BRANIMIR VOJCIC, PhD 1/28/2021
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` APPLE, INC.
` Petitioner
`
` v.
`
` MAXELL, LTD.
` Patent Owner
`
` Case No. IPR2020-00202
` U.S. Patent No. 10,212,586 B2
`
` _______________
`
`REMOTE DEPOSITION OF BRANIMIR VOJCIC, PhD
`
` Taken on Behalf of Petitioner
`
` Thursday, January 28, 2021
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`www.alaris.us
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
`
`IPR2020-00202
`Apple Inc. EX1060 Page 1
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`
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` APPLE, INC.
` Petitioner
`
` v.
`
` MAXELL, LTD.
` Patent Owner
`
` Case No. IPR2020-00202
` U.S. Patent No. 10,212,586 B2
`
` _______________
`
`REMOTE DEPOSITION OF BRANIMIR VOJCIC, PhD
`
` Taken on Behalf of Petitioner
`
` Thursday, January 28, 2021
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
`
`IPR2020-00202
`Apple Inc. EX1060 Page 1
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` BRANIMIR VOJCIC, PhD 1/28/2021
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`Page 2
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` INDEX OF EXAMINATION
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`BRANIMIR VOJCIC, PhD PAGE
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`Examination by Mr. Snader. . . . . . . . . . . . 6
`
` oOo
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` PREVIOUSLY MARKED EXHIBITS
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` Ex. 1001 - Page 7, Line 17
` Ex. 1004 - Page 8, Line 1
` Ex. 2022 - Page 8, Line 3
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` oOo
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`Fax: 314.644.1334
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` BRANIMIR VOJCIC, PhD 1/28/2021
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`Page 3
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` APPLE, INC.
` Petitioner
`
` v.
`
` MAXELL, LTD.
` Patent Owner
`
` Case No. IPR2020-00202
` U.S. Patent No. 10,212,586 B2
`
` _______________
`
` REMOTE DEPOSITION OF BRANIMIR VOJCIC, PhD,
`
`produced, sworn and examined on Thursday, January 28,
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`2021, between the hours of 9:05 a.m. and 10:25 a.m.
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`of that day, before Connie McCarthy, CCR, RMR, CRR.
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`ALARIS LITIGATION SERVICES
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`Fax: 314.644.1334
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`IPR2020-00202
`Apple Inc. EX1060 Page 3
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` BRANIMIR VOJCIC, PhD 1/28/2021
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`Page 4
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` A P P E A R A N C E S
`
` For the Petitioner:
` ROBIN SNADER, ESQ.
` (via Zoom)
` PAUL R. HART, ESQ.
` (via Zoom)
` ERISE IP, P.A.
` 7015 College Boulevard
` Suite 700
` Overland Park, Kansas 66211
` (913) 777-5600
` robin.snader@eriseip.com
` paul.hart@eriseip.com
`
` For the Patent Owner:
`
` ROBERT G. PLUTA, ESQ.
` (via Zoom)
` MAYER, BROWN, LLP
` 71 South Wacker Drive
` Chicago, Illinois 60606
` (312) 701-8641
` rpluta@mayerbrown.com
`
`Reported By:
`Connie McCarthy, RMR, CRR
`MO CCR #1435
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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` BRANIMIR VOJCIC, PhD 1/28/2021
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`Page 5
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`Thursday, January 28, 2021 9:05 a.m.
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` COURT REPORTER: We're on the record.
`
` I'm going to read the stipulation in, and
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`then I will swear in the witness.
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` The attorneys participating in this
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`deposition acknowledge that I am not physically
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`present in the deposition room and that I will be
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`reporting this deposition remotely.
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` They further acknowledge that, in lieu of
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`an oath administered in person, I will administer the
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`oath remotely.
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` The parties and their counsel consent to
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`this arrangement and waive any objections to this
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`manner of reporting.
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` Please indicate your agreement by stating
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`your name and your agreement on the record.
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` MR. PLUTA: This is Rob Pluta for Maxell.
