019
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`equate with a connection?
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` A Sir, to answer that question, I'd have to
`
`search the entire document. I doubt it, but I've not
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`memorized the text, so I can't answer that truthfully
`
`without reviewing every line of the document.
`
` Q Fair enough. Your -- your -- your answer
`
`before said in that instance. My question is: Are
`
`there any other instances that you have in mind as
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`you're sitting here now in which you use the word
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`connection in a different way than link or have some
`
`different meaning?
`
` A Well, of course, link key has a specific
`
`meaning in the Blu
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