UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE,
`
`INC.
`
`Petitioner
`
`V.
`
`UUSI, LLC d/b/a NARTRON,
`
`Patent Owner.
`
`vvvvvvvvvv
`
`Case IPR2019—00358
`
`Patent No. 5,796,183
`
`VOLUME I
`
`ORAL DEPOSITION OF
`
`DARRAN R. CAIRNS, Ph.D.
`
`DECEMBER 18, 2019
`
`provisions stated on the record or attached hereto.
`
`ORAL DEPOSITION OF DARRAN R. CAIRNS, Ph.D.,
`
`produced as a witness at the instance of the Petitioner,
`
`and duly sworn, was taken in the above—styled and
`
`numbered cause on the 18th of December, 2019,
`
`from 9:40
`
`a.m. to 12:03 p.m., before Caroline Massa, RPR, CSR in
`
`and for the State of Texas, reported by machine
`
`shorthand, at the law offices of Fish & Richardson,
`
`P.C., 1717 Main Street, Suite 5000, Dallas, Texas,
`
`pursuant to the Code of Federal Regulations and the
`
`S THE SULLIVAN GROUP
`
`OF COURT REPORTERS
`SULLIVANCOURTREPORTERS.COM
`
`PHONE 855.525.3860 | 323.938.8750
`
`1
`
`Exhibit 1033
`Apple v. UUSI
`IPR2019-00359
`
`1
`
`Exhibit 1033
`Apple v. UUSI
`IPR2019-00359
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE,
`
`INC.
`
`Petitioner
`
`V.
`
`UUSI, LLC d/b/a NARTRON,
`
`Patent Owner.
`
`vvvvvvvvvv
`
`Case IPR2019—00358
`
`Patent No. 5,796,183
`
`VOLUME I
`
`ORAL DEPOSITION OF
`
`DARRAN R. CAIRNS, Ph.D.
`
`DECEMBER 18, 2019
`
`provisions stated on the record or attached hereto.
`
`ORAL DEPOSITION OF DARRAN R. CAIRNS, Ph.D.,
`
`produced as a witness at the instance of the Petitioner,
`
`and duly sworn, was taken in the above—styled and
`
`numbered cause on the 18th of December, 2019,
`
`from 9:40
`
`a.m. to 12:03 p.m., before Caroline Massa, RPR, CSR in
`
`and for the State of Texas, reported by machine
`
`shorthand, at the law offices of Fish & Richardson,
`
`P.C., 1717 Main Street, Suite 5000, Dallas, Texas,
`
`pursuant to the Code of Federal Regulations and the
`
`S THE SULLIVAN GROUP
`
`OF COURT REPORTERS
`SULLIVANCOURTREPORTERS.COM
`
`PHONE 855.525.3860 | 323.938.8750
`
`1
`
`Exhibit 1033
`Apple v. UUSI
`IPR2019-00359
`
`1
`
`Exhibit 1033
`Apple v. UUSI
`IPR2019-00359
`
`
`
`·1· · · · · ·UNITED STATES PATENT AND TRADEMARK OFFICE
`
`·2· · · · · ·BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`·3
`
`·4
`
`·5· ·APPLE, INC.· · · · · · · ·)
`· · · · · · · · · · · · · · · ·)
`·6· · · · · · · ·Petitioner· · )
`· · · · · · · · · · · · · · · ·)
`·7· · · · · ·v.· · · · · · · · ) Case IPR2019-00358
`· · · · · · · · · · · · · · · ·) Patent No. 5,796,183
`·8· ·UUSI, LLC d/b/a NARTRON,· )
`· · · · · · · · · · · · · · · ·)
`·9· · · · · · · ·Patent Owner. )
`· · ·__________________________)
`10
`
`11· · · · · · · · · · · · · ·VOLUME I
`
`12· · · · · · · · · · · ORAL DEPOSITION OF
`
`13· · · · · · · · · · DARRAN R. CAIRNS, Ph.D.
`
`14· · · · · · · · · · · ·DECEMBER 18, 2019
`
`15
`
`16· · · · ORAL DEPOSITION OF DARRAN R. CAIRNS, Ph.D.,
`
`17· ·produced as a witness at the instance of the Petitioner,
`
`18· ·and duly sworn, was taken in the above-styled and
`
`19· ·numbered cause on the 18th of December, 2019, from 9:40
`
`20· ·a.m. to 12:03 p.m., before Caroline Massa, RPR, CSR in
`
`21· ·and for the State of Texas, reported by machine
`
`22· ·shorthand, at the law offices of Fish & Richardson,
`
`23· ·P.C., 1717 Main Street, Suite 5000, Dallas, Texas,
`
`24· ·pursuant to the Code of Federal Regulations and the
`
`25· ·provisions stated on the record or attached hereto.
`
`2
`
`
`
`·1· · · · · · · · · · ·A P P E A R A N C E S
`
`·2
`
`·3· ·FOR THE PETITIONER:
`
`·4· · · · Mr. Daniel D. Smith
`· · · · · FISH & RICHARDSON, P.C.
