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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` Case No. IPR2020-00846
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` Patent No. 7,076,431
`
` ----------------------------------x
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` GOOGLE LLC, SAMSUNG ELECTRONICS
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` CO., LTD, SAMSUMG ELECTRONICS
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` AMERICA, INC., LG ELECTRONICS,
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` INC., and LG ELECTRONICS U.S.A., INC.
`
` Petitioners,
`
` v.
`
` PARUS HOLDINGS, INC.,
`
` Patent Owner.
`
` ----------------------------------x
`
` REMOTE VIDEOTAPED DEPOSITION of
`
` BENEDICT OCCHIOGROSSO
`
` Perrineville, New Jersey
`
` March 23, 2021
`
` Reported by:
`
` MaryJo O'Connor, RDR, RMR
`
` Job No.: 4505282
`
`800-567-8658
`
`Veritext Legal Solutions
`
`973-410-4098
`Google Exhibit 1051
`Google v. Parus
`IPR2020-00846
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` Case No. IPR2020-00846
`
` Patent No. 7,076,431
`
` ----------------------------------x
`
` GOOGLE LLC, SAMSUNG ELECTRONICS
`
` CO., LTD, SAMSUMG ELECTRONICS
`
` AMERICA, INC., LG ELECTRONICS,
`
` INC., and LG ELECTRONICS U.S.A., INC.
`
` Petitioners,
`
` v.
`
` PARUS HOLDINGS, INC.,
`
` Patent Owner.
`
` ----------------------------------x
`
` REMOTE VIDEOTAPED DEPOSITION of
`
` BENEDICT OCCHIOGROSSO
`
` Perrineville, New Jersey
`
` March 23, 2021
`
` Reported by:
`
` MaryJo O'Connor, RDR, RMR
`
` Job No.: 4505282
`
`800-567-8658
`
`Veritext Legal Solutions
`
`973-410-4098
`Google Exhibit 1051
`Google v. Parus
`IPR2020-00846
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`Page 2
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` March 23, 2021
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` 9:21 a.m. EDT
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` REMOTE VIDEOTAPED DEPOSITION of
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` BENEDICT OCCHIOGROSSO, held remotely via
`
` Zoom in Perrineville, New Jersey, pursuant
`
` to notice, before MaryJo O'Connor,
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` Registered Diplomat Reporter, Registered
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` Merit Reporter, and Notary Public in and for
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` the Commonwealth of Massachusetts.
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`Page 3
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` A P P E A R A N C E S:
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` ATTORNEYS FOR THE PETITIONERS:
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` WOLF, GREENFIELD & SACKS, P.C.
`
` (Attending remotely)
`
` 600 Atlantic Avenue
`
` Boston, Massachusetts 02210
`
` (617) 646-8000
`
` BY: ELISABETH H. HUNT, ESQ.
`
` Ehunt@wolfgreenfield.com
`
` GREGORY NIEBERG, ESQ.
`
` Gregory.Nieberg@WolfGreenfield.com
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` ATTORNEYS FOR THE PATENT OWNER:
`
` MINTZ, LEVIN, COHN, FERRIS, GLOVSKY, AND
`
` POPEO
`
` (Attending remotely)
`
` One Financial Center
`
` Boston, Massachusetts 02111
`
` (617) 542-6000
`
` BY: MICHAEL J. MCNAMARA, ESQ.
`
` mmcnamara@mintz.com
`
` SEAN M. CASEY, ESQ.
`
` smcasey@mintz.com
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`800-567-8658
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`973-410-4098
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`Page 4
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` A P P E A R A N C E S (Con't):
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` ALSO PRESENT:
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` Jaysun Loushin, Veritext Consierge
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`Page 5
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` -----------------I N D E X------------------
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` EXAMINATION of BENEDICT OCCHIOGROSSO PAGE
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` By Ms. Hunt 7
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` By Mr. Casey 114
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` By Ms. Hunt 115
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` ----------------INSTRUCTIONS----------------
`
` (None)
`
` ------------------EXHIBITS------------------
`
` HUNT EXHIBIT PAGE
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` (None)
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` ----------PREVIOUSLY MARKED EXHIBITS--------
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` EXHIBIT PAGE
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` Exhibit 1001 United States Patent 48
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` No. 7,076,431 B2
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` Exhibit 2025 295 pages of code/commands , 13
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` mc_vm.c file
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` Exhibit 2027 U.S. Patent No. 7,076,431: 63
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` Claim 1
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`800-567-8658
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` -------PREVIOUSLY MARKED EXHIBITS(Con't)----
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` EXHIBIT PAGE
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` Exhibit 2028 U.S. Patent No. 9,451,084: 63
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` Claim 1
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` Exhibit 2032 Five pages of code/commands, 72
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` webget.pl file
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` Exhibit 2033 Seven pages of 72
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` code/commands, weather.ini
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` file
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` Exhibit 2042 url.pl file 101
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` Exhibit 2059 Document entitled 15
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` "Declaration of Benedict
`
` Occhiogrosso in Support
`
` of Patent Owner's Response
`
` to Inter Partes Review of
`
` U.S. Patent Nos. 7,076,431
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` & 9,451,084
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` P R O C E E D I N G S
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`Page 7
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` COURT REPORTER: Since I am not
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` a New Jersey notary, I would like a
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` stipulation from the attorneys that my oath
`
` will be binding.
