Case IPR2019-00819
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`Page 1
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`Patent 7,620,810
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`APPLE, INC.,
`Petitioner
`v.
`MPH TECHNOLOGIES OY,
`Patent Owner.
`__________________
`Case IPR2019-00819
`Patent 7,620,810
`___________________
` DEPOSITION OF DAVID MOSHE GOLDSCHLAG, PH.D.
`TUESDAY DECEMBER 17TH, 2019
`WASHINGTON, D.C.
`Reported by: Jeaninn Alexis, Stenographer
`
`MAGNA LEGAL SERVICES
`(866) 624-6221
`www.MagnaLS.com
`
`MPH Technologies Oy, Exhibit 2008
`Page 2008 - 1
`IPR2019-00820, Apple Inc. v. MPH Technologies Oy
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`Page 1
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`Patent 7,620,810
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`APPLE, INC.,
`Petitioner
`v.
`MPH TECHNOLOGIES OY,
`Patent Owner.
`__________________
`Case IPR2019-00819
`Patent 7,620,810
`___________________
` DEPOSITION OF DAVID MOSHE GOLDSCHLAG, PH.D.
`TUESDAY DECEMBER 17TH, 2019
`WASHINGTON, D.C.
`Reported by: Jeaninn Alexis, Stenographer
`
`MAGNA LEGAL SERVICES
`(866) 624-6221
`www.MagnaLS.com
`
`MPH Technologies Oy, Exhibit 2008
`Page 2008 - 1
`IPR2019-00820, Apple Inc. v. MPH Technologies Oy
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` DEPOSITION OF DAVID MOSHE GOLDSCHLAG, PH.D.
`The Deposition of David Goldschlag, Ph.D.,
`taken pursuant to the Washington, D.C. Rules of Civil
`Procedure in the above-entitled case on Tuesday
`December 17th, 2019, commencing at 9:05 a.m., taken at
`Sterne, Kessler, Goldstein, Fox, 1100 New York Avenue,
`N.W., Washington, D.C., 20005, and reported by Jeaninn
`Y. Alexis, a Notary Public and Shorthand Reporter.
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`APPEARANCES
`DANIEL S. BLOCK, ESQUIRE
`TIMOTHY L. TANG, ESQUIRE
` Sterne Kessler Goldstein & Fox
` 1100 New York Avenue, NW
` Washington, D.C. 20005
` 202.371.2600
` dblock@sternekessler.com
` On Behalf of the Petitioner
`
`JAMES T. CARMICHAEL, ESQUIRE
`STEPHEN T. SCHREINER, ESQUIRE
` Carmichael IP, PLLC
` 800 Towers Crescent Drive, 13th Floor
` Tysons Corner, Virginia 22182
` 703.646.9254
` schreiner@carmichaelip.com
` On Behalf of the Patent Owner
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`
` I N D E X
` DEPOSITION OF DAVID MOSHE GOLDSCHLAG, PH.D.
` DECEMBER 17TH, 2019
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`Page 4
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`EXAMINATION BY: PAGE
`MR. SCHREINER 8
`
`EXHIBITS: DESCRIPTION: PAGE
`Exhibit GS1 Curriculum Vitae 12
`Exhibit GS2 Claim Documents '810, '581, and '302 23
`Exhibit GS3 United States Patent Vaarala et al.,
` Patent No. US 7,620,810 B2 23
`Exhibit GS4 Declaration of David Goldschlag, Ph.D.