`
`I agree.
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` MR. SNADER: Robin Snader of Apple. I
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`agree.
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` COURT REPORTER: Dr. Vojcic, could you
`
`raise your right hand, please?
`
` (Witness sworn)
`
`//
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`Fax: 314.644.1334
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` BRANIMIR VOJCIC, PhD 1/28/2021
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`Page 6
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` BRANIMIR VOJCIC, PhD,
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` called as a witness by the Petitioner, having
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` been duly sworn, testified as follows:
`
` EXAMINATION
`
`BY MR. SNADER:
`
` Q. Good morning, Dr. Vojcic. My name is Robin
`
`Snader. Nice to meet you.
`
` A. Good morning, Counsel. Nice to meet you,
`
`too.
`
` Q. Have you been deposed before, Dr. Vojcic?
`
` A. Yes, I have.
`
` Q. About how many times?
`
` A. Probably over 30.
`
` Q. Okay.
`
` A. Maybe 40. I don't know. Somewhere in that
`
`range.
`
` Q. Okay. In that case, you're probably
`
`familiar with the ground rules, but I'd like to cover
`
`them just for the record.
`
` First, I'll ask the question, and you'll
`
`respond. You let me finish my question and I'll let
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`you finish your answer. I'm sure the court reporter
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`would appreciate it if we didn't talk over each
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`other, particularly in light of the remote nature of
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`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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` BRANIMIR VOJCIC, PhD 1/28/2021
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`Page 7
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`this deposition.
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` I'll be planning to take a break about
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`every hour or so, but if you need a break before
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`then, just let me know. The only thing I ask is that
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`we finish up the question we're on before we take
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`that break.
`
` Before we jump into the substance, I'd like
`
`to get some naming conventions out of the way. The
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`patent we're here to talk about today, subject to
`
`this IPR, is U.S. Patent No. 10,212,586. Do you have
`
`a copy of that?
`
` A. I do.
`
` Q. If I just refer to that as the '586 patent,
`
`you'll understand what I'm referring to?
`
` A. I will.
`
` Q. And just for the record, that's
`
`Exhibit 1001 in the IPR proceeding.
`
` Next we're going to discuss United States
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`patent application Publication No. 2006/0041746 to
`
`Kirkup. Do you have a copy of that?
`
` A. I do.
`
` Q. And if I just refer to that as Kirkup,
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`you'll understand what I'm referring to?
`
` A. Yes, sir.
`
` Q. And again, for the record, that's
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`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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` BRANIMIR VOJCIC, PhD 1/28/2021
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`Page 8
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`Exhibit 1004 in the IPR proceeding.
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` I'd also like to discuss the declaration
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`you submitted in this proceeding, Exhibit 2022. Do
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`you have a copy of that?
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` A. I do.
`
` Q. Okay. And if I refer to that as your
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`declaration, will you know what I'm referring to?
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` A. Yes, sir.
`
` Q. All right. Excellent.
`
` I'd like to start first with your
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`declaration. Can you turn, please, in your
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`declaration to Paragraph 69? Just let me know when
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`you get there.
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` A. I am there.
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` Q. You included a chart which you've
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`characterized as including exemplary citations to the
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`'586 patent for certain claim limitations. The
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`limitations 1(f) and also at 16(e), which require
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`performing -- just say performing short range
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`wireless communications while both terminals are
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`locked point to steps 801 and 802 in Figure 8, and
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`the corresponding description at Column 6, Line 63,
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`to Column 7, Line 8 in the '586 patent; is that
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`correct?
`
` A. That's correct.
`
`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
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`Page 9
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` Q. Is it correct that steps 801 and 802
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`provide support for the short range wireless
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`communications in limitations 1(f) and 16(e)?
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` A. That is my -- that is my intention, unless
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`I made a typo.
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` Q. Let take a look at the '586 patent, in that
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`case. Let's go to paragraph -- I'm sorry, Column 6,
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`Line 63, and Column 7, Line 8.
