DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
`1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC., )
` )
` Petitioner, )
` )
`v. ) CASE NO: IPR2019-01079
` ) U.S. PATENT 7,979,023
`CARUCEL INVESTMENTS, L.P., )
` )
` Patent Owner. )
`________________________________________________________
`
` The Deposition of:
`
` VIJAY K. MADISETTI, Ph.D.
`
` Pursuant to stipulations herein
`
` Taken at the offices of
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` Janice S. Baker & Associates, Inc.
`
` 235 Peachtree Street, Northeast
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` Suite 400
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` Atlanta, Georgia 30303
`
` Before Crystal Brumbelow, CCR
`
` January 7, 2020
`
` Commencing at 9:13 a.m.
`
`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
`
`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 1
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
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` A P P E A R A N C E S
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`ON BEHALF OF THE PETITIONER:
`
` Michelle Callaghan, Esquire
`
` Roshan Mansinghani, Esquire (Telephonic)
`
` Unified Patents
`
` 1875 Connecticut Avenue, Northwest
`
` Washington, D.C. 20009
`
` (559) 214-3388
`
`ON BEHALF OF THE PATENT OWNER:
` Elvin Smith, Esquire
` Law Offices of Elvin E. Smith, PLLC
` 7914 Bryn Mawr Drive
` Dallas, Texas 75225
` (214) 238-3345
`
`ON BEHALF OF THE PATENT OWNER:
`
` Sanford E. Warren, Esquire
`
` Warren Rhoades, LLP
`
` 1212 Corporate Drive
`
` Suite 250
`
` Irving, Texas 75038
`
` (972) 550-2955
`
`ALSO PRESENT:
` Mark Lanning, Expert
`
`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
`
`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 2
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
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` 2
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` I N D E X O F E X A M I N A T I O N S
`________________________________________________________
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`3
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`Cross-Examination by Mr. Smith Page 5
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` A T T A C H M E N T S
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`Errata Sheet
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`Court Reporter's Disclosure Statement
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` T R A N S C R I P T C O D E S:
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`-- interruption/change in thought
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`. . . incomplete thought
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`(sic) denotes word/phrase that may seem strange or
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`incorrect has been written verbatim
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`(ph) phonetically spelled
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`(indiscernible) not capable of being understood
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 3
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
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` 3
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`Notice of Deposition 12
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`Declaration 12
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`Gavrilovich 13
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`Massa 30
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`Vogel 52
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`Kaewell 96
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`Thrower 98
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`Toshiba 100
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`Padovani 104
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` P R O C E E D I N G S
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` 9:13 a.m.
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` Whereupon,
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` VIJAY K. MADISETTI, Ph.D.,
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` was called as a witness herein and, having
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`been first duly sworn, was deposed and testified as
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`follows:
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` CROSS-EXAMINATION
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`BY MR. SMITH:
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` Q. Can you please state your full name for the
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`record?
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` A. It's Vijay K. Madisetti.
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` Q. All right. And it's -- you have a Ph.D.,
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`correct?
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 4
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
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` A. Yes.
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` Q. All right. Dr. Madisetti, do you -- you've
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`given your deposition before, correct?
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`5
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` A. Yes.
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` Q. About how many times?
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` A. Quite a few times.
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` Q. All right. So you understand the process and
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`that your testimony is under oath, correct?
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` A. Yes.
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` Q. And if you do not understand one of my
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`questions, will you agree to ask me to rephrase it so
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`that I can make sure you're asked -- answering a
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`question you have properly understood?
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` A. I will.
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` Q. All right. The other thing, and I can be bad
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`about this sometimes, but the court reporter is having
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`to try to take all this down, so if you will let me
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`finish my questions before you begin an answer, I'll do
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`my best to let you finish your answer before I ask
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`another question; is that fair?
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` A. Sounds good.
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` Q. All right. When were you first contacted in
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`relation to this matter?
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` A. I believe it was sometime early in 2019.
