Vijay Madisetti , Ph.D.
`Canon U.S.A., Inc. Vs. Cellspin Soft, Inc.
`
`June 12, 2019
`
`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` _______________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` _______________________
`
` CANON U.S.A., INC.
`
` Petitioner,
`
` v.
`
` CELLSPIN SOFT, INC.
`
` Patent Owner
`
` Case No. IPR 2019-00127
`
` Patent No. 9,258,698
`
` _______________________
`
` DEPOSITION OF VIJAY MADISETTI, Ph.D.
`
` June 12, 2019
`
` 8:58 a.m.
`
` Veritext Legal Solutions
`
` 1075 Peachtree Street, N.E.
`
` Suite 3625
`
` Atlanta, Georgia
`
`REPORTED BY:
`
`LAURA R. SINGLE, CCR-B-1343
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`Veritext Legal Solutions
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`Canon U.S.A., Inc. Vs. Cellspin Soft, Inc.
`
`June 12, 2019
`
`Page 1
`
` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` _______________________
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` _______________________
`
` CANON U.S.A., INC.
`
` Petitioner,
`
` v.
`
` CELLSPIN SOFT, INC.
`
` Patent Owner
`
` Case No. IPR 2019-00127
`
` Patent No. 9,258,698
`
` _______________________
`
` DEPOSITION OF VIJAY MADISETTI, Ph.D.
`
` June 12, 2019
`
` 8:58 a.m.
`
` Veritext Legal Solutions
`
` 1075 Peachtree Street, N.E.
`
` Suite 3625
`
` Atlanta, Georgia
`
`REPORTED BY:
`
`LAURA R. SINGLE, CCR-B-1343
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`Veritext Legal Solutions
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`
`
`Vijay Madisetti , Ph.D.
`Canon U.S.A., Inc. Vs. Cellspin Soft, Inc.
`
`June 12, 2019
`
`Page 2
`
` A P P E A R A N C E S
`
`For the Petitioner:
` JARED W. NEWTON, Esq.
` Quinn Emanuel Urquhart & Sullivan, LLP
` 1300 I Street, N.W.
` Suite 900
` Washington, D.C. 20005
` (202) 538-8000
` jarednewton@quinnemanuel.com
`
`For the Patent Owner:
` JOHN J. EDMONDS, Esq.
` Edmonds & Schlather
` 1616 South Voss Road
` Suite 125
` Houston, Texas 77057
` (713) 364-5291
` jedmonds@ip-lit.com
`
`Also Present:
` Gruvinder Singh
` (Cellspin Soft, Inc.)
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`770.343.9696
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`Veritext Legal Solutions
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`
`
`Vijay Madisetti , Ph.D.
`Canon U.S.A., Inc. Vs. Cellspin Soft, Inc.
`
`June 12, 2019
`
`Page 3
`
` I N D E X
`
`EXAMINATION OF VIJAY MADISETTI, Ph.D. PAGE
`BY MR. EDMONDS................................. 4
`BY MR. NEWTON.................................. 48
`
` * * *
`
`NUMBER DESCRIPTION PAGE
`For the Patent Owner:
`Exhibit 1 Specification of the 12
` Bluetooth System - Master
` Table of Contents &
` Compliance Requirements
`
`Exhibit 2 Japanese Unexamined Patent 13
` Application Publication,
` 2/28/03
`Exhibit 3 An Overview of the Bluetooth 34
` Wireless Technology
`
`Exhibit 4 United States Patent 35
` Application Publication,
` 10/3/02
`Exhibit 5 United States Patent 36
` Application Publication,
` 8/24/06
`Exhibit 6 Japanese Unexamined Patent 38
` Application Publication,
` 10/27/05
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`Veritext Legal Solutions
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`Vijay Madisetti , Ph.D.
`Canon U.S.A., Inc. Vs. Cellspin Soft, Inc.
`
`June 12, 2019
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` P R O C E E D I N G S
`
` (Pursuant to Article 10(B) of the Rules and
`
` Regulations of the Georgia Board of Court
`
` Reporting, a written disclosure statement was
`
` submitted by the court reporter to all counsel
`
` present at the proceeding.)
`
` * * *
`
` VIJAY MADISETTI, Ph.D.,
`
`Having been first duly sworn to state the truth, was
`
`examined and testified as follows:
`
` EXAMINATION
`
`BY MR. EDMONDS:
`
` Q. Would you please state your name?
`
` A. Vijay Madisetti.