`·5· · · · 1717 Main Street
`· · · · · Suite 5000
`·6· · · · Dallas, Texas 75201
`· · · · · Phone:· (214) 292-4071
`·7· · · · Email:· dsmith@fr.com
`· · ·AND
`·8· · · · Mr. Ryan Chowdhury (Via Telephone)
`· · · · · FISH & RICHARDSON, P.C.
`·9· · · · 1000 Maine Avenue Southwest
`· · · · · Washington, D.C. 20024
`10· · · · Phone:· (202) 638-6554
`· · · · · Email:· rchowdhury@fr.com
`11
`
`12· ·FOR THE RESPONDENT:
`
`13· · · · Mr. Lawrence M. Hadley
`· · · · · GLASER WEIL
`14· · · · 10250 Constellation Boulevard
`· · · · · 19th Floor
`15· · · · Los Angeles, California 90067
`· · · · · Phone:· (310) 282-6235
`16· · · · Email:· lhadley@glaserweil.com
`
`17
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`18
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`19
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`20
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`21
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`22
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`23
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`24
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`25
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`3
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`·1· · · · · · · · · · · · · · ·INDEX
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`·2· · · · · · · · · · · · · · · · · · · · · · · · · ·PAGE
`
`·3· ·Appearances...................................... 2
`
`·4· ·Stipulations..................................... 4
`
`·5· ·DARRAN R. CAIRNS, Ph.D.
`· · · · · Examination by Mr. Smith.................... 4
`·6
`
`·7· ·Signature and Changes............................ 50/51
`
`·8· ·Reporter's Certificate........................... 52
`
`·9
`· · · · · · · · · · · · · · ·EXHIBITS
`10
`· · · · · · · · ·(No exhibits were marked.)
`11
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`12
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`13
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`14
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`15
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`16
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`17
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`18
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`19
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`20
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`21
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`22
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`23
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`24
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`25
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`4
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`
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`·1· · · · · · · · · P R O C E E D I N G S
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`·2· · · · · · · · · THE REPORTER:· Any stipulations or
`
`·3· ·agreements today?
`
`·4· · · · · · · · · MR. SMITH:· No, I don't think so.
`
`·5· · · · · · · · · ·DARRAN R. CAIRNS, Ph.D.,
`
`·6· ·having been first duly sworn, testified as follows:
`
`·7· · · · · · · · · · · · · EXAMINATION
`
`·8· ·BY MR. SMITH:
`
`·9· · · · Q.· ·Good morning, Dr. Cairns.
`
`10· · · · A.· ·Good morning.
`
`11· · · · Q.· ·Could you state your full name and -- your
`
`12· ·full name and spell it for the record?
`
`13· · · · A.· ·Yep.· It's Darran, D-A-R-R-A-N, and then my
`
`14· ·middle name is Robert, R-O-B-E-R-T.· And then my last
`
`15· ·name is Cairns.· That's C-A-I-R-N-S.
`
`16· · · · Q.· ·Okay.· Do you understand we're here to take
`
`17· ·your deposition today?
`
`18· · · · A.· ·I do.
`
`19· · · · Q.· ·Have you been deposed before?
`
`20· · · · A.· ·Yes.
`
`21· · · · Q.· ·How many times, roughly?
`
`22· · · · A.· ·Somewhere -- yeah.· Maybe it's close to ten
`
`23· ·times now.
`
`24· · · · Q.· ·And when was the last time you were deposed?
`
`25· · · · A.· ·I was deposed earlier this year, maybe around
`
`5
`
`
`
`·1· ·May in an IPR case.
`
`·2· · · · Q.· ·And do you understand that your testimony here
`
`·3· ·today is as if you were testifying before the board in
`
`·4· ·this proceeding?
`
`·5· · · · A.· ·Yes, I do.
`
`·6· · · · Q.· ·And you understand that the board may hear
`
`·7· ·and/or read the testimony you provide here today?
`
`·8· · · · A.· ·Yes, I do.
`
`·9· · · · Q.· ·You understand that your answers need to be
`
`10· ·verbal so that they can be on the record.· So if you nod
`
`11· ·your head or make a gesture, that's not going to appear
`
`12· ·on the record.· You understand that?
`
`13· · · · A.· ·Yes, I do.
`
`14· · · · Q.· ·Okay.· You understand that you've taken an
`
`15· ·oath?
`
`16· · · · A.· ·I do.
`
`17· · · · Q.· ·You understand the oath requires you to tell
`
`18· ·the truth?
`
`19· · · · A.· ·Yes.
`
`20· · · · Q.· ·And you will do that here today, correct?
`
`21· · · · A.· ·Yes.
`
`22· · · · Q.· ·Okay.· All right.
`
`23· · · · · · · · · I'm planning to take a break like every
`
`24· ·hour or so.· If you need a break to stretch your legs at
`
`25· ·any time just let me know, and we can -- you know, we
`
`6
`
`
`
`·1· ·can take a break.· The only thing I'd ask is if there's
`
`·2· ·a question pending, you know, we -- that you answer that
`
`·3· ·question before the break.· Do you agree to that?
`
`·4· · · · A.· ·Yes.
`
`·5· · · · Q.· ·Are you being represented by counsel today?
`
`·6· · · · A.· ·I believe so.
`
`·7· · · · Q.· ·Okay.· Who is that?