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` MS. CALLAGHAN: Counsel, before we proceed, I
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 5
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
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`6
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` do not think Mr. Smith is counsel of record in this
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` case, and I just want to put this on the deposition
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` record. The power of attorney lists Mr. Rhoades
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` and Warren and Charles Gavrilovich, and the
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` mandatory notices do as well. Perhaps I'm missing
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` something, but I just want to put that on the
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` record before we continue the proceeding --
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` MR. WARREN: Okay.
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` MR. SMITH: That's fine.
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` MR. WARREN: You can put it on the record.
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` MS. CALLAGHAN: -- because I do not think it's
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` appropriate.
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` MR. SMITH: So noted.
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`BY MR. SMITH:
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` Q. Who contacted you?
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` A. I believe it was an attorney from Haynes
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`Boone.
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` Q. All right. Do you recall who that was?
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` A. I believe it was Mr. Bajaj, Raghav B-a-j-a-j.
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` Q. Okay. And do you know what office of Haynes
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`and Boone he's in? What city?
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` A. I don't specifically remember, but it's
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`somewhere in Texas.
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` Q. All right. What did he specifically ask you
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`to do in relation to this case?
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`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 6
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`

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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
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`7
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` MS. CALLAGHAN: Let me just caution the
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` witness not to reveal privileged information.
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` MR. SMITH: Yeah.
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`BY MR. SMITH:
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` Q. And I will not be asking for privileged
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`information today, so if -- to the extent my question
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`can be interpreted that way, I'm not asking you to
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`provide that to me.
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` A. He asked me if I were willing to provide my
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`independent technical opinion.
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` Q. Uh-huh.
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` Did he describe to you anything about what the
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`case was about, generally?
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` A. I don't specifically recall what the initial
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`communications were, but I believe he may have sent me a
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`copy of the patent.
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` Q. All right. And did he send you any other
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`materials to review in addition to the patent itself?
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` A. No.
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` Q. All right. You've got certain pieces of prior
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`art that are referenced in your material.
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` Who -- did you personally find that prior art,
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`or did somebody send it to you? Or how did you come to
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`utilize those references?
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` MS. CALLAGHAN: Same -- I object to the extent
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`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 7
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`

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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
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` it requests privileged information, and I counsel
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` you not to answer to the extent the answer involves
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`8
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` privileged information.
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`BY MR. SMITH:
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` Q. I'll ask it a different -- did you personally
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`find each of the references that you've included in your
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`declaration?
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` A. I mean, there were a lot of those, a lot of
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`back and forth as to the references to use. I believe I
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`contributed some. I believe the attorneys provided
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`some.
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` Q. All right. And do you recall the ones that
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`you specifically selected?
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` A. I don't recall.
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` Q. And do you recall any specific ones that were
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`provided to you by the attorneys?
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` A. Again, I don't specifically recall.
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` Q. All right. Well, when we go through them
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`individually, we can ask on each one and see if that
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`refreshes your recollection.
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` Did you contribute to the petition that was
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`filed in this case, in terms of its preparation?
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` A. No.
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` Q. Did you review the petition that was filed in
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`this case?
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`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 8
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`

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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
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`9
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` A. I believe I did.
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` Q. All right. Did you review the petition in --
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`as something you reviewed in part of preparing your
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`declaration, or had you already prepared your
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`declaration?
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` MS. CALLAGHAN: Objection to form.
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` THE WITNESS: I believe I prepared the
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` declaration first.
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`BY MR. SMITH:
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` Q. All right.
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` A. But it was a back and forth.
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` Q. The declaration and the petition were back and
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`forth, or --
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` A. No. I mean, there was some discussion back
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`and forth, but I prepared the declaration.
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` Q. All right. It's your testimony that you
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`prepared the declaration before you saw the petition
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`itself?
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` MS. CALLAGHAN: Objection to form.
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` THE WITNESS: Again, I don't recall the
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` specifics, but that's generally my recollection.
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`BY MR. SMITH:
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` Q. All right. Who assisted you in the
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`preparation of the declaration -- and I'm not asking
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`about the input back and forth between the attorneys --
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 9
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
`10
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`staff? Secretary? Research assistant? Who helped you
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`with that process, if anyone?
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` A. I worked on it, and I was -- I worked with, I
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`believe, an attorney from Haynes Boone.