` for US Patent No. '810 23
`Exhibit GS5 Petition for Inter Partes Review for
` Patent No. US 7,620,810 23
`Exhibit GS6 Decision Granting Institution of
` Inter Partes Review for Patent
` No. '810 23
`Exhibit GS7 United States Patent Ishiyama et al.,
` Patent No. US 6,904,466 B1 23
`Exhibit GS8 United States Patent Murakawa Patent
` No. US 7,028,337 B2 23
`Exhibit GS9 United States Patent Ahonen Patent
` No. US 6,976,117 B2 23
`Exhibit GS10 Demystifying the IPsec Puzzle by
` Sheila Frankel 23
`Exhibit GS11 Requirements for Internet Hosts --
` Communication Layers 23
`Exhibit GS12 Security Architecture for the
` Internet Protocol 23
`Exhibit GS13 IP Mobility Support 23
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`Exhibit GS14 Security Issues in Networks with
` Internet Access 23
`Exhibit GS15 United States Patent Application
` Publication Ford et al., Pub No. US
` 2002/0112186 A1 23
`Exhibit GS16 United States Patent Vaarala et al.,
` Patent No. US 8,037,302 B2 233
`Exhibit GS17 Declaration of David Goldschlag, Ph.D.
` for US Patent No. '302 233
`Exhibit GS18 Petition for Inter Partes Review of
` US Patent No. 8,037,302 233
`Exhibit GS19 International Application Published
` Under the Patent Cooperation Treaty
` (PCT) 233
`Exhibit GS20 Decision Granting Institution of
` Inter Partes Review for Patent
` No. '302B2 233
`
`(Note: Exhibits attached hereto.)
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` PROCEEDINGS
`Whereupon,
` DAVID MOSHE GOLDSCHLAG, PH.D.,
`the witness herein, called for oral examination in the
`matter pending, being first duly sworn to tell the
`truth, the whole truth, and nothing but the truth,
`testifies as follows:
` EXAMINATION
` BY MR. SCHREINER:
` Q Good morning, Dr. Goldschlag.
` A Good morning.
` Q My name is Steven Schreiner, and I'm here on
`behalf of Carmichael IP on behalf of the patent owner,
`MPH Technologies Oy, so that's M-P-H and then
`Technologies O-Y.
` And I'm going to be asking you a series of
`questions today. The goal of my questions is not to
`confuse you in any way. If you find the question that
`I presented to be unclear, please let me know and I
`will try to rephrase it.
` We can -- we will take breaks, roughly, on
`the hour as it aligns with my questioning. If you get
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`to a point where you really need to take a bathroom
`break, of course, let me know.
` A Thank you.
` Q Let's start with just some basic background
`information.
` What's your full name?
` A David Moshe Goldschlag.
` Q Okay. And you submitted -- in these three
`proceedings that we're discussing today, which are
`IPR2019-00819, -00820, and -00821, you submitted a CV
`in each of those proceedings; is that correct?
` A I did.
` Q Has there been any updates to your CV since
`you submitted it originally?
` A I don't believe so.
` Q And describe for me how you prepared for
`this deposition.
` A There's a variety of materials; the patents
`in hand and prior art, and so I read those.
` Q Okay. And who did you meet with as part of
`your preparation for this deposition?
` A I met with the attorneys.
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` Q Okay. So that would be David Block --
` MR. BLOCK: It's Daniel Block, actually.
` MR. SCHREINER: I'm sorry. So Daniel Block
`and this gentleman here?
` MR. BLOCK: Yes, perhaps, maybe so we can
`clear it up, I can maybe introduce myself for the
`record.
` MR. SCHREINER: Sure.
` MR. BLOCK: So Daniel Block from the law
`firm of Sterne Kessler Goldstein & Fox on behalf of
`the petitioner, Apple Incorporated. With me today is
`Tim Tang, also with the law firm Sterne Kessler.
` MR. SCHREINER: T-I-M, T-A-N-G?
` MR. TANG: Timothy.
` BY MR. SCHREINER:
` Q So to loop back, Dr. Goldschlag, is it
`correct that you met with Daniel Block and Tim Tang as
`part of your preparation for this deposition?
` A That is correct.
` Q And how many times did you meet with them in
`person to prepare for the deposition?
` A I don't remember offhand, right. This is --
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`you know, started probably about the beginning of this
`year.
` Q Okay. Can you give me an estimate of the
`number of times you met with them to prepare for the
`deposition? Less than five? Five to ten?
` A Maybe five to ten.
` Q Okay. And were those meetings conducted
`here in the offices of Sterne Kessler?