`
` Q. And do you realize that you're here under
`
`oath for a deposition?
`
` A. I do.
`
` Q. Is there anything about your health or
`
`wellbeing that would inhibit in any way your ability
`
`to give full and truthful answers to this deposition?
`
` A. No.
`
` Q. How many kinds of Bluetooth connections are
`
`possible?
`
` A. I didn't understand the question.
`
` Q. What different kinds of Bluetooth
`
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`Vijay Madisetti , Ph.D.
`Canon U.S.A., Inc. Vs. Cellspin Soft, Inc.
`
`June 12, 2019
`
`Page 25
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` that the priority date is December of 2007.
`
`BY MR. EDMONDS:
`
` Q. Okay. So I'm just making sure we're
`
`communicating. When you say priority date, you're
`
`referring to December of 2007, correct?
`
` A. I was asked assume December 2007 as the time
`
`mentioned.
`
` Q. So when I say priority date, you'll
`
`understand that I'm talking about December of 2007 in
`
`the context of this conversation. Understood?
`
` A. Okay. I can do that.
`
` Q. Okay. As of the priority date, was
`
`cryptographic authentication optional in Bluetooth?
`
` MR. NEWTON: Objection.
`
` THE WITNESS: I would have to refer to the
`
` standard specifically. My disclosures and
`
` reliance on Bluetooth was to show that there is
`
` cryptographic authentication, for example,
`
` mandated in security mode 3 in version 2.1; and
`
` that itself is sufficient to render obvious that
`
` cryptographic authentication in Bluetooth and the
`
` disclosure of Bluetooth in Hiroishi would render
`
` the limitation of cryptographic authentication
`
` obvious.
`
`BY MR. EDMONDS:
`
`800.808.4958
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`770.343.9696
`
`Veritext Legal Solutions
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`Vijay Madisetti , Ph.D.
`Canon U.S.A., Inc. Vs. Cellspin Soft, Inc.
`
`June 12, 2019
`
`Page 26
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` Q. So I hear you saying that cryptographic
`
`authentication is mandated in security mode 3. Is
`
`cryptographic authentication mandated in all forms of
`
`Bluetooth communication?
`
` A. Again, I'm not offering a specific opinion
`
`as to whether there are modes in Bluetooth that
`
`require cryptographic authentication. I relied on
`
`the knowledge of a person of ordinary skill in the
`
`art at the time of version 2.1, which is early July
`
`of 2007, that security mode 3 that is used in all
`
`previous versions of Bluetooth as well requires
`
`cryptographic authentication. And for that reason, I
`
`say the disclosure of Bluetooth in Hiroishi or any
`
`other product references I rely upon renders this
`
`limitation obvious to one of ordinary skill in the
`
`art.
`
` Q. Okay. So you're not relying on the opinion
`
`that cryptographic authentication is mandatory in all
`
`modes of Bluetooth, correct?
`
` A. That is not an opinion that I have offered
`
`upon. Since you asked me for an obviousness opinion,
`
`my understanding is that one of ordinary skill in the
`
`art would understand that security mode 3 mandates
`
`authentication cryptographically, as one of ordinary
`
`skill in the art reading the disclosure of Bluetooth
`
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`Veritext Legal Solutions
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`Vijay Madisetti , Ph.D.
`Canon U.S.A., Inc. Vs. Cellspin Soft, Inc.
`
`June 12, 2019
`
`Page 30
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` unrelated to this particular '698 specification.
`
`BY MR. EDMONDS:
`
` Q. So you've not offered an opinion as to
`
`whether the Bluetooth specification 2.1 has modes
`
`that do not require pairing as the word "pairing" is
`
`used in the Bluetooth specification, correct?
`
` MR. NEWTON: Objection.
`
` THE WITNESS: I mean, it's a very
`
` complicated question. Let me be very clear.
`
` In my opinion, the '698 specification, as
`
` understood by one of ordinary skill in the art,
`
` discloses the type of pairing that's not limited
`
` to Bluetooth. In my opinion, the type of pairing
`
` that is described in the '698, as understood by
`
` one of ordinary skill in the art, is disclosed in
`
` Bluetooth and is used in Bluetooth; and I have
`
` not offered a specific opinion outside the
`
` context of the '698 patent as to whether a
`
` particular type of pairing or limited form of
`
` pairing is present or not present in any
`
` particular standard.
`
`BY MR. EDMONDS:
`
` Q. If you turn back to Exhibit 1, that same
`
`page 681 that we were looking at.