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` Q. Okay. Did you have any staff under you assist
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`-- anybody at your university or anybody associated with
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`you, not directly associated with Haynes Boone, that
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`assisted on this project?
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` A. No.
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` Q. Okay. So the declaration is solely your work
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`product?
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` A. Yes.
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` Q. All right. And all the references there,
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`you've checked? You verified that the references are
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`correct and that they say what you've reported them to
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`say in your declaration?
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` A. Yes. As I describe in my declaration, I have
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`relied on the references I cite.
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` Q. All right. And those are references you
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`selected to include in your declaration?
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` MS. CALLAGHAN: Objection to form.
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` THE WITNESS: As I said, it was a back and
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` forth between the attorneys and myself as to which
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` references to use.
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`BY MR. SMITH:
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`CSI GLOBAL DEPOSITION SERVICES
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 10
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
`11
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` Q. All right. I understand there was a back and
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`forth between you and the attorneys with respect to
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`which references.
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` How about the specific citations within the
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`reference?
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` MS. CALLAGHAN: Objection to form and --
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`BY MR. SMITH:
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` Q. Was that solely your choice, or was that
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`something that was a combined process as well?
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` MS. CALLAGHAN: And calls for work product.
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` THE WITNESS: As I said, I don't specifically
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` recall. I think there was -- I believe that I
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` would find cites, and we would discuss them.
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`BY MR. SMITH:
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` Q. But you're standing by that this declaration
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`was a declaration that you prepared, you believe all the
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`references are accurate, and this is what you've sworn
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`to be your opinion in this case, correct?
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` A. Yes.
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` Q. All right. I'm going to -- I probably
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`should've started with this first.
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` I'm handing you what I'm going to have marked
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`as Deposition Exhibit 1.
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` (Exhibit No. 1 was marked for identification.)
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`BY MR. SMITH:
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`CSI GLOBAL DEPOSITION SERVICES
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 11
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
`12
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` Q. Have you seen this exhibit before?
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` A. I believe so. I was given the notice.
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` Q. All right. And you're here testifying today
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`pursuant to that notice, correct?
`
` A. Yes.
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` (Exhibit No. 2 was marked for identification.)
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`BY MR. SMITH:
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` Q. Take a minute if you need to, to review
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`Deposition Exhibit 2 because I'd like you to verify that
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`that's a true and correct copy of the declarations and
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`attachments that you prepared for this case.
` 12
` A. Yes, it is. Exhibit 2 is my declaration dated
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`May 16, 2019.
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` Q. All right. And then it probably will help for
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`us to go ahead and review Exhibit 3 as well.
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` (Exhibit No. 3 was marked for identification.)
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` MS. CALLAGHAN: Just noting for the record
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` that the Exhibit 2 is black and white.
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` MR. SMITH: Okay. As opposed to color?
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` MS. CALLAGHAN: Just -- yeah.
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` MR. SMITH: Yeah. No problem.
`
`BY MR. SMITH:
`
` Q. Can you tell us what Exhibit 3 is?
`
` A. Exhibit 3 is the U.S. Patent 7,979,023.
`
` Q. All right. And is it your understanding that
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`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 12
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`

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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
`13
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`that was the patent that you were asked to analyze?
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` A. Yes.
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` Q. All right. And if you'll go ahead and turn to
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`page 1, we'll start -- actually, page 2 of Exhibit 2.
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` 3 is there in the event -- just so you kind of
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`have a feel of where we're going to go. We're going to
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`basically walk through your declaration.
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` Obviously, you're analyzing the claims
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`contained in Exhibit 3, so that's there for your
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`reference if we need to discuss it as part of going
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`through your declaration. Okay?
` 13
` A. Okay.
`
` Q. In terms of the outline for the table of
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`contents, is this a standard form that you utilize for
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`declarations, or did you receive this from somebody
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`else?
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` A. It's similar to what I usually use, and it is
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`-- it's similar to what I usually use.
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` Q. All right. And in terms of the -- the
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`detailed analysis where it has grounds, in terms of
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`choosing which claims that would be challenged with
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`which references, was that something that was solely
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`your work product, or was that something done in
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`collaboration with others?