`
`·8· · · · A.· ·It's Larry Hadley from Glaser Weil.
`
`·9· · · · Q.· ·Okay.· And you were retained by counsel to
`
`10· ·serve as an expert for this proceeding on the '183
`
`11· ·patent, correct?
`
`12· · · · A.· ·Yes.
`
`13· · · · Q.· ·You understand your attorney may assert
`
`14· ·objections from time to time during the deposition?
`
`15· · · · A.· ·Yes, I do.
`
`16· · · · Q.· ·Okay.· And that unless he instructs you not to
`
`17· ·answer, you must answer my questions.· You understand
`
`18· ·that?
`
`19· · · · A.· ·Yes, I do.
`
`20· · · · · · · · · MR. HADLEY:· As long as you understand
`
`21· ·the question.
`
`22· · · · · · · · · MR. SMITH:· That was the next thing.
`
`23· · · · Q.· ·(BY MR. SMITH)· If for any reason you don't
`
`24· ·understand a question, will you let me know?
`
`25· · · · A.· ·Yes.
`
`7
`
`
`
`·1· · · · Q.· ·And if you don't ask me to clarify a question,
`
`·2· ·I'm going to assume you understood it.· Is that okay?
`
`·3· · · · A.· ·Yes.
`
`·4· · · · Q.· ·Okay.· Is there any reason you can't give your
`
`·5· ·best and most accurate testimony today?
`
`·6· · · · A.· ·I don't believe so.
`
`·7· · · · Q.· ·Okay.· I'm gonna hand you two documents.· The
`
`·8· ·first one is Exhibit 2002 from -- from both
`
`·9· ·IPR2019-OO358 and IPR2019-00359.· This is your --
`
`10· ·actually --
`
`11· · · · · · · · · MR. SMITH:· Do we want to mark these?
`
`12· ·Would that be easier if we did that?
`
`13· · · · · · · · · MR. HADLEY:· It's up to you.
`
`14· · · · · · · · · THE WITNESS:· Oh, I see what you're
`
`15· ·saying.
`
`16· · · · · · · · · MR. SMITH:· Yeah.
`
`17· · · · Q.· ·(BY MR. SMITH)· Have you seen that document
`
`18· ·before?
`
`19· · · · A.· ·Yes.
`
`20· · · · Q.· ·And what is that document?
`
`21· · · · A.· ·It's a declaration that I prepared as part of
`
`22· ·the patent owner's preliminary response in this matter.
`
`23· · · · Q.· ·Do you have any reason to believe that it's
`
`24· ·not a true, correct and complete copy of your
`
`25· ·declaration submitted?
`
`8
`
`
`
`·1· · · · A.· ·No.
`
`·2· · · · Q.· ·The second document, this is Exhibit 2004.
`
`·3· ·And do you recognize that document?
`
`·4· · · · A.· ·Yeah, I do.
`
`·5· · · · Q.· ·And what is that document?
`
`·6· · · · A.· ·It's the declaration I prepared in support of
`
`·7· ·the patent owner's response, and both of these are for
`
`·8· ·the '358 IPR.
`
`·9· · · · Q.· ·Okay.· Do you have any reason to believe that
`
`10· ·that's not a true, correct, and complete copy of your
`
`11· ·declaration that was submitted as Exhibit 2004?
`
`12· · · · A.· ·No.
`
`13· · · · Q.· ·Okay.· And this is Exhibit 1001.· Do you
`
`14· ·recognize this document?
`
`15· · · · A.· ·Yes.
`
`16· · · · Q.· ·And what is that document?
`
`17· · · · A.· ·It's the '183 patent that is at issue in this
`
`18· ·IPR -- or these IPRs.
`
`19· · · · Q.· ·And do you have reason to believe that that's
`
`20· ·not a true, correct, and complete copy of the '183
`
`21· ·patent?
`
`22· · · · A.· ·No.
`
`23· · · · Q.· ·Okay.· So you're familiar with the term
`
`24· ·"supply voltage"?
`
`25· · · · A.· ·Yes.
`
`9
`
`
`
`·1· · · · Q.· ·And what -- what does that term mean to you?
`
`·2· · · · A.· ·It's a voltage that's supplied to an electric
`
`·3· ·circuit or to a piece of electronics.
`
`·4· · · · Q.· ·And what is that -- what does the piece of
`
`·5· ·electronics generally use that voltage for?
`
`·6· · · · A.· ·To function.
`
`·7· · · · Q.· ·And when you say "function," you mean perform
`
`·8· ·the -- perform the operations that the circuit was
`
`·9· ·designed to do?
`
`10· · · · A.· ·To perform the operations that the circuit or
`
`11· ·the component and the circuit was designed to do.
`
`12· · · · Q.· ·Is a supply voltage usually positive or
`
`13· ·negative?
`
`14· · · · A.· ·I -- I don't understand the question.
`
`15· · · · Q.· ·If I -- if you were supplying a supply voltage
`
`16· ·to a electronic circuit, would you generally supply a
`
`17· ·positive voltage or a negative voltage?
`
`18· · · · A.· ·I don't really understand the question. I
`
`19· ·mean, it's whatever the -- whatever -- whatever it calls
`
`20· ·for or whatever you decide to do.