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` Did you review those sections?
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` A. Not yet.
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` Yeah, okay, I did.
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` Q. I'll repeat my question. Is it correct
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`that steps 801 and 802 provide support for the short
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`range wireless communication in limitations 1(f) and
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`16(e)?
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` MR. PLUTA: Object to form.
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` THE WITNESS: Yeah, I definitely -- it's
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`for wireless -- short range wireless communication,
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`and it's also referring to embodiment one. So it's
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`same configuration, not repeating again.
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`BY MR. SNADER:
`
` Q. Dr. Vojcic, what is the purpose of the
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`communication performed at steps 801 and 802?
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` MR. PLUTA: Object to form.
`
` THE WITNESS: Well, it's a long story, but
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`www.alaris.us
`
`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
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`Page 10
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`it's the -- the idea is to identify the terminals
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`within the range of short range communication so that
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`they could eventually -- they could eventually
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`establish communication and be unlocked for purposes
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`described in the '586 patent.
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`BY MR. SNADER:
`
` Q. So to make sure I'm understanding you
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`correctly, the purpose is to identify an in-range
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`available device?
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` A. Device -- or devices, rather.
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` Q. Or devices. Okay.
`
` A. Yeah.
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` Q. Does the '586 patent describe any specific
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`information that's communicated at steps 801 and 802?
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` A. In just steps 801 or 802?
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` Q. Any specific information that's
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`communicated at steps 801 and 802.
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` A. Doesn't explicitly show how communication
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`is -- is communicated, but from the step 802, it
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`implies that some exchange is -- of information is
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`communicated because it has to determine -- sorry,
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`sorry, sorry. I was looking at wrong figure. Just a
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`moment.
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` Yeah, it has to determine whether the --
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`whether a mobile terminal in the neighborhood is
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`www.alaris.us
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`Phone: 1.800.280.3376
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`IPR2020-00202
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`Page 11
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`registered. So it implies that some information is
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`exchanged, and I don't remember exactly embodiment
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`one how it was described there, where it was
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`transcribed in more detail.
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` Q. Okay, let's look at the embodiment of
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`Figure 1. If you can turn to Column 4 -- yes,
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`Column 4, Line 1, to Column 4, Line 13.
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` A. That's Figure 2?
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` Q. Yes, if you turn back to --
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` A. Yes, yeah. Yeah.
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` Yeah, it says that -- searches for mobile
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`terminal in which the short range wireless
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`communications are established by receiving the radio
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`waves. And again, in the next paragraph, the mobile
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`terminal 1 determines whether there is a mobile
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`terminal in the neighborhood and it is previously
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`registered mobile terminal.
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` So it also -- it's similar, actually,
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`language as in figure -- as for Figure 8. So which
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`implies that there was communication already
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`established and that there was some exchange of
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`information to determine whether it is registered.
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` Q. So for steps 801 and 802 and analogous
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`steps 202 and 203 of Figure 1, which are referenced,
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`there's no specific information that's described as
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`www.alaris.us
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`ALARIS LITIGATION SERVICES
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`being communicated?
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` A. There is no specific information that shows
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`that it's being communicated, but it -- it -- it
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`shows that there was communication for determination
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`whether these mobile terminals in the range of short
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`range wireless communication were registered. So
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`there was some communication.
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` And also, if you look specifically in this
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`just last part that you looked, that communication
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`was established, which, by itself, implies that there
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`was communication of control messages that could be
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`used for connection establishment between pairs of
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`transceivers. You know, that may be different
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`messages in different file standards, but, you know,
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`at least a couple of messages involved in actions.
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` Q. Just general control messages communicated
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`on an available device, but no specific information?
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` A. Not to locate. Not to locate. It could --
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`well, it could determine that they're in the range by
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`receiving the inputs, right. But since they
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`established communication, that inherently implies
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`that that was the exchange of messages.
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` In addition to this checking of whether
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`they are registered, which means there is some
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`exchange of information there.