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` MS. HUNT: Yes.
`
` MR. CASEY: Yes.
`
` * * *
`
` BENEDICT OCCHIOGROSSO,
`
` having been duly sworn by the Notary Public,
`
` was examined and testified as follows:
`
` EXAMINATION
`
` BY MS. HUNT:
`
` Q. So my name is Elizabeth Hunt, and
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` with me is my colleague, Gregory Nieberg. We
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` are from the firm Wolf, Greenfield & Sacks.
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` We're counsel for the Petitioners in these
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` proceedings.
`
` Should we do appearances for the
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` Patent Owner?
`
` MR. CASEY: Sure. My name is Sean
`
` Casey, and with me is Michael McNamara,
`
` and we represent patent holder -- Patent
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`Page 8
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` Owner, Parus Holdings.
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` Q. And you've already met the court
`
` reporter, and Jason is our tech support from
`
` the court reporting agency.
`
` Could you please say and spell
`
` your full name for the record?
`
` A. Sure. Benedict Occhiogrosso. Do
`
` you want me to spell both the last and the
`
` first name?
`
` Q. Yes, please.
`
` A. Okay. So Benedict,
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` B-e-n-e-d-i-c-t, and Occhiogrosso,
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` O-c-c-h-i-o-g-r-o-s-s-o.
`
` Q. All right. Thank you. Today's
`
` deposition concerns two cases, IPR2020-00846
`
` regarding the '431 patent, and IPR2020-00847
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` regarding the '084 patent.
`
` Do you understand that?
`
` A. Yes.
`
` Q. And you have submitted a
`
` declaration in those proceedings, correct?
`
` A. Correct.
`
` Q. Have you been deposed before?
`
` A. Yes.
`
` Q. About how many times have you been
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` deposed in the past?
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` A. In excess of two dozen. I don't
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` have an exact count.
`
` Q. Okay. So you're generally
`
` familiar with how these go, but I'm just going
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` to go through a few preliminaries.
`
` Do you understand that you're
`
` under oath for the statements you make today?
`
` A. Yes.
`
` Q. And do you understand that this is
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` a question-and-answer deposition and that your
`
` answers have to be audible so the court
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` reporter can transcribe them?
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` A. Yes.
`
` Q. Do you understand that if patent
`
` owner's counsel makes an objection to a
`
` question, you're still required to answer the
`
` question unless counsel specifically instructs
`
` you not to answer?
`
` A. Yes.
`
` Q. And if at any point I ask a
`
` question that you don't understand or that's
`
` not clear, please ask me for a clarification
`
` before you answer. Okay?
`
` A. Sure.
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` Q. And I'm going to try to watch the
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` clock and take a break each time we've been
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` going for about an hour. But if you need to
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` take a break at any point, feel free to let me
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` know, and we will get to a convenient stopping
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` place as soon as we can. Okay?
`
` A. That's fine.
`
` Q. Have you been informed that now
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` that this deposition has started, patent
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` owner's counsel is not permitted to discuss
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` with you the substance of your testimony for as
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` long as we're still in the period where it's my
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` turn to ask questions?
`
` A. Yes.
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` Q. And is there any reason you cannot
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` give full, complete, and truthful answers
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` today?
`
` A. No.
`
` Q. Did you do anything to prepare for
`
` today's deposition?
`
` A. Yes.
`
` Q. And what did you do to prepare for
`
` today's deposition?
`
` A. I reviewed my declaration and a
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` number of the exhibits in the proceedings, and
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` I met with counsel.
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` Q. The counsel you met with, are
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` those Sean Casey and Michael McNamara?