`
`21· · · · Q.· ·What's a ground voltage?
`
`22· · · · A.· ·A ground voltage is what you set as a ground,
`
`23· ·so it could be -- it could be a real ground, or it could
`
`24· ·be some sort of virtual ground, but the ground voltage
`
`25· ·would typically be your zero voltage or your ground
`
`10
`
`
`
`·1· ·voltage.
`
`·2· · · · Q.· ·Is a ground voltage generally less than a
`
`·3· ·supply voltage?
`
`·4· · · · A.· ·I don't understand what you mean by -- yeah.
`
`·5· ·I don't really understand the question.
`
`·6· · · · Q.· ·Would the magnitude of the voltage signal --
`
`·7· ·would the number of volts for a ground voltage generally
`
`·8· ·be less than the number of volts in a supply voltage?
`
`·9· · · · A.· ·I mean, the ground voltage sets -- you know,
`
`10· ·it is -- it will set your zero.· Many times you would
`
`11· ·use that -- a supply voltage that would be positive, but
`
`12· ·there could be reasons why you would make it that --
`
`13· ·that you use an inverter or something else to make it so
`
`14· ·that it's negative, but, you know, in many cases, the
`
`15· ·supply voltage will be -- will be positive.· And the
`
`16· ·ground voltage will be, you know -- to the extent that
`
`17· ·what you're saying, if it's positive, then it's less,
`
`18· ·but there can be reasons where you would -- you know,
`
`19· ·you wouldn't set it up that way.
`
`20· · · · Q.· ·And the abbreviation "VDD" is usually used to
`
`21· ·denote a supply voltage, correct?
`
`22· · · · A.· ·Is there a particular -- VDD can often be used
`
`23· ·to mean a supply voltage.· It can.
`
`24· · · · Q.· ·And VSS can be used to denote a ground
`
`25· ·voltage?
`
`11
`
`
`
`·1· · · · A.· ·I mean it can.
`
`·2· · · · Q.· ·Would you say that it's common that VSS is
`
`·3· ·used to denote a ground voltage?
`
`·4· · · · · · · · · MR. HADLEY:· Calls for speculation.
`
`·5· · · · A.· ·Yeah.· I don't -- I don't know what -- to say
`
`·6· ·common, but certainly it can be.
`
`·7· · · · Q.· ·(BY MR. SMITH)· What's -- what is a battery?
`
`·8· · · · A.· ·In a general sense?
`
`·9· · · · Q.· ·Yes, in a general sense.
`
`10· · · · A.· ·A battery is a -- a -- a device that can
`
`11· ·deliver current and voltage that is typically through
`
`12· ·chemical means, you know, so it will be -- for example,
`
`13· ·a lithium ion battery or some other similar type -- or a
`
`14· ·lead acid battery that through chemical means can
`
`15· ·develop -- can provide voltage in a current.
`
`16· · · · Q.· ·And so a battery can be used to power an
`
`17· ·electronic circuit?
`
`18· · · · A.· ·Yeah.
`
`19· · · · Q.· ·And would the -- strike that.
`
`20· · · · · · · · · So a battery would -- can be used to
`
`21· ·provide a supply voltage to an electronic circuit?
`
`22· · · · A.· ·Yes.
`
`23· · · · Q.· ·Would that supply voltage commonly be
`
`24· ·alternating current or direct current?
`
`25· · · · A.· ·Usually for a battery it's -- it's direct
`
`12
`
`
`
`·1· ·current.
`
`·2· · · · Q.· ·Is there a difference between a DC supply
`
`·3· ·voltage supplied by a battery and that supplied from
`
`·4· ·another source, such as mains power?
`
`·5· · · · · · · · · THE REPORTER:· Such as?
`
`·6· · · · · · · · · MR. SMITH:· Mains power.
`
`·7· · · · A.· ·Maybe you could restate the question.
`
`·8· · · · Q.· ·(BY MR. SMITH)· Sure.
`
`·9· · · · · · · · · Would you be able to differentiate a DC
`
`10· ·supply voltage signal -- or scratch that.
`
`11· · · · · · · · · Would you be able to differentiate a DC
`
`12· ·voltage signal produced by a battery from a DC voltage
`
`13· ·signal produced by another power source, assuming that
`
`14· ·the magnitude of the voltage is the same?
`
`15· · · · A.· ·I don't -- I don't really understand what you
`
`16· ·mean by differentiate between the two.
`
`17· · · · Q.· ·Well, would there be any difference between
`
`18· ·them?· Would there -- if you had a DC voltage signal on
`
`19· ·a wire that was provided by a -- a battery and another
`
`20· ·one that was provided from mains power, would there be a
`
`21· ·difference between those signals?· Would you be able to
`
`22· ·tell one from the other?
`
`23· · · · A.· ·You wouldn't tell a difference in the voltage,
`
`24· ·no.
`
`25· · · · Q.· ·But would you -- okay.· Strike that.
`
`13
`
`
`
`·1· · · · · · · · · MR. HADLEY:· Strike what?
`
`·2· · · · · · · · · MR. SMITH:· What I just -- my -- strike
`
`·3· ·my stutter.
`
`·4· · · · · · · · · MR. HADLEY:· Oh, okay.· Not his answer?