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` A. That was provided to me. I did not identify
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`CSI GLOBAL DEPOSITION SERVICES
`972-719-5000
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 13
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`

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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
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`the grounds.
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` Q. Okay. And you didn't identify which claims
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`went with which grounds?
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` A. I did not.
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` Q. All right. We'll turn to page 5, and it
`
`references what you've reviewed in preparation for the
`
`declaration.
`
` We have the 023 patent, which is Exhibit 3,
`
`correct?
`
` A. Yes.
`
` Q. We have the file history, which we may or may
` 14
`not mark later.
`
` And then there are prior art references
`
`discussed below, which are -- the first one is the Massa
`
`patent.
`
` A. Yes.
`
` Q. Was that one you provided or one that was
`
`given to you? Or do you recall?
`
` A. Again, my recollection is not perfect, but I
`
`believe that was provided to me.
`
` Q. All right. What about Vogel?
`
` A. The U.S. Patent 5,613,219, I believe that was
`
`also provided to me.
`
` Q. Okay. And the European patent, Toshiba, same
`
`question.
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
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`15
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` A. That's European Patent U0482503 (sic). Again,
`
`I think that was provided to me.
`
` Q. All right. Same question as to U.S. Patent
`
`5,577,022 to Padovani.
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` A. I don't recall, and it could have been either
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`way, but I don't specifically recall.
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` Q. All right. What about U.S. Patent 4,748,655
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`to Thrower?
`
` A. I think that was provided to me.
`
` Q. All right. Same question as to U.K. Patent
`
`GB 2 227 910 to Kaewell.
` 15
` A. I think that was provided to me.
`
` Q. All right. And then same question as to U.S.
`
`Patent 5,267,261 to Blakeney.
`
` A. I think that was provided to me, but again, I
`
`don't completely recall specifics.
`
` Q. All right. And then continuing through, the
`
`background and qualification sections would have been
`
`ones that you would have prepared on your own, correct?
`
` A. Yes.
`
` Q. In Paragraph 15 of your declaration, you
`
`reference MIMO. Can you tell me just a little bit more
`
`about your experience with respect to MIMO?
`
` A. Yes. I've been active in the area of
`
`communications and signal processing for the past 25 to
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`Carucel Investments—Exhibit 2108
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
`16
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`30 years, and I have worked in this area. I've
`
`published papers in this area over that period.
`
` Q. Right.
`
` And specifically, explain to me just for a
`
`minute so I'm making sure I'm understanding it the same
`
`way you are. What is MIMO?
`
` A. MIMO is a -- is a set of techniques for having
`
`multiple antennas at the transmitter and multiple
`
`antennas at the receiver.
`
` Q. Okay.
`
` A. In a general form.
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` Q. All right. And are they -- are they receiving
`
`-- are they transmitting the same information, or are
`
`they transmitting different information?
`
` A. It depends on the context.
`
` Q. All right. In which context would it be the
`
`same, and in which -- let me just start with that.
`
` In which context would it be the same
`
`information?
`
` MS. CALLAGHAN: Objection; relevance.
`
` THE WITNESS: As I said, it depends on the
`
` context, and there are so many different contexts.
`
`BY MR. SMITH:
`
` Q. Can you give me an example of one that would
`
`be transmitting the same information with respect to
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 16
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
`MIMO?
`
` MS. CALLAGHAN: Same objection; relevance.
`
` THE WITNESS: Are you -- so could you please
`
` clarify as to what you mean by same information, to
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`17
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` be precise?
`
`BY MR. SMITH:
`
` Q. All right. The same signal, the same
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`information signal being communicated.
`
` You referenced to me previously, it could be
`
`the same or it could be different. And I'm just asking
`
`for an example of it being the same just for my
` 17
`understanding.
`
` A. Yeah. If you were trying to, for example,
`
`repeat the same signal through multiple antennas at the
`
`transmitter to take advantage of --
`
` Q. And why would you do that? What would be the
`
`advantage of doing that?
`
` MS. CALLAGHAN: Same objection.