` A It was probably a mix.
` Q Okay. A mix between what locations?
` A Well, here or by phone.
` Q And what rate are you being compensated for
`your expert support in these proceedings?
` A The same rate that I have been using for
`this sort of work.
` Q Okay. Which is how much?
` A $500 per hour.
` Q Does your rate of compensation change or is
`it different for when you are sitting for a deposition
`as compared to doing other work?
` A No, it's the same rate.
` Q Is your remuneration in this case in any way
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`dependent on the outcome of the case, these IPR
`proceedings?
` A No.
` Q I'd like to understand how you prepared your
`declarations for the '810, '581, and '302 patents.
` And you understand what I'm referring to
`when I refer to the '810, '581, '302 patents; correct?
` A I do.
` Q So how did you go about preparing those
`declarations?
` MR. BLOCK: Objection. Form.
` THE DEPONENT: So it's iterative, right. I
`read, we talk, right. There's some writing, I review,
`and then at some point we're done.
` BY MR. SCHREINER:
` Q Did you prepare first drafts of
`declarations, or did attorneys prepare first drafts of
`the declarations?
` A So the attorneys prepared drafts.
` Q So they prepared the first draft of the
`declaration and then you went through an iterative
`process where you reviewed and -- the declarations
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`were refined; is that accurate?
` A Yes, but I think you missed the -- there's
`an iterative process before the first draft as well.
` Q I see. So there is some discussions that
`take place before the first draft; correct?
` A Yes, that's right.
` Q Then the attorneys prepare the first draft
`of the declarations; correct?
` A Yes, that's correct.
` Q And then there's a further iterative process
`where you provide feedback and the declarations are
`updated based on your feedback; is that correct?
` A Yes, I think the overall thing is what I
`said in the beginning. This is an iterative process,
`right. And the drafting -- discussions and drafting
`are interweaved in that process.
` Q Okay. I'd like to introduce your CV as GS1.
` MR. BLOCK: Isn't this already an exhibit to
`this case?
` MR. SCHREINER: I'm sorry?
` MR. BLOCK: Isn't it already an exhibit to
`this case, the CV? Can we just refer to it as the
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`exhibit that's in the record already?
` MR. SCHREINER: I thought about doing that,
`but it seems like it was going to get complicated, so
`we're just going to -- we're going to -- it will still
`have your markings on it.
` MR. BLOCK: Okay. Just so we're clear, if
`there is, like, exhibit numbers, would you mind just
`putting those on the record, too, and then we can call
`them -- just so we are all clear.
` MR. SCHREINER: Yes, I will try to, and if
`I --
` MR. BLOCK: If not, I'll try to remind you.
` MR. SCHREINER: Yes.
` MR. BLOCK: Because it will get really
`confusing if we don't have that.
` MR. SCHREINER: So court reporter, for you.
` MR. BLOCK: So this is marked as Exhibit
`1016?
` MR. SCHREINER: Yeah, so we are going to
`mark this as GS1 for purposes of this deposition.
` (Goldschlag Deposition Exhibit GS1 marked
`for identification.)
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` (Exhibit tendered to the deponent.)
` BY MR. SCHREINER:
` Q And GS1 is the CV of Dr. Goldschlag which
`was submitted by Apple as Exhibit 1016 in connection
`with proceeding IPR2019-00819.
` The exhibit indicates that in the 1993 to
`1997 period, you helped invent the Onion routing
`invention; is that correct?
` A Yes. When I was in the naval research
`laboratory, I was one of the three coinventors of what
`was called Onion route.
` Q And can you please describe for me what is
`the Onion routing invention.
` A The Onion routing invention is a system for
`private or anonymous communication over the Internet.
`Typically, when you use the Internet to go to a
`website, the website you go to or people observing the
`Internet can tell who is talking to whom. You are
`going to that website. So Tor Onion routing lets you
`do that privately.
` Q Tor stands for the Onion router?
` A I think the Tor people like to say that it
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`stands for Tor, but it stands for the Onion router.