`
`·5· · · · · · · · · MR. SMITH:· Oh, no.· Sorry, no.
`
`·6· · · · · · · · · MR. HADLEY:· I was gonna say, I've never
`
`·7· ·heard of that one before, but --
`
`·8· · · · · · · · · MR. SMITH:· I'm breaking new ground here.
`
`·9· · · · Q.· ·(BY MR. SMITH)· So if a battery supplied a DC
`
`10· ·voltage signal to a circuit that had the same voltage as
`
`11· ·the -- as a signal provided by, let's say, mains power,
`
`12· ·the circuit could operate identically, correct?
`
`13· · · · A.· ·Yes.
`
`14· · · · Q.· ·So why would you use a battery in an
`
`15· ·electronic circuit, just commonly?
`
`16· · · · A.· ·Because it's portable for when you don't have
`
`17· ·access to mains outlets.
`
`18· · · · Q.· ·Could it also be useful if mains power failed?
`
`19· · · · A.· ·Yes.
`
`20· · · · Q.· ·And devices -- devices existed at the time of
`
`21· ·the '183 patent that used a battery to supplement mains
`
`22· ·power in that way, correct?
`
`23· · · · A.· ·So the question is -- sorry, just repeat the
`
`24· ·question.
`
`25· · · · Q.· ·That's fine.
`
`14
`
`
`
`·1· · · · · · · · · I said, Devices existed at the time of the
`
`·2· ·'183 patent that would use a battery to supplement mains
`
`·3· ·power in the event of a failure, correct?
`
`·4· · · · A.· ·Yes.
`
`·5· · · · Q.· ·What is a buffer amplifier?
`
`·6· · · · A.· ·It's an amplifier that acts as a -- as a
`
`·7· ·buffer between one thing and something else.
`
`·8· · · · Q.· ·Can a buffer -- buffer amplifier be used to
`
`·9· ·raise the voltage of a signal provided as input?
`
`10· · · · A.· ·Yes, it can.
`
`11· · · · Q.· ·So if you were designing an electronic circuit
`
`12· ·and you wanted information on a particular component
`
`13· ·that you were going to include in that circuit, how
`
`14· ·would you find that information?
`
`15· · · · A.· ·As a general --
`
`16· · · · Q.· ·Yeah.
`
`17· · · · A.· ·Typically, you would look at the data sheets
`
`18· ·for the -- for the component.
`
`19· · · · Q.· ·And if -- if you couldn't find the data sheets
`
`20· ·for the component, would you continue looking at other
`
`21· ·sources?
`
`22· · · · A.· ·I don't recall ever not being able to find the
`
`23· ·data sheets.
`
`24· · · · Q.· ·But let's say that you hypothetically could
`
`25· ·not find the data sheets for a particular component.
`
`15
`
`
`
`·1· ·Would you stop designing the circuit, or would you stop,
`
`·2· ·you know -- would you give up at that point?
`
`·3· · · · · · · · · MR. HADLEY:· Object to form.
`
`·4· · · · A.· ·I mean, if I've got a chip and I don't have
`
`·5· ·the data sheet for it, and the data sheet doesn't exist,
`
`·6· ·I don't know how -- why that would happen, but, you
`
`·7· ·know, let's say I've got some chip laying around; and I
`
`·8· ·want to know how to set it up, and I don't have the data
`
`·9· ·sheet.· I'd probably go and find an alternative chip
`
`10· ·that does have a data sheet.
`
`11· · · · · · · · · But again, I've never had it happen.
`
`12· ·Typically, you know, for as long as I've been working
`
`13· ·with data sheets, I've always been able to get the data
`
`14· ·sheets.
`
`15· · · · Q.· ·(BY MR. SMITH)· Let's say you wanted
`
`16· ·information about the particular component that wasn't
`
`17· ·contained in the data sheet, let's say, examples of how
`
`18· ·it was integrated into other circuits, for example.
`
`19· ·Would you look beyond the data sheet to find that
`
`20· ·information?
`
`21· · · · · · · · · MR. HADLEY:· Object to form.
`
`22· · · · A.· ·I mean, what a lot of companies do if they
`
`23· ·make -- if they make chips like that is they'll -- you
`
`24· ·know, they'll make application notes.· So you might take
`
`25· ·a look on the manufacturer's website for the application
`
`16
`
`
`
`·1· ·notes, and then, you know, you might give them a call.
`
`·2· ·That would be a typical thing if you want to ask, you
`
`·3· ·know, on how -- on how they would recommend implementing
`
`·4· ·it.
`
`·5· · · · Q.· ·(BY MR. SMITH)· Are you familiar with the term
`
`·6· ·"hertz"?
`
`·7· · · · A.· ·Like the car rental place?
`
`·8· · · · · · · · · No.· I am familiar with the term "hertz."
`
`·9· ·I'm sorry.
`
`10· · · · Q.· ·And what -- what does the term "hertz"
`
`11· ·generally refer to?
`
`12· · · · A.· ·The frequency.
`
`13· · · · Q.· ·And what's the -- what is the -- what's the
`
`14· ·meaning of the -- of the word -- of the term "hertz"?
`
`15· ·Like, what does it represent as far as the frequency?