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`www.alaris.us
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
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`Fax: 314.644.1334
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`Page 13
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` Q. Checking who's registered. It happens at
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`step eight oh --
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` A. 802, I think.
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` Q. Okay. I'd like to switch gears for a
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`moment, and -- to Kirkup. You can pull that out.
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`And in particular, I'd like to refer to the sections
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`in Kirkup that describe Figure 2.
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` A. Sorry, you were breaking up a little bit.
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`A section that describes...?
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` Q. Figure 2. Turn to Paragraph 76 of Kirkup.
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` A. Oh, just this reminds me. I forgot to
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`mention, I want to report a typo that I had in my
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`declaration. And let me see which paragraph it was.
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`If I may.
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` Q. Absolutely.
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` A. Yeah, so it's last line in Paragraph 143.
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`Instead of unlocked, should read locked.
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` Q. Okay. Let me go to that.
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` A. Okay. I am at Paragraph 76.
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` Q. Okay. So Paragraph 76 -- in Paragraph 76,
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`Kirkup states that the authentication process
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`depicted in Figure 2 may begin either at the PC 110
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`or at the handheld electronic device 120. Is that
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`correct?
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` A. That's what it says, yeah.
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`www.alaris.us
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
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` Q. So do you agree that Figure 2 broadly
`
`captures these alternative authentications where the
`
`process begins at either the PC or the handheld
`
`electronic device?
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` MR. PLUTA: Object to form.
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`BY MR. SNADER:
`
` Q. I'm sorry, could you answer the question?
`
` A. You are asking whether I agree that the
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`authentication initiation may begin at either the PC
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`or handheld device?
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` Q. My question was whether Figure 2 broadly
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`captures these alternative embodiments where the
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`process begins either at the PC or a handheld
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`electronic device?
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` MR. PLUTA: Renewing my objection. And can
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`you guys hear me okay?
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` THE WITNESS: Now, yes. I didn't hear the
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`objection.
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` MR. PLUTA: Okay. I'll speak up.
`
` THE WITNESS: My understanding is that it
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`generally allows this authentication process to start
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`at either place, to be initiated at either place.
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`BY MR. SNADER:
`
` Q. Well, just to clarify, it is method 200 as
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`depicted in Figure 2?
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`Page 15
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` A. I didn't understand the question. About
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`200?
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` Q. You said it allows the process to begin
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`either at the PC or the handheld electronic device.
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`Could you clarify that it is the method 200 that is
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`depicted at Figure 2?
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` A. No. I meant authentication initiation is
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`it. So authentication initiation may begin at either
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`the HED or the PC.
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` Q. And is authentication initiation depicted
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`in Figure 2?
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` A. Could you speak up? Not speak up, but
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`speak little bit slower?
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` Q. Sure. Is authentication initiation part of
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`Figure 2?
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` A. Yes, it is.
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` Q. And so when you say authentication
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`initiation can begin at the handheld electronic
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`device or the PC, would you agree that Figure 2
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`depicts implementations where the handheld electronic
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`device begins the initiation and where PC begins the
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`authentication initiation?
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` A. Either of them could initiate.
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` Q. In the method of Figure 2?
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` A. That -- yes.
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`Page 16
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` Q. Thank you.
`
` Turning now to Paragraph 78. Paragraph 78
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`states that, At step 210, the handheld electronic
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`device 120, or PC 110, depending on whether the
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`authentication initiation occurred at the handheld
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`electronic device 120 or the PC 110.
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` A. Hold on, hold on. I'm not following. You
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`said Paragraph 78. Which is this table of, in my
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`copy, table of Claims 14, 16.
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` Q. Paragraph 78 of Kirkup?
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` A. Oh, all right. Yes.
`
` Please. Go ahead, Counsel.
`
` Q. Paragraph 78 states, At step 210, the
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`handheld electronic device 120, or PC 110, depending
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`on whether the authentication initiation occurred at
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`the handheld electronic device 120 or PC 110 checks
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`whether communication link 115 has been established.
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` Is that correct?