`
` A. Yes.
`
` Q. Did you meet with anyone else to
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` prepare for today's deposition?
`
` A. No.
`
` Q. And you said you reviewed your
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` declaration and exhibits that are already of
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` record in these proceedings; is that right?
`
` A. Sure.
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` Q. Did you review any other documents
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` to prepare for today's deposition?
`
` A. Not that I can recall.
`
` Q. About how many hours did you spend
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` preparing for today's deposition?
`
` A. Probably between 18 and 24. Maybe
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` more.
`
` Q. Now, you should have received from
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` us a FedEx shipment that contained six binders
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` of paper copies for use in this deposition.
`
` Did you receive those?
`
` A. I did.
`
` Q. So I'm just going to go through so
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` that we can confirm that you receive what I
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` believe you should have received.
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` Do you see a Binder 1 containing
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`Page 12
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` Exhibit 2059?
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` A. Yes.
`
` Q. And do you have a --
`
` A. Yes.
`
` Q. Thanks.
`
` And do you have a Binder 2
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` containing the petition and Exhibit 1002 from
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` the '846 proceeding?
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` A. Yes.
`
` Q. Do you have a Binder 3 containing
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` the petition and Exhibit 1002 from the '847
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` proceeding?
`
` A. Yes.
`
` Q. Do you have a Binder 4 containing
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` a set of exhibits from the '846 proceeding?
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` A. Yes.
`
` Q. And do you have a Binder 5
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` containing Exhibits 2020 to 2024 and 2026 to
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` 2058?
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` A. Yes.
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` Q. And then, finally, do you have a
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` Binder 6 containing Exhibit 2025, which is a
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` long exhibit?
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` A. Yes.
`
` Q. All right, great.
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` (Document previously marked for
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` identification as Exhibit 2025)
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` Q. Are you currently employed?
`
` A. Yes.
`
` Q. And who is your current employer?
`
` A. DVI Communications.
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` Q. And what type of company is DVI
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` Communications?
`
` A. We're a technology consulting
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` firm.
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` Q. And what's your current title at
`
` DVI Communications?
`
` A. President.
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` Q. And what are your current job
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` responsibilities in that position?
`
` A. Project management, technical
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` work, business development.
`
` Q. How many employees does DVI
`
` Communications have?
`
` A. I believe we're currently at ten,
`
` or maybe nine. I lost track.
`
` Q. Okay. Prior to being approached
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` to work on this case, did you know of Parus
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` Holdings, the Patent Owner?
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` A. To the best of my recollection,
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` no.
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` Q. And prior to being approached to
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` work on this case, did you know of Webley
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` Systems?
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` A. No, I don't believe I did.
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` Q. Prior to working on this case, had
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` you had any contact with Google, other than as
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` a consumer of Google products or services?
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` A. I don't believe I had any
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` professional contact with Google.
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` Q. You qualified "professional
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` contact with Google." Did you have a different
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` kind of contact with Google?
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` A. No. Merely as a consumer.
`
` Q. I see.
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` Prior to working on this case, had
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` you had any contact with Samsung, other than as
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` a consumer of Samsung products or services?
`
` A. I don't believe I did.
`
` Q. And prior to working on this case,
`
` had you had any contact with LG, other than as
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` a consumer of LG products or services?
`
` A. No. I don't think so.
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` Q. Okay, thanks.
`
` Could you please get out Binder 1,
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` which should have Exhibit 2059 in it.
`
` A. All right.
`
` (Document previously marked for
`
` identification as Exhibit 2059)
`
` Q. So looking at Exhibit 2059, do you
`
` recognize this as the declaration that you
`
` submitted in these proceedings?
`
` A. Yes. This appears to be my
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` declaration.
`
` Q. And you submitted the same
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` declaration in both of the two proceedings,
`
` correct?
`
` A. That is correct.
`
` Q. All right. Could you please turn
`
` to page 5 of your declaration.
`
` A. Yes.
`
` Q. So I'm looking at paragraph 12.
`
` In paragraph 12 of your declaration, you said,
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` quote:
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` "I have also developed technical
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` expertise with regard to
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` telecommunication applications utilizing
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` speech recognition."
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` Do you see that?
`
` A. Yes.
`
` Q. Do you have experience designing
`
` or building a speech recognition engine?
`
` A. I have experience deploying speech
`
` recognition engines in a variety of
`
` applications.
`
` Q. Does that mean deploying a premade
`
` speech recognition engine that you were not
`
` involved in designing or building?