`
` A. Sure. Yes.
`
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`Vijay Madisetti , Ph.D.
`Canon U.S.A., Inc. Vs. Cellspin Soft, Inc.
`
`June 12, 2019
`
`Page 31
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` Q. Do you see 7(b) where it says optional
`
`authentication for ACL connections?
`
` A. There is a step 7(b) that describes --
`
`that's labeled optional authentication on page 861;
`
`but as I described earlier, I relied upon security
`
`mode 3 that is present in Bluetooth 2.1 and earlier
`
`that mandates authentication cryptographically. For
`
`that reason, it is my opinion that the disclosure of
`
`Bluetooth in Hiroishi and other references would
`
`render obvious. Whether or not authentication is
`
`optional or not is a different question.
`
` The fact there are modes where
`
`authentication is mandated is sufficient for me to
`
`find that one of ordinary skill in the art would
`
`understand from the disclosure of the '698 patent
`
`that the type of cryptographic authentication is
`
`obvious based on the disclosure of Bluetooth in
`
`Hiroishi and other prior art references that are
`
`cited.
`
` Q. So you don't have an opinion that in
`
`Bluetooth 2.1 that cryptographic authentication is
`
`mandated in every security mode, correct?
`
` A. Again, as I said, I'm aware and the standard
`
`specifically discloses that there are modes such as
`
`security mode 3 that mandate cryptographic
`
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`Canon U.S.A., Inc. Vs. Cellspin Soft, Inc.
`
`June 12, 2019
`
`Page 32
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`authentication. I'm not offering a specific opinion
`
`as to whether mandate three, cryptographic
`
`authentication, is present in all modes; but one of
`
`ordinary skill in the art would understand that at
`
`least for the use of security mode 3 that is present
`
`in all Bluetooth standards 2.1 and below
`
`cryptographic authentication is mandated and does
`
`render obvious this limitation based on Hiroishi and
`
`its disclosure of Bluetooth.
`
` Q. Is security mode 3 referenced in Hiroishi?
`
` A. One of ordinary skill in the art would
`
`understand that Bluetooth at the time of the '698
`
`patent would be covered by the standard, which is
`
`standard 2.1 plus EDR, that was published in July of
`
`2007 and that has, for example, explicit teaching and
`
`disclosure of these security modes. So the
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`disclosure of Bluetooth in Hiroishi would convey to
`
`one of ordinary skill in the art that Bluetooth has
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`modes that mandate cryptographic authentication.
`
` Q. At paragraph 99 of your report, you have a
`
`statement that cryptographic authentication between
`
`wireless devices like a digital camera and cellular
`
`phone is routine at the time of the invention. Do
`
`you see that?
`
` A. Yes, I do.
`
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`Vijay Madisetti , Ph.D.
`Canon U.S.A., Inc. Vs. Cellspin Soft, Inc.
`
`June 12, 2019
`
`Page 52
`
` VERITEXT LEGAL SOLUTIONS
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` FIRM CERTIFICATE AND DISCLOSURE
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`Veritext represents that the foregoing transcript as
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`Certified Notaries, is a true, correct and complete
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`transcript of the colloquies, questions and answers
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`attorneys or witness in this case; and that the
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`Vijay Madisetti , Ph.D.
`Canon U.S.A., Inc. Vs. Cellspin Soft, Inc.
`
`June 12, 2019
`
`Page 53
`
` CERTIFICATE
`STATE OF GEORGIA:
`COUNTY OF GWINNETT:
` I hereby certify that the foregoing
`transcript was taken down, as stated in the caption,
`and the colloquies, questions and answers were
`reduced to typewriting under my direction; that the
`transcript is a true and correct record of the
`evidence given upon said proceeding.
` I further certify that I am not a
`relative or employee or attorney of any party, nor am
`I financially interested in the outcome of this
`action.
` I have no relationship of interest in
`this matter which would disqualify me from
`maintaining my obligation of impartiality in
`compliance with the Code of Professional Ethics.
` I have no direct contract with any
`party in this action and my compensation is based
`solely on the terms of my subcontractor agreement.
` Nothing in the arrangements made for
`this proceeding impacts my absolute commitment to
`serve all parties as an impartial officer of the
`court.
` This the 25th day of June, 2019.
`
` <%12314,Signature%>
`
` LAURA R. SINGLE, CCR-B-1343
`
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`770.343.9696
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`Veritext Legal Solutions
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