`
`16· ·What's the unit, I guess?
`
`17· · · · A.· ·Number of cycles per second.
`
`18· · · · Q.· ·If two signals have the same hertz value, do
`
`19· ·they have the same frequency?
`
`20· · · · A.· ·Yes.
`
`21· · · · Q.· ·What's a -- what is a periodic signal?
`
`22· · · · A.· ·It's a signal that is periodic.
`
`23· · · · Q.· ·Does any signal that has a frequency -- excuse
`
`24· ·me.
`
`25· · · · · · · · · Is any signal that has a frequency
`
`17
`
`
`
`·1· ·periodic?
`
`·2· · · · A.· ·So a signal that has a frequency -- the
`
`·3· ·inverse of that is the -- the period.· So the frequency
`
`·4· ·is cycles per second, and the period is the time
`
`·5· ·between.· Correspondingly, similar points in the -- in a
`
`·6· ·signal or in a -- doesn't have to be a signal.· I mean,
`
`·7· ·it could be -- the period could be if you're pushing
`
`·8· ·someone on a swing, you know, the time -- the time
`
`·9· ·between when you push them is the period.· And the
`
`10· ·number of times that they swing in a second is the
`
`11· ·frequency.
`
`12· · · · Q.· ·How many times does a signal have to repeat to
`
`13· ·be periodic?
`
`14· · · · A.· ·I don't know that there's a specific number,
`
`15· ·but -- but a number of times, so several times, more
`
`16· ·than a -- more than a couple of times, so, you know, 10
`
`17· ·or so -- 10, 15.· But to the best of my knowledge,
`
`18· ·there's no specific number.
`
`19· · · · Q.· ·Could you calculate a hertz value for a
`
`20· ·frequency that repeated twice -- I'm sorry.· Now I'm
`
`21· ·getting confused on terminology.
`
`22· · · · · · · · · Could you calculate a frequency for a
`
`23· ·signal that repeated twice?
`
`24· · · · A.· ·So in some ways having something that occurs
`
`25· ·twice -- that's not really -- normally, the way you
`
`18
`
`
`
`·1· ·would do a frequency is you'd want -- what you'd want to
`
`·2· ·do is you'd want to take -- you know, you would want to
`
`·3· ·measure it over a period of time and sort of average
`
`·4· ·things out.· If what you're saying is can you measure
`
`·5· ·the time between two events that happened, you can
`
`·6· ·measure the time between two events.· And you can -- but
`
`·7· ·you can't tell if there's going to be any more events if
`
`·8· ·there's only two.
`
`·9· · · · · · · · · It's like -- in some ways it's like the --
`
`10· ·you know, first annual -- you know, when people schedule
`
`11· ·those first annual events, you've got no -- I mean, I'm
`
`12· ·sure there are many, many first annual events that were
`
`13· ·the last annual event too.· And so it wasn't really --
`
`14· ·was it really annual?· It wasn't really annual.
`
`15· · · · · · · · · So to me this is kind of the same thing.
`
`16· ·You know, you could say, you know, that's the time
`
`17· ·between two things, and you could say -- and you could
`
`18· ·say if this were to continue on then -- and continue on
`
`19· ·in exactly the same way that those two events did, then,
`
`20· ·you can -- then we can estimate what the frequency is
`
`21· ·going to be for the period.
`
`22· · · · · · · · · So, yes, we could do that.· But it's
`
`23· ·certainly not clear to me that you would consider that
`
`24· ·to be either periodic or representative of a frequency.
`
`25· · · · Q.· ·Signals with a duration of less than a second
`
`19
`
`
`
`·1· ·can be said to have a frequency, though, right?
`
`·2· · · · A.· ·So your question is, is can you have a
`
`·3· ·frequency if --
`
`·4· · · · Q.· ·If -- if you have a signal that repeats for
`
`·5· ·less than a second.
`
`·6· · · · A.· ·Yes, it can have a frequency, absolutely.
`
`·7· · · · Q.· ·So the time period at which the signal repeats
`
`·8· ·is not what defines whether you can calculate a
`
`·9· ·frequency, correct?
`
`10· · · · A.· ·The time period?
`
`11· · · · Q.· ·Right.· So you had said earlier that hertz is
`
`12· ·cycles per second.· You don't need a full second of
`
`13· ·signal to calculate that -- a hertz value, correct?
`
`14· · · · A.· ·No.· You can have -- you can have frequencies
`
`15· ·that are -- maybe you should repeat the question.· I'll
`
`16· ·make sure that I answer the question that you asked.
`
`17· · · · Q.· ·Sure.· So hertz -- you had testified earlier
`
`18· ·that hertz represents number of cycles per second.· Can
`
`19· ·you have a signal that lasts less than a second that
`
`20· ·still has a hertz value and still has a frequency?
`
`21· · · · A.· ·Yes.· I mean, if the signal lasts -- maybe I'm
`
`22· ·not 100 percent clear what you mean by signal lasts less
`
`23· ·than a second.· Do you mean -- well, maybe you can
`
`24· ·clarify what that means.
`
`25· · · · Q.· ·Let's say that you have a -- a signal that is
`
`20
`
`
`
`·1· ·generated for half a second and then stops.· Would
`
`·2· ·that -- the -- would you be able to calculate a hertz
`
`·3· ·value for that signal, assuming it was periodic?