` Q Understood. And so how does the Onion
`routing invention go about providing anonymity for
`communications between senders and recipients over
`networks?
` MR. BLOCK: Objection. Outside the scope.
` BY MR. SCHREINER:
` Q Please answer.
` A So traditionally, communication over the
`Internet travels in packets that identify the IP
`address of the person initiating -- the device
`initiating the connection and the destination of that
`connection, so anybody seeing those packets can trace
`those back to the source and destination.
` In Onion routing, what you do is you push
`those packets through a series of intermediate steps,
`and you also change the packets as they move through
`those steps so that the source and destination is
`not -- is not known to anybody who is observing any of
`the Internet as a whole or the steps, right, or even
`the packets as they pass through.
` Q Okay. The Onion routing invention has been
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`deployed on so-called dark web for transactions
`involving illegal products; is that correct?
` MR. BLOCK: Objection. Outside the scope.
` BY MR. SCHREINER:
` Q Please answer.
` A You're sounding like my son who -- it has
`been said that his father invented the dark web, and
`that's not true. The --
` Q I want to be clear. Allow me to interject.
`I'm not suggesting that you invented the dark web or
`that you're involved in the dark web at all, I'm just
`asking: Are you aware that the Onion routing
`invention has been used for dark web transactions
`involving illicit goods?
` MR. BLOCK: Again, outside the scope.
`Objection.
` BY MR. SCHREINER:
` Q Please answer.
` A So anonymous communication was -- Onion
`routing was funded by the U.S. government, and it is
`used for a variety of purposes. And the combination
`of traffic provides the anonymity, right. If it was
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`only used for one purpose, it wouldn't provide very
`much anonymity.
` Q So Tor is used on the dark web; correct?
` MR. BLOCK: Objection. Asked and answered.
`Outside the scope.
` THE DEPONENT: I actually have never used
`Tor for that purpose.
` BY MR. SCHREINER:
` Q I'm not asking whether you used Tor for that
`purpose, I'm just trying to understand just some of
`your basic knowledge -- most of this is public
`domain -- as to how the Onion routing invention has
`been deployed by others?
` A So the Onion routing network Tor is used for
`a variety -- to access a variety of things. So it's
`used by human rights people in countries to get to
`places, and it's used for anonymous web browsing, and
`it's used for accessing parts of the dark web, right,
`the so-called dark web.
` Q Okay. Still referring to your CV, what was
`the first job where you were involved in the design of
`network security processes?
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` A I've been doing security stuff for a very
`long time. My Ph.D. from the University of Texas at
`Austin was on predictable secure systems, and that's
`related to your -- the area you're talking about.
` Q Just referring to your professional
`positions, your jobs. So would it be, for example,
`the work at NRL from 1993 to '97, or would it be the
`work for DBX from 1997 to 1999 that would be the first
`job where you were involved in the design of network
`security systems?
` A So I think it would go back to, if you are
`looking at jobs, the job I had while I was in graduate
`school in 1987 at Computational Logic.
` Q And can you describe for me the nature of
`the work you did on network security systems at
`Computational Logic?
` A So at Computational Logic, the research I
`did there was the ability to specify and improve the
`correctness of various algorithms or systems, and some
`of the systems were related to security or
`communication over network.
` Q So they involved algorithms that helped
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`provide security for communications over the Internet;
`is that correct?
` A No. You're talking about the security of
`systems that would communicate with each other over
`the Internet.
` Q When was the first -- what was the first job
`where you were involved in the design of systems that
`provided security over networks where one device is
`transmitting a packet to another device?
` MR. BLOCK: Objection. Form.
` THE DEPONENT: Where one device is
`transmitting a packet or information?
` BY MR. SCHREINER:
` Q Packet or information?
` A Yes. So as I said, I think that my earlier
`research work at Computational Logic covered areas
`where devices were sharing information with each other
`and you wanted to demonstrate the correctness of
`those, and of course, that persisted through virtually
`everything I've done since.