`
` A. When you say "designing and
`
` building" --
`
` Q. Let me rephrase.
`
` You said you have experience
`
` deploying speech recognition engines. Were
`
` those speech recognition engines created by a
`
` company?
`
` A. Yes.
`
` Q. And what companies made the speech
`
` recognition engines that you have experience
`
` deploying.
`
` A. Dragon. Nuance. IBM. I can't
`
` recall some of the other vendors offhand, but a
`
` variety of players in the speech recognition
`
` marketplace.
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` Q. Okay. So you have experience
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` using a Nuance speech recognition engine?
`
` A. To my recollection, yes, we used
`
` Nuance on occasion.
`
` Q. What versions of Nuance speech
`
` recognizers have you used?
`
` A. I don't recall.
`
` Q. What -- in what time frame did you
`
` use Nuance speech recognizers?
`
` A. I would say as far back, to my
`
` recollection, late '80s, '90s, mid '90s. I
`
` think that's accurate.
`
` Q. Okay. Do you have experience
`
` using Nuance speech recognizers in the late
`
` '90s?
`
` A. I don't recall.
`
` Q. Do you have experience creating
`
` recognition grammars for a speech recognizer?
`
` A. We created scripts.
`
` Q. Were those recognition grammars?
`
` A. They formed the basis of
`
` recognition grammars.
`
` Q. So can you explain that? What are
`
` the scripts that you created and how do they
`
` form the basis of recognition grammars?
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` A. Sure. The scripts are the
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` dialogues that the system would engage in with
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` a user, and they form the basis of the
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` recognition grammar insofar as the developers
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` would then codify those scripts into the
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` grammar language and integrate that into the
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` recognition engine.
`
` Q. Okay. So do I understand
`
` correctly that you were involved in specifying
`
` what you would like the user to be able to say
`
` that would be recognized?
`
` A. Yes.
`
` Q. And then different people who you
`
` called developers would take your
`
` specifications and use them as reference in
`
` creating recognition grammars?
`
` A. That's correct.
`
` Q. Okay. When those developers had
`
` created a new recognition grammar, are you
`
` familiar with what process would be used to
`
` provide the grammar to the Nuance speech
`
` recognizer?
`
` A. I'm familiar that there was a
`
` process involved with respect to their
`
` codifying our requirements to a grammar that
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` the recognizer would execute.
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` Q. Do you know would the grammar be
`
` loaded into some location for the recognizer to
`
` be able to execute it?
`
` A. I wasn't familiar with the
`
` location.
`
` Q. Do you know would there be some
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` software that would feed a recognition grammar
`
` to the Nuance recognizer?
`
` A. I don't know if there was
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` pre-processing involved. We convey our
`
` specifications, and the developers would codify
`
` that into the recognition engine.
`
` Q. Okay. So you're not familiar with
`
` the specifics of what the developers would do
`
` to codify it into the recognition engine; is
`
` that right?
`
` A. As I recall, we did not get
`
` involved in that aspect.
`
` Q. Okay. Do you have any experience
`
` designing or building a speech synthesis
`
` device?
`
` A. We would, again, specify scripts
`
` that might be generated by a speech
`
` synthesizer.
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` Q. And would that speech synthesizer
`
` be made by a company?
`
` A. Yes.
`
` Q. What company has made the speech
`
` synthesizers used by the scripts that you
`
` specified?
`
` A. I don't recall the specific
`
` vendors that were deployed. Oftentimes it
`
` might have been OEM'd by a contractor or
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` winning vendor in a project. It might have
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` been embedded.
`
` Q. Would you explain what "OEM'd"
`
` means?
`
` A. Yes. OEM'd, a figure of speech.
`
` OEM, as in Mary, stands for Original Equipment
`
` Manufacturer. And OEM'd means that a vendor
`
` would take another vendor's product, re-sell
`
` it, and sometimes even brand it as their own.
`
` Q. Okay. So for the court reporter's
`
` benefit, I am going to use the name of a
`
` company that I will likely mispronounce, but
`
` it's Lernout & Hauspie, but it's spelled
`
` L-e-r-n-o-u-t ampersand H-a-u-s-p-i-e.
`
` Mr. Occhiogrosso, if I just say
`
` L&H to refer to Lernout & Hauspie, will you
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` understand what I am referring to?
`
` A. Yes.
`
` Q. Do you have experience working
`
` with an L&H speech synthesizer?