`
` THE WITNESS: I mean, it's the same context.
`
` It depends on the context.
`
` In some cases, you may want to -- you may want
`
` to receive -- you may want to receive a better copy
`
` of the signal. Sometimes you may want to improve
`
` the data rate.
`
`BY MR. SMITH:
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`CSI GLOBAL DEPOSITION SERVICES
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 17
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
`18
`
` Q. Would I be improving the data rate if I'm
`
`transmitting the same signal?
`
` A. It depends on if you lost -- if one of the
`
`paths were very poor in terms of throughput, then you
`
`may be able to get a better path that has higher data
`
`rate.
`
` Q. So in that instance, the improvement you're
`
`discussing would be due to the switching between which
`
`path had the best connection or best signal?
`
` A. Again, as I said, these are general questions.
`
`It depends on the context, but that could be an example
` 18
`of a case where you have a bad path and you switch to a
`
`better path.
`
` Q. All right. And then with respect to why you
`
`would be transmitting different signals, what would be
`
`an example -- and we're just asking in general. I'm
`
`trying 10,000 foot to understand the use of the term
`
`right now.
`
` MS. CALLAGHAN: And objection to relevance.
`
` THE WITNESS: Like I said, I mean, if you're
`
` pointing to a specific portion of my declaration --
`
`BY MR. SMITH:
`
` Q. I'm not at the moment. I'm asking you --
`
` A. Yeah.
`
` Q. You've referenced MIMO not only here, but it's
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`CSI GLOBAL DEPOSITION SERVICES
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 18
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
`also in some of the patent references that you've
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`utilized. And I'm just asking for your general
`
`understanding of it in the context of the 023 and in the
`
`context of the prior art you've referenced.
`
` A. Oh, you are asking with respect to how MIMO is
`
`19
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`used --
`
` Q. I'm not -- I'm not asking --
`
` A. Oh.
`
` Q. -- specific, right?
`
` A. Okay.
`
` Q. I'm just asking general. But I'm saying
` 19
`you've mentioned it, so I want to understand generally
`
`how -- your understanding of how it worked.
`
` We will get to the specifics as we continue
`
`on.
`
` MS. CALLAGHAN: Objection to relevance.
`
`BY MR. SMITH:
`
` Q. You can refer to...
`
` A. Yes. So what is the question?
`
` Q. I'm asking for an example -- a real-world
`
`example of why it would be beneficial to transmit
`
`different signals between those antennas.
`
` A. Again, it depends on the context. You may
`
`want to -- you may want to, in some contexts, improve
`
`upon the throughput so you can have different streams of
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
`20
`
`information from different antennas. You could be
`
`sending them to -- you could, that way, increase the
`
`rate at which you're transferring information.
`
` Q. Okay. Yeah. And I was just -- high level.
`
` Before we move on to the next, with respect to
`
`cellular systems in the use of MIMO, can you tell me
`
`what transit (sic) diversity is?
`
` A. I didn't understand the specific terms you're
`
`using. What was it that you asked?
`
` Q. Transit (sic) diversity.
`
` A. I am unsure as to that particular term.
` 20
` Q. All right. Can you explain to me what spatial
`
`multiplexing is?
`
` A. Yes.
`
` Q. And what is spatial multiplexing?
`
` A. Again, it means a lot of things but in
`
`different contexts --
`
` Q. Let me just -- since you've raised the
`
`objection, I will clarify the question so that we're on
`
`the same page.
`
` In the context of MIMO use and cellular
`
`systems, what is spatial multiplexing?
`
` A. You can transmit -- again, it's not part of my
`
`declaration, but it is called layering. And it allows
`
`you to improve the rate at which you're transmitting.
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`CSI GLOBAL DEPOSITION SERVICES
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 20
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
` Q. All right. Continuing in your declaration at
`
`page 15, you have an understanding of the patent law
`
`that is included there. As you testified previously,
`
`21
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`you --
`
` A. One second. I'm --
`
` Q. I'm sorry.
`
` A. You're going to which page?
`
` Q. Page 15.
`
` A. Okay. Yes.