` Q Okay. So what I'm going to do now, I'm
`going to introduce just a series of exhibits --
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` A I did want to add something. I'm sorry. I
`should have -- I don't know if I gave you the most
`up-to-date CV. My company, New Edge Labs, was
`acquired at the beginning of the year, so we can
`provide an updated CV.
` Q Who acquired it at the beginning of 2019?
` A In Q1.
` Q What was the company that acquired New Edge
`Labs?
` A So the acquired company for whom I currently
`work is Netskope, N-E-T-S-K-O-P-E.
` Q Is that N-E-T and then capital S?
` A I don't know. One -- it's one word.
` Q So we are going to go ahead and introduce a
`series of exhibits, just to be efficient about this.
`So the first exhibit, which will be GS2, is a copy of
`the claims for these three patents that we're
`discussing in today's --
` A I'd like us to all make one correction. On
`Page 2 under Claim 7, the last two steps say D and E.
`Those bracketed letters, D and E, are actually not in
`the patent, which is part of annotating.
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` MR. BLOCK: Is there a reason you can't give
`Dr. Goldschlag the actual patents?
` MR. SCHREINER: No. I'm going to introduce
`those, of course.
` MR. BLOCK: Okay.
` BY MR. SCHREINER:
` Q Next, we are going to introduce as GS3. GS3
`is U.S. Patent No. 7,620,810, entitled "Method and
`Network for Ensuring Secure Forwarding of Messages,"
`bearing an issue date of November 17, 2009.
` MR. BLOCK: This is Exhibit 1001 to the '819
`proceedings?
` BY MR. SCHREINER:
` Q Correct. So GS3 in this deposition
`corresponds with Exhibit 1001 in the IPR2019-00819
`proceedings.
` Next, we will introduce as GS4, which is the
`declaration of David Goldschlag in IPR2019-00819 for
`the '810 patent, and it bears a marking as being
`Exhibit 1002 in IPR2019-819.
` Next, we will introduce GS5, which is the
`petition for Inter Partes review of U.S. Patent No.
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`MPH Technologies Oy, Exhibit 2008
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`7,620,810, and which is dated March 27th, 2019.
` Next, we're going to introduce as GS6 the --
`and GS6 is the decision branding institution of Inter
`Partes review for case IPR2019-00819. And it bears a
`date of September 27, 2019.
` And next, we will introduce as GS7. GS7 is
`U.S. Patent No. 6,904,466 issued to lead inventor
`Ishiyama. That's I-S-H-I-Y-A-M-A. And this patent is
`entitled "Mobile Communication Scheme Without Home
`Agents for Supporting Communications of Mobile Nodes."
`And GS7 bears a prior Bates marking of Exhibit 1004 in
`IPR2019-00819.
` Next, we will introduce as GS8, which is
`U.S. Patent No. 7,028,337, and which bears a prior
`Bates number of Exhibit 1005 in IPR2019-00819.
` Next, we will introduce as GS9, which is
`U.S. Patent No. 6,976,177 entitled "Virtual Private
`Networks," and issued in the name of an inventor
`Ahonen, A-H-O-N-E-N. And this GS9 bears a prior
`marking as Exhibit 1006 in IPR2019-00819.
` Next, we will introduce as GS10, excerpts
`from the book entitled, "Demystifying the IPsec
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`MPH Technologies Oy, Exhibit 2008
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`Page 22
`puzzle," IPsec spelled capital I, capital P, small
`s-e-c. And this text was previously marked as Exhibit
`1008 in the IPR2019-00819 proceeding.
` Next, we will introduce as GS11. GS11 is
`excerpted pages from a document entitled "Request for
`Comments 1122," also referred to RFC1122. It is
`entitled "Requirements for Internet
`host--Communication Layers." And it was -- it is
`dated October 1989 and lists as the editor R. Braden,
`B-R-A-D-E-N.
` Next, we will introduce as Exhibit GS12.