`
` A. I don't recall.
`
` Q. So sitting here today, you don't
`
` recall any project you worked on that used an
`
` L&H speech synthesizer?
`
` A. I don't recall. That entity in
`
` the speech processing industry was short-lived.
`
` Q. You mentioned it was short-lived.
`
` Do you remember what was the time period in
`
` which L&H speech synthesizers were used?
`
` A. I don't recall the exact time
`
` frame. I know they acquired Dragon.
`
` Q. Are you familiar with the
`
` RealSpeak TTS product by L&H?
`
` A. Only from a specifications
`
` standpoint in reviewing it. I don't recall if
`
` we actually deployed that system in support of
`
` client applications.
`
` Q. You mentioned reviewing it. In
`
` what way did you review the RealSpeak TTS
`
` product?
`
` A. In the context of this case.
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` Q. Okay. So you're familiar with the
`
` RealSpeak TTS product being mentioned in this
`
` proceeding, correct?
`
` A. Yes.
`
` Q. And other than that, sitting here
`
` today, you don't recall having been familiar
`
` with the RealSpeak TTS product?
`
` A. I don't recall if we explicitly
`
` specified, deployed, or it was proposed as part
`
` of a solution for a client's system.
`
` Q. Did you know of the RealSpeak TTS
`
` product prior to working on this case?
`
` A. Yes.
`
` Q. And how did you know of it?
`
` A. Through the Lernout & Hauspie
`
` history.
`
` Q. When did you review the L&H
`
` history?
`
` A. Well, numerous times they were the
`
` subject of acquisitions, mergers, and some, if
`
` memory serves, civil and criminal proceedings.
`
` Q. And so are you saying that you
`
` heard of L&H products through news of these
`
` events?
`
` A. Well, that; and in conjunction
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` with the underlying algorithms and capabilities
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` that they enjoyed.
`
` Q. Okay. So I think I'm hearing that
`
` you had heard of the L&H RealSpeak TTS product,
`
` but you don't recall whether you ever used it;
`
` is that correct?
`
` A. Yeah, I think that's a fair
`
` summary of what I have just stated.
`
` Q. Okay. Do you have experience
`
` working on applications that retrieve
`
` information from Websites?
`
` MR. CASEY: Objection to form.
`
` A. I had experience with applications
`
` that relied on databases that were populated
`
` with information from Websites.
`
` Q. So what applications did you work
`
` on that relied on databases populated with
`
` information from Websites?
`
` A. Financial services applications.
`
` Q. Can you give me some examples of
`
` financial services applications you have worked
`
` on that relied on databases populated with
`
` information from Websites?
`
` A. Yeah. Credit authorization,
`
` transaction processing, funds transfer.
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` Q. And these were software
`
` applications that you worked on; is that right?
`
` A. They were a combination of
`
` hardware and software.
`
` Q. The applications that you worked
`
` on, did those applications retrieve the
`
` information from the Websites?
`
` A. My recollection is that some did.
`
` Q. Could you give me an example of
`
` one that did?
`
` A. Yeah. If somebody was trying to
`
` make a purchase above a certain threshold, the
`
` application would go out and do a credit
`
` authorization to a service provider Website.
`
` Q. Is this a project that appears on
`
` your CV?
`
` A. I don't recall the projects
`
` enumerated on the CV offhand.
`
` Q. So your CV, I believe, is attached
`
` at the end of Exhibit 2059.
`
` A. Correct.
`
` Q. So you mentioned an application
`
` where somebody is trying to make a purchase
`
` above a certain threshold and the application
`
` would do a credit check.
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` Was that a project you worked on
`
` for a particular company?
`
` A. Yeah. That was CitiBank.
`
` Q. So I see a mention of CitiBank on
`
` page 94 of Exhibit 2059, which is page 3 of --
`
` A. There --
`
` Q. Sorry, go ahead.
`
` A. No, that's all right. There are a
`
` number of projects with CitiBank listed there.
`
` Q. And according to your CV on
`
` page 94 of Exhibit 2059, you did work for
`
` CitiBank in the time frame 1979 to 2000; is
`
` that correct?
`
` A. Yes.
`
` Q. When in that time frame did you
`
` work on the application that would do a credit
`
` check?
`
` A. I don't recall. It had to be in
`
` the late '80s or early '90s, if memory serves.
`
` Maybe mid '90s. I don't recall offhand.
`
` Q. Okay. Do you have experience
`
` working on systems that control devices on a
`
` home or office network?