`
` Q. And it's my understanding that for purposes of
`
`your declaration, that you're testifying that the
` 21
`understanding of the patent law that you utilized for
`
`this declaration -- was that given to you by
`
`Petitioner's attorney? Is that correct?
`
` A. Yes.
`
` Q. And I just want to make sure that you haven't
`
`used any other understanding that you may have obtained
`
`from other cases you've worked on; is that accurate?
`
` A. I mean, this understanding is generally
`
`consistent with my own understanding and experience, so
`
`I don't see any difference.
`
` Q. All right. But you didn't understand anything
`
`they communicated to you to be different than your prior
`
`understanding, and you used your prior understanding in
`
`preparing your report?
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`Page 21
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
`22
`
` MS. CALLAGHAN: Objection; misstates
`
` testimony.
`
` THE WITNESS: That's not my testimony.
`
`BY MR. SMITH:
`
` Q. Well, please clarify it for me.
`
` A. Yeah. I mean, I applied the understanding I
`
`was provided, and that was -- is generally consistent
`
`with my previous understanding as well.
`
` Q. Okay. That's really all I had on the
`
`background.
`
` Let's skip over to page 20 in Paragraph 43.
` 22
`You reference there, briefly, Mears as -- General
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`Electric was developing mobile repeater stations placed
`
`in vehicles.
`
` What's the purpose of a mobile repeater
`
`station?
`
` A. There can be, again, many different reasons
`
`for using mobile repeaters depending on the context of
`
`use.
`
` Q. What context of use were you referring to in
`
`your reference to Mears that was included as the
`
`reference at Paragraph 43?
`
` What context are you using for developing
`
`mobile repeaters placed in the vehicles?
`
` A. So as I describe in Paragraph 43, I was
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 22
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`

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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
`23
`
`referring to the -- that even as early as 1983,
`
`companies like General Electric were developing mobile
`
`repeater stations in vehicles.
`
` Q. And for those instances, what was the purpose
`
`of the mobile repeater station?
`
` A. It was something like -- working in some sense
`
`like a -- like an apparatus that would receive signals
`
`from the fixed base station and transmit the signals to
`
`the mobile devices.
`
` Q. All right. Was there any -- was there any
`
`other functionality with these mobile repeater stations?
` 23
` A. Again, we have to look at Mears to be
`
`specific. My understanding is that these would be --
`
`these would have a lot of features, depending on the
`
`context of use.
`
` Q. Were they merely retransmitting the same
`
`received signal further?
`
` A. Again, it depends on the context. They could
`
`do additional processing. They could -- I mean, as I
`
`said, it depends on the context and the particular
`
`reference.
`
` Q. Well, I'm asking with respect to Mears as you
`
`were utilizing it here.
`
` A. I mean, I would like to refresh my memory and
`
`have a look at the Mears.
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`CSI GLOBAL DEPOSITION SERVICES
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`Carucel Investments—Exhibit 2108
`IPR2019-01079: Unified Patents, Inc. v. Carucel Investments L.P.
`Page 23
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`DEPOSITION OF VIJAY K. MADISETTI, PH.D.
`January 7, 2020
`
` Q. Well --
`
` A. Then I can provide a precise answer.
`
` Q. All right. Well, let's take -- you know what?
`
`I don't think we brought Mears. We'll come back to
`
`24
`
`that.
`
` A. Okay.
`
` Q. But as we sit here right now, you have no
`
`recollection of what that was?
`
` A. No. As I said, I would like to look at Mears.
`
`My understanding is that this technology of using mobile
`
`repeater stations with various capabilities was well
` 24
`known, even in the early '80s.
`
` Q. Was Mears a reference that you found, or was
`
`it a reference that was given to you?
`
` A. Again, I think I may have found it, but again,
`
`I don't specifically recall.
`
` Q. All right. Let's dive in on page 26 and
`
`let's -- actually, we'll turn over to 27. And I want to
`
`start with a -- well, let me ask this.
`
` Do you teach courses in addition to doing
`
`research at the university?
`
` A. I do.
`
` Q. All right. What courses do you teach?
`
` A. I teach signal processing, communications,
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`computing and control systems courses.
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