`
`·4· · · · A.· ·You can, except if the frequency was so low --
`
`·5· ·well, if the frequency was so low that -- let's say the
`
`·6· ·frequency was 1 hertz.· If the frequency was 1 hertz and
`
`·7· ·you measured it for half of a second, there's no way
`
`·8· ·that you can know what the frequency is because you
`
`·9· ·wouldn't have enough signal to do that.· So the amount
`
`10· ·of time that you need depends upon how many cycles
`
`11· ·you're going to be able to measure to then use that to
`
`12· ·figure out the frequency.· So the less the number of --
`
`13· ·the less the number of cycles that you have, the more
`
`14· ·difficult it is to -- to get an accurate measure of
`
`15· ·frequency.· And when you're down to one or two cycles,
`
`16· ·you can't really measure the frequency.
`
`17· · · · Q.· ·Well, you said accurate -- accurately measure
`
`18· ·the frequency.· You can -- you can compute a hertz value
`
`19· ·from -- if you only had two cycles in a certain amount
`
`20· ·of time, you could still compute a hertz value, correct?
`
`21· · · · A.· ·If you have two cycles, you can -- you can --
`
`22· ·if you have two cycles, you don't know what's gonna
`
`23· ·happen after that, right?· But if what you're saying is
`
`24· ·can you measure the period and use the reciprocal of the
`
`25· ·period to get a -- to get a frequency, I mean, that's
`
`21
`
`
`
`·1· ·definition, so you -- so if you have the period, you can
`
`·2· ·do one over that to get a frequency.· But you
`
`·3· ·wouldn't -- but you typically wouldn't do it because,
`
`·4· ·you know, it's not -- you wouldn't necessarily think of
`
`·5· ·it as anything other than, you know, two signals that
`
`·6· ·occurred with some time in between.
`
`·7· · · · · · · · · You'd have no way of knowing whether it's
`
`·8· ·even completely periodic, right, because you don't know
`
`·9· ·what the third one is.· It could be aperiodic.· It could
`
`10· ·be that you get a signal -- you know, it could be almost
`
`11· ·like a syncopated rhythm.· You know, you get something
`
`12· ·on the first, the fourth and then the ninth beat, right?
`
`13· ·And then it could be 1, 4, 9, 1, 4, 9.· I mean, that's
`
`14· ·not -- you'd have no way of knowing anything about that
`
`15· ·unless you had more to look at.· So you don't even know
`
`16· ·that it's periodic until you've got, you know, more than
`
`17· ·two.· 'Cause it could be aperiodic, right?· It could be
`
`18· ·something where the period changes.· You don't know.
`
`19· · · · Q.· ·Isn't it possible that the period could change
`
`20· ·for any -- at any cycle in a signal?
`
`21· · · · · · · · · MR. HADLEY:· Object to form.
`
`22· · · · A.· ·If what you're saying is -- is can you have
`
`23· ·signals that are aperiodic, yes.· If you're saying could
`
`24· ·the aperiodness be once every 10,000 years?· Like, you
`
`25· ·know, for example, every hundred years or so they do a
`
`22
`
`
`
`·1· ·correction on the leap year, right, because we haven't
`
`·2· ·quite got the period right.· So we've got -- you know,
`
`·3· ·we say what the frequency is of the Earth's rotation,
`
`·4· ·whatever, whatever, whatever, but then, we make a little
`
`·5· ·correction every now and then.
`
`·6· · · · · · · · · So there can always be little things, but
`
`·7· ·the more -- the more time something is cycled through,
`
`·8· ·the more comfortable -- the more you know what the
`
`·9· ·frequency is.
`
`10· · · · Q.· ·(BY MR. SMITH)· With respect to the leap year
`
`11· ·example, would you say that the -- that that signal was
`
`12· ·periodic from one correction to the next, that the
`
`13· ·portion of the signal between the two corrections was
`
`14· ·periodic?
`
`15· · · · A.· ·Yes, you would.
`
`16· · · · Q.· ·So if you're given a portion of a signal and
`
`17· ·that portion appears periodic, you would say that that
`
`18· ·portion -- strike that.
`
`19· · · · · · · · · So if a portion of -- if a portion of a
`
`20· ·signal repeats regularly, that portion of the signal is
`
`21· ·periodic regardless of what happens outside of that
`
`22· ·portion?
`
`23· · · · A.· ·I mean, it would -- if there are enough --
`
`24· ·enough things that happen, you know -- enough peaks or
`
`25· ·drops in between, then, you would -- and they repeat
`
`23
`
`
`
`·1· ·regularly, you would say it's periodic, yes.
`
`·2· · · · · · · · · I mean, if you take -- the easiest way to
`
`·3· ·draw a straight line is to take two points and nothing
`
`·4· ·in between, right?· So, you know, basically, what we've
`
`·5· ·got if we look at the example of the rotation of the
`
`·6· ·Earth, right, is we've got all these -- we've got, you
`
`·7· ·know -- okay.· This is when January 1st this year, the
`
`·8· ·next year, the next year, the next year, the next year.