`
` A. I would say yes.
`
` Q. And what systems have you worked
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` on that control devices on a home or office
`
` network?
`
` A. A variety of sensor networks,
`
` close-circuit television, security systems,
`
` intrusion detection, alarms, access control.
`
` Q. Were those projects done for a
`
` particular company?
`
` A. Yeah, a variety of companies.
`
` Q. Which companies?
`
` A. I mean, the security systems were
`
` an embedded design requirement for virtually
`
` all of our relocation construction projects.
`
` So we did work for Metropolitan Transportation
`
` Authority, more recent comes to mind.
`
` (Court reporter comment)
`
` A. I'm sorry, I lost track of where I
`
` was. Could you repeat the question?
`
` Q. The question was: For which
`
` companies did you work on systems that control
`
` devices on a home or office network?
`
` A. Okay. So I mentioned MTA; we did
`
` a lot of work with them. Let me look at my --
`
` I don't offhand recall. I mean, it was so many
`
` different companies that we would design those
`
` systems, so...
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` Q. So for the MTA, you are referring
`
` to security systems, correct?
`
` A. Yes.
`
` Q. What are the devices that were
`
` controlled by the system?
`
` A. Cameras, door poppers, access
`
` control systems, card swipes, motion detection
`
` sensors, thermal detection sensors.
`
` Q. And where were those devices
`
` installed? Was it in a building?
`
` A. Yes. And on outdoor perimeter
`
` locations. Lighting control.
`
` Q. What type of building?
`
` A. Commercial office buildings, as
`
` well as industrial, semi-industrial complexes,
`
` train yards, bus depots.
`
` Q. And what year or years did you
`
` work on this project?
`
` A. Oh, for I'd say mid 2000s to the
`
` present.
`
` Q. Could you turn, please, to page 10
`
` of your declaration.
`
` A. Yes.
`
` Q. So on page 10 of your declaration,
`
` there is a paragraph 18.
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` Do you see that?
`
` A. Yes.
`
` Q. And that paragraph is followed by
`
` a table listing materials. And the table goes
`
` from page 10 to page 15 of your declaration.
`
` Do you see that?
`
` A. Yes.
`
` Q. Other than what's listed in this
`
` table, did you rely on any other documents in
`
` forming your opinions expressed in this
`
` declaration?
`
` A. Not that I can recall at the
`
` moment.
`
` Q. Other than what's listed in this
`
` table, did you receive any other information
`
` from the inventor, Mr. Kurganov, that you
`
` relied on in forming your opinions in this
`
` declaration?
`
` A. No.
`
` Q. And other than what's listed in
`
` this table, did you receive any other
`
` information from anyone other than patent
`
` owner's counsel that you relied on in forming
`
` your opinions in this declaration?
`
` A. No.
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` Q. All right. Could you turn,
`
` please, to page 16 of your declaration.
`
` A. Okay.
`
` Q. And I'm looking at paragraph 20.
`
` In paragraph 20 of your declaration, you
`
` discuss the person of ordinary skill in the
`
` art, correct?
`
` A. Correct.
`
` Q. And in the second half of
`
` paragraph 20, you say, quote:
`
` "Such a person would have had" --
`
` sorry, strike that. Start over.
`
` In the second half of
`
` paragraph 20, you say, quote:
`
` "Such a person would have a
`
` Bachelor's degree in electrical or
`
` computer engineering, or in a related
`
` field."
`
` Do you see that?
`
` A. Yes.
`
` Q. What's an example of a related
`
` field?
`
` A. Computer science,
`
` telecommunications engineering.
`
` Q. Okay. And looking at paragraph 21
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` of your declaration, you say, quote:
`
` "I understand that Petitioners
`
` have proposed a broader definition," end
`
` quote.
`
` Do you see that?
`
` A. Yes.
`
` Q. In what way is the Petitioners'
`
` definition broader than your definition of the
`
` person of ordinary skill in the art?
`
` MR. CASEY: Objection to form.
`
` A. Could you point me to the
`
` Petitioner's definition?
`
` Q. Sure. Your paragraph 21 cites the
`
` petition at 6. I believe the petition is in
`
` your Binder 2.
`
` A. Okay. Yes, it is.
`
` Q. So there might be a -- there might
`
` be a typo in your declaration's citation, but
`
` in the petition on the '431 patent, I see a
`
` section on person of ordinary skill in the art
`
` on page 5.
`
` Do you see it?
`
` A. Yes, I do.
`
` Q.
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