`
` A. That's correct.
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` Q. Do you agree that Figure 2 captures at
`
`least two alternative implementations, one in which
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`the PC performs the check and second in which the
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`handheld electronic device performs the check?
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` A. That's not explicitly -- that's not
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`explicitly stated in this Paragraph 78, but it's
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`Page 17
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`possible.
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` Q. So Figure 2 does cover an embodiment where
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`the PC performs the check?
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` A. That's possible.
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` Q. And Figure 2 captures an implementation
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`where the handheld electronic device performs the
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`check?
`
` A. That's correct.
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` Q. Okay.
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` A. I'd just say that's possible.
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` Q. Continuing in Paragraph 78 of Kirkup,
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`Kirkup explains that the authorization input may
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`either be a coded or uncoded, and then gives examples
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`of that. Do you agree that Kirkup covers an
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`implementation -- sorry. Withdraw that question.
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` Do you agree that Figure 2 depicts an
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`implementation where the authorization input at
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`step 220 is a coded input and an implementation where
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`the authorization input at step 220 is an uncoded
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`input?
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` MR. PLUTA: Object to form.
`
` THE WITNESS: It's too long question. I
`
`couldn't really follow.
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`BY MR. SNADER:
`
` Q. Kirkup says the authorization input may
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`Page 18
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`either be coded or uncoded; is that correct?
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` A. That's correct.
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` Q. Does Figure 2 depict an implementation in
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`which the authorization input is coded?
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` A. Yeah, that's allowed by Paragraph 79.
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` Q. And does Paragraph 79 cover an
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`implementation -- does Figure 2 cover an
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`implementation in which the authorization input is
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`uncoded?
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` A. It does, yes.
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` Q. Please go to Paragraph 83 of Kirkup.
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` A. 83?
`
` Q. Eight three.
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` A. I am there.
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` Q. Kirkup states, Authentication method 200
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`may alternatively be performed so as to check the
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`establishment of the communication link 115 after the
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`authorization input has been requested and validated,
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`and gives steps 220, 225, but before accessing user
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`authentication code at step 230.
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` Is that correct?
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` A. That's correct.
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` Q. So that would change the order in which the
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`steps are performed? Would it change the order
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`moving step 210 in the flow chart down below step
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`Page 19
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`225?
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` A. Well, I am not sure if it would go below
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`225, but certainly after -- after the authorization
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`input. I mean, it's not -- it's not specific, where
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`exactly. The check could happen before authorization
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`input is valid or after input authorization is valid.
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`But certainly saying after authorization input,
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`right.
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` Q. Okay. So Figure 2 covers an implementation
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`in which the step 210 occurs after step 225, and the
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`implementation in which step 210 occurs after
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`step 220 but before step 225? Is that what you're
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`saying?
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` A. Just a moment. Just so I can look at it
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`more carefully.
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` Actually, does say in parenthesis, after
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`225, so you're -- you're incorrect in your first
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`question.
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` Q. So just to clean up the record there,
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`Figure 2 contemplates an implementation in which the
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`order of steps is completely changed so that step 210
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`moves down the flow chart below step 225; is that
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`correct?
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` A. That's correct.
`
` Q. Turning to Paragraph 120 in your
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`Page 20
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`declaration.
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` A. I am there.
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` Q. You cite Paragraph 82 of Kirkup and you
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`say, Kirkup also teaches a configuration when the
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`second-level function authorization input is not
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`required.
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` Is that correct?
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` A. That's what I said.
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` Q. And then in Paragraph 122 of your
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`declaration, you have an illustration of Figure 2
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`that's annotated in accordance with this disclosure
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`at Paragraph 82 of Kirkup; is that correct?
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` A. That's -- that was the intent.
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` Q. So in the figure, annotated Figure 2 that
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`occurs at Paragraph 122 of your declaration, you
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`assume that the handheld electronic device is
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`unlocked, and assume that the handheld electronic
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`device does not require a second-level authorization
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`input; is that correct?