`
`·9· ·Oh, you know, we measure something, you know, and we
`
`10· ·measure where everything is, and we draw a straight
`
`11· ·line.· And then we do the correction on -- every so
`
`12· ·often.· We end up getting a line that kind of tells us
`
`13· ·what the frequency is.
`
`14· · · · · · · · · If you choose two points and only two
`
`15· ·points, you get a straight line 100 percent of the time,
`
`16· ·but you have no idea what went on, either interpolation
`
`17· ·or extrapolation, right?· So you don't -- the whole
`
`18· ·thing could be curved.· You have no way of knowing from
`
`19· ·two points, and that's really what -- you know, if you
`
`20· ·have one point, you definitely can't do anything.· And
`
`21· ·if you've got two points, you know, you can say it's a
`
`22· ·straight line, but you're making a whole lot of
`
`23· ·assumptions that you can't really make without having
`
`24· ·multiple other points.
`
`25· · · · · · · · · And that's essentially what we're doing
`
`24
`
`
`
`·1· ·when we're determining -- hertz values, is, it's like --
`
`·2· ·you know, we take all these points, and we do -- and we
`
`·3· ·do a line of best fit, and that tells what the frequency
`
`·4· ·is.· And you just can't do it with two.
`
`·5· · · · Q.· ·You said, You can't do it with two.· Can --
`
`·6· ·what did you mean by "you can't do it"?
`
`·7· · · · A.· ·You can't know with two.· You can always do a
`
`·8· ·straight line between two points.
`
`·9· · · · Q.· ·Uh-huh.
`
`10· · · · A.· ·But you can't know it's a straight line.· You
`
`11· ·can't know that it -- that if you went -- extrapolate it
`
`12· ·out that it would be a straight line.· You have no way
`
`13· ·of -- you have no way of -- of having an expected degree
`
`14· ·of certainty from only two points.
`
`15· · · · Q.· ·And with respect to a signal, you're saying
`
`16· ·that you have no way of knowing that that signal
`
`17· ·continues to repeat after two cycles?
`
`18· · · · A.· ·Yeah.· You have no way of knowing that the
`
`19· ·signal would repeat.· So, you know, you know
`
`20· ·something -- you know the two events happened, but
`
`21· ·that's it.· You don't know what -- you don't -- you
`
`22· ·couldn't extrapolate what the next one is because you
`
`23· ·don't know that it repeats.
`
`24· · · · Q.· ·If you had 10,000 cycles, could you
`
`25· ·extrapolate that the next one would be identical?
`
`25
`
`
`
`·1· · · · A.· ·So the expectation would be yes, right?
`
`·2· · · · Q.· ·But you don't know?
`
`·3· · · · A.· ·If you're saying could somebody change the
`
`·4· ·frequency or do something else, yeah.· Right?· Sure.
`
`·5· ·You don't know, but you would have a high degree of
`
`·6· ·certainty.
`
`·7· · · · · · · · · And the same way that if you -- if you
`
`·8· ·draw a best fit line with two points, you have no degree
`
`·9· ·of certainty that it does anything, but if you have a
`
`10· ·large number of points, yes, you have a high degree of
`
`11· ·certainty.
`
`12· · · · Q.· ·But regardless of if that -- if the repetition
`
`13· ·of the signal stops after, let's say, the 10,000th time,
`
`14· ·you still have a periodic signal that repeats 10,000
`
`15· ·times?
`
`16· · · · A.· ·And -- yes.· You have a periodic signal that
`
`17· ·repeated 10,000 times, and you could figure out the
`
`18· ·frequency.
`
`19· · · · Q.· ·And if you had a signal that repeated twice,
`
`20· ·you would have a periodic signal that repeated twice,
`
`21· ·and you could figure out a frequency for that, correct?
`
`22· · · · A.· ·If -- if you -- you can calculate the time
`
`23· ·between to get a period.· It really comes to, you know,
`
`24· ·do you know that it's a periodic signal?· I would say
`
`25· ·that with two points you don't know.
`
`26
`
`
`
`·1· · · · Q.· ·But it is periodic for that portion of the
`
`·2· ·signal, correct?
`
`·3· · · · A.· ·I don't know that you would think of it that
`
`·4· ·way.· I mean, you can -- when you're saying what the
`
`·5· ·period is, you're assuming that it's repeating for a
`
`·6· ·number of cycles.· So, you know, you know what the time
`
`·7· ·in between the two is.· You would have to make an
`
`·8· ·assumption that you can't tell from those -- from those
`
`·9· ·two points to use that period to calculate -- to...
`
`10· · · · Q.· ·What assumption would you have to make?
`
`11· · · · A.· ·I mean, I just wouldn't even do it, right?· If
`
`12· ·I just had -- if I had two, I just wouldn't even try to
`
`13· ·-- if I had two points, I wouldn't even try to calculate
`
`14· ·the frequency.
`
`15· · · · Q.· ·So how many points would you need?
`
`16· · · · A.· ·I mean, I think we talked about that earlier,
`
`17· ·and we said, you know, we'd be looking at 10 or 50 --
`
`18· ·you know, 10 or 50 times -- 10 or 50 cycles you'd feel
`
`19· ·confident that you were getting a frequency.
`
`20· · · · Q.· ·Woul
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