`GS12 is excerpted pages from request for comments
`2401, also referred to as RC2401. It is entitled
`"Security Architecture for the Internet Protocol." It
`lists a date of November 1998, and it lists S. Kent as
`an apparent author. This document was previously
`marked as Exhibit 1011 in IPR2019-00820.
` Next, we will mark as Exhibit GS13. GS13 is
`marked as "Request for Comments 2002," also referred
`to as RC2002. It is entitled "IP mobility support."
`It bears a date of October 1996 and lists C. Perkins,
`P-E-R-K-I-N-S, as the editor. This document was
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`MPH Technologies Oy, Exhibit 2008
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`Page 23
`previously marked as MPH Technologies Exhibit 2001 in
`IPR2019-00819.
` Next, we will mark as GS14 an article
`entitled "Security Issues in Networks with Internet
`Access," listing authors Carl E. Landwehr -- that's
`L-A-N-D-W-E-H-R -- and David M. Goldschlag.
` And lastly, we will mark as GS15 a published
`Patent Application No. US2002/011-2186 that was filed
`September 12, 2001 and was published on August 15,
`2002. It is entitled "Authentication and
`Authorization for Access to Remote Production," and it
`lists three inventors including David Goldschlag.
` Dr. Goldschlag, if I could refer you to GS3,
`which is the '810 patent.
` (Goldschlag Deposition Exhibit GS2 through
`GS15 marked for identification.)
` (Exhibits tendered to the deponent.)
` A Yes, thank you.
` Q And referring to Claim 1 at Column 10 of the
`patent, beginning at line 48.
` Do you see Claim 1 there?
` A I do.
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`MPH Technologies Oy, Exhibit 2008
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` Q Okay. And is it correct that the preamble
`of Claim 1 of the '810 patent recites a network with,
`quote, "at least one mobile terminal and another
`terminal and a security gateway there between"?
` A Can you give me one minute? I'm just
`finding my way around '810.
` Q Sure.
` A Thank you. Okay. Could you please repeat
`the question?
` Q Sure. Referring you to Column 10 of the
`patent, the '810 patent, at line -- starting at Line
`48, and extending through Line 51.
` Do you see that passage there, the preamble
`of the claim?
` A Right. I'm reading it now. Thank you.
` Q Just let me know when you have read it.
` A Yes, I've read it.
` Q Is it correct that Column 10, Lines 48
`through 51, recites a telecommunication network having
`"at least one mobile terminal and another terminal and
`a security gateway there between"; is that correct?
` A Yes, those are the words.
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`MPH Technologies Oy, Exhibit 2008
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`IPR2019-00820, Apple Inc. v. MPH Technologies Oy
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` Q And now referring to Column 10, Line 67
`through Column 11, Line 3, do you agree that it refers
`to "the mobile terminals sending a secure message and
`a secure connection from the second address of the
`mobile terminal to the other terminal via the security
`gateway"?
` A Let me read it. Yes, those are the words.
` Q So what I read reflects what is recited in
`Claim 1 of the '810 patent; correct?
` A You read some phrases from the preamble and
`from the section after.
` Q And you see those phrases?
` A I do.
` Q And agree that they're there in the '810
`patent?
` A Yes, those phrases are there.
` Q Thank you. Is it correct that Claim 1 of
`the '810 patent separately recites the mobile
`terminal, the other terminal, and the security
`gateway?
` A So the preamble states those three.
` Q If you can give me a complete answer, let me
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`MPH Technologies Oy, Exhibit 2008
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`Page 26
`
`read the question again.
` Is it correct that Claim 1 of the '810
`patent separately recites the mobile terminal, the
`other terminal, and the security gateway?
` MR. BLOCK: Objection. Asked and answered.
` THE DEPONENT: So I said that the preamble
`in Claim 1 states those three.
` BY MR. SCHREINER:
` Q And those three are also recited in the body
`of the claim. For example, in Step A of Claim 1, it
`refers to the mobile terminal and the security
`gateway.
` Do you see that?
` MR. BLOCK: Objection. Form.
` THE DEPONENT: Which part of the claim are
`you talking about?