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` A. That's -- that's correct. But that was
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`sort of hypothetical scenario that it's unlocked
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`because I explained in multiple places, including
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`previous, you know, several paragraphs, that it's my
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`understanding that in Kirkup, in Figure 2, when it's
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`applied to wireless for sure, and in some other
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`Page 21
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`embodiments too, it's locked. Then Figure 2 starts.
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` Q. Is it your opinion that Figure 2
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`contemplates a scenario where a handheld electronic
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`device is unlocked, when Figure -- when the
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`authentication method at Figure 2 begins?
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` A. No. No. My understanding is that it's
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`locked. And here what I was trying to -- I forgot
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`exactly what I was saying, but I was sort of trying
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`to say even if it is unlocked, as Dr. Shoup was
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`trying to suggest, you know, what would happen in
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`that case? And I forgot exactly now the discussion,
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`but -- that was here, but I believe there was some
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`still deficiencies.
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` Q. Turning back to Paragraph 120 of your
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`declaration.
`
` A. Sorry, 2020?
`
` Q. Paragraph 120.
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` A. 120. I'm there.
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` Q. You say, Kirkup teaches a configuration
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`when the second-level function of the authorization
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`input is not required.
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` A. Correct.
`
` Q. And looking at the annotation of Figure 2
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`that occurs directly above Paragraph 120 -- I guess
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`that's part of Paragraph 118 -- you have an
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`Page 22
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`annotation that says, handheld electronic device is
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`already unlocked when the authentication process
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`begins; is that correct?
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` A. I don't see that. You said Paragraph 118?
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` Q. The annotation of Figure 2 that occurs
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`directly above Paragraph 120 on Page 59.
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` A. I am not following. So I'm -- you are
`
`sending me to which paragraph?
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` Q. Can you turn to Page 59 of Exhibit 2022?
`
` A. I'm there.
`
` Q. Do you see the figure at the top of that
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`page, the annotated version of Figure 2?
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` A. No.
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` Q. I think I may see the problem. Can you
`
`turn -- do you have the Page 59 that says Page 59 of
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`106 at the bottom right-hand corner?
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` A. Page 59 says Page 62 of 106.
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` Q. Can you turn back to -- three pages to the
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`one that says Page 59 of 106?
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` A. I'm there.
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` Q. Do you see the annotated version of
`
`Figure 2 at the top of that page?
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` A. Yes. Yes, I do. Above the Paragraph 120?
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` Q. Yes.
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` A. Okay.
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`Page 23
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` Q. So the annotation there says, Handheld
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`electronic device is already unlocked when the
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`authentication process begins; is that correct?
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` A. That's correct.
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` Q. So turning to Paragraph 122, where we were
`
`before, the previous annotated version?
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` A. Okay.
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` Q. The same annotation appears there; is that
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`correct?
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` A. Oh, yeah. I misread. So it says unlocked.
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` Okay, so my previous comment for
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`hypothetical scenario was for locked. Yeah, I
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`misread. Yeah, it's -- it's same -- it's same
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`annotation, I agree, for the unlocked case.
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` Q. So for the annotated Figure 2 that occurs
`
`in Paragraph 122, you assume that the handheld
`
`electronic device is unlocked and assume that the
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`handheld electronic device does not require a
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`second-level authentication input; is that correct?
`
` A. That's -- that's one of the embodiments
`
`that's -- these are two different aspects: Unlocked
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`and that doesn't require authentication input.
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`That's sort of different issue.
`
` Q. And --
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` A. Because unlocked could work with multiple
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`embodiments.
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` Q. So when the particular embodiment that you
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`depict in the annotated version of Figure 2 that
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`occurs at Paragraph 122, that implementation does
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`away with steps 220, 223, and 225 entirely; is that
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`correct?
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` A. That's correct.
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` Q. So based on the paragraphs we've discussed,
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`would you agree that the method 200 depicted by
`
`Figure 2 is not limited to a single specific process,
`
`but rather catches multiple alternative
`
`implementations?