` BY MR. SCHREINER:
` Q Step A of Claim 1 at Column 10, Line 52.
` Do you see step A there?
` A I see Step A.
` Q And does Step A separately recite a mobile
`terminal and a security gateway?
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`MPH Technologies Oy, Exhibit 2008
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`IPR2019-00820, Apple Inc. v. MPH Technologies Oy
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`Page 27
` A Yes. Claim 1, step -- Claim 1A, right,
`talks -- mentions mobile terminal and security
`gateway.
` Q It recites a mobile terminal and a security
`gateway; correct?
` MR. BLOCK: Objection. Asked and answered.
` THE DEPONENT: That's -- those are in the
`text of the claim.
` BY MR. SCHREINER:
` Q And continuing with Claim 1, do you see Step
`C?
` A I see Step C.
` Q And does Step C separately state "the mobile
`terminal and the security gateway"?
` A Step C says, "mobile terminal and security
`gateway."
` Q And if we look at the passage in Claim 1 --
`this is Column 10, Line 64, starting with "in response
`to the request message."
` Do you see that passage?
` A I see Line 64.
` Q If you look at Line 64 through Column 11,
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`Line 3, I'll give you a moment to look at that.
` A Yes, I have that.
` Q Does that passage in the body of the claim
`recite "a mobile terminal, the other terminal, and the
`security gateway"?
` A Yes, so there's the terms, mobile, terminal,
`and security gateway, and other terms.
` Q I just want to be clear. These aren't trick
`questions, I'm just trying to establish basic
`foundational facts about what's in the claims.
` MR. BLOCK: Is that a question?
` MR. SCHREINER: No.
` BY MR. SCHREINER:
` Q So the claim recites something called "the
`other terminal"; correct, referring you to Column 11,
`Line 2?
` A Yes, there's the words "other terminal."
` Q Does the -- this is not a question, but a
`point of clarification to assist this deposition. So
`when I re -- when I say the claim recites a phrase,
`that means that the claim states that phrase. So when
`I use the word "recite," that's what I mean.
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` Do you understand that?
` A Yeah, lawyer talk. I'm sorry. I would use
`the word "states."
` Q But you understand --
` A Now I do.
` Q -- when I say "recite" --
` A Now I understand.
` Q -- I mean "states"?
` A Okay.
` Q Does the claim suggest in any way that the
`recited other terminal is the recited security
`gateway?
` MR. BLOCK: Objection. Form.
` THE DEPONENT: I'm sorry, can you repeat?
` BY MR. SCHREINER:
` Q Does the claim suggest in any way that the
`recited, quote, "other terminal," is the recited,
`quote, "security gateway"?
` A The claim has the three terms: One
`terminal, another terminal, and security gateway.
` Q Do you contend that the recited other
`terminal in the claim is the security gateway?
`
`MPH Technologies Oy, Exhibit 2008
`Page 2008 - 29
`IPR2019-00820, Apple Inc. v. MPH Technologies Oy
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`
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`Page 30
` MR. BLOCK: Objection. Asked and answered.
` BY MR. SCHREINER:
` Q Please answer.
` A The claim states those three devices, but
`sometimes a device can be -- the same device can have
`two personas, two functions. Maybe that's a better
`word.
` Q Is it your contention in this case that the
`recited, quote, "other terminal" is a recited, quote,
`"security gateway"?
` Is that your contention?
` A I guess I'm saying that if you read it, you
`wouldn't want to preclude that.
` Q And why is that?
` A Because you may want to communicate with the
`security gateway as the other terminal.
` Q I'm sorry. Could you repeat that answer?
` A So I look at it as mobile terminal, another
`terminal, and the security gateway. Those are
`devices, but they're functions. So the other terminal
`may be the security gateway.
` Q But the -- isn't it correct that the claim
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`refers to communications between the mobile terminal,
`the security gateway, and the other terminal?
` A So repeat that, please.
` Q Isn't it correct that the claim refers to
`communications between the mobile terminal, the
`security gatewa
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