`
` MR. PLUTA: Object to form.
`
` THE WITNESS: Yeah, it's possible. It's
`
`possible that the process of Figure 2 could capture
`
`some of other embodiments, or multiple embodiments.
`
`But not all.
`
`BY MR. SNADER:
`
` Q. Captures the embodiments we've discussed
`
`previously?
`
` A. You mean that authorization is acquired or
`
`authorization is not acquired? Is that what you
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`mean? We discussed previously? If that's what you
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`meant -- if that's what you meant, yes.
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` Q. And also it covers implementations in which
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`the authorization input is validated after accessing
`
`the user authentication code and before accessing the
`
`user authentication code?
`
` A. I have to think about that. Probably so.
`
` Q. Turning back to your --
`
` A. Yeah, that would be variant of -- that
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`would be a variant of alternative to the figure above
`
`Paragraph 120.
`
` Q. Okay. Turning to Paragraph 114 of your
`
`declaration, one one four.
`
` A. I'm there.
`
` Q. Starting at this paragraph, you describe
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`two different implementations in Kirkup that you
`
`refer to as Scenario 1 and Scenario 2; is that
`
`correct?
`
` A. That's correct.
`
` Q. And in Paragraph 114, you note that,
`
`Scenario 1 in Kirkup occurs when the handheld
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`electronic device is already unlocked when the
`
`authenticating process for a user of PC 110 commences
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`as described in Figure 2
`
` A. Correct.
`
` Q. Is it correct that your description of
`
`Scenario 1 assumes an unlocked handheld electronic
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`device when the Figure 2 method begins?
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` A. That's correct. That's my understanding,
`
`actually, how this works for multiple embodiments,
`
`and in particular in the wireless environment.
`
` Q. Okay. And it is your opinion that
`
`Scenario 1 cannot satisfy the three claim conditions
`
`that are required in Claims 1, 9 and 16 of the '586
`
`patent, at least because the handheld electronic
`
`device is unlocked when the Figure 2 method begins?
`
`Is that correct?
`
` A. Did you say doesn't satisfy those
`
`scenarios?
`
` Q. Yes.
`
` A. Not satisfy.
`
` Q. Does not satisfy.
`
` A. That's correct. That's my understanding.
`
` Q. Turning to Paragraph 126 of your
`
`declaration.
`
` A. I am there.
`
` Q. At Paragraph 126, you note that, Scenario 2
`
`in Kirkup occurs when the handheld electronic device,
`
`while still in the locked state, transmits the
`
`authentication code for the locked PC 110; is that
`
`correct?
`
` A. That's correct.
`
` Q. So Scenario 2 differs from Scenario 1 in
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`www.alaris.us
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`ALARIS LITIGATION SERVICES
`Phone: 1.800.280.3376
`
`Fax: 314.644.1334
`
`IPR2020-00202
`Apple Inc. EX1060 Page 26
`
`
`
` BRANIMIR VOJCIC, PhD 1/28/2021
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`Page 27
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`that the handheld electronic device is locked when it
`
`transmits the authentication code to the PC; is that
`
`correct?
`
` A. Just a moment.
`
` I would like you please to repeat the
`
`question.
`
` Q. Scenario 2 differs from Scenario 1 in that
`
`the handheld electronic device is locked when it
`
`transmits the authentication code to the PC; is that
`
`correct?
`
` A. That's one -- yeah, that's one possible
`
`scenario that I assumed in this paragraph.
`
` Q. Turning to Paragraph 128 of your
`
`declaration.
`
` A. I'm there.
`
` Q. You quote from Paragraph 57 from Kirkup and
`
`you conclude that it can be read in one of two ways;
`
`is that correct?
`
` A. That's what I said.
`
` Q. At Paragraph 129 of your declaration, you
`
`describe the first way that this paragraph can be
`
`interpreted, and you characterize it as describing
`
`the scenario in which a handheld electronic device is
`
`already unlocked before the communication link is
`
`established as a part of the auth
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