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PAGES: 1-61
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` EXHIBITS: 0
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`Page 1
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` UNITED STATES PATENT AND TRADEMARK OFFICE
`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` GOOGLE LLC, SAMSUNG ELECTRONICS CO., LTD,
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` SAMSUNG ELECTRONICS AMERICA, INC., LG ELECTRONICS
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` INC., and LG ELECTRONICS U.S.A., INC.,
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` Petitioners,
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` v.
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` PARUS HOLDINGS, INC.,
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` Patent Owner.
`
` REMOTE DEPOSITION OF PAUL K.
`
` MULKA, called as a witness by and on behalf of the
`
` Petitioners, pursuant to the applicable provisions
`
` of the Federal Rules of Civil Procedure, before P.
`
` Jodi Ohnemus, (remotely) RPR, RMR, CRR, CA-CSR
`
` #13192, NH-LSR #91, and MA-CSR #123193 at Chicago
`
` Ridge, Illinois, on Thursday, March 25, 2021,
`
` commencing at 9:02 (CDT) a.m.
`
` Job No. CS4505329
`
`800-567-8658
`
`Veritext Legal Solutions
`
`973-410-4098
`Google Exhibit 1052
`Google v. Parus
`IPR2020-00846
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`Page 2
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` APPEARANCES:
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` (Via Videoconference)
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` WOLF, GREENFIELD & SACKS, P.C.
`
` BY: Anant Saraswat, Esq.
`
` Elisabeth H. Hunt, Esq.
`
` 600 Atlantic Avenue
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` Boston, MA 02210
`
` 617 646-8000
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` asaraswat@wolfgreenfield.com
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` ehunt@wolfgreenfield.com
`
` For the Petitioners
`
` (Via Videoconference)
`
` MINTZ, LEVIN, COHN,
`
` FERRIS, GLOVSKY, AND POPEO
`
` BY: Michael J. McNamara
`
` Sean Casey, Esq.
`
` One Financial Center
`
` Boston, MA 02111
`
` 617 348-1884
`
` mmcnamara@mintz.com
`
` scasey@mintz.com
`
` For the Patent Owner
`
` ALSO PRESENT:
`
` Jaysun Loushin, Veritext (remote)
`
`800-567-8658
`
`Veritext Legal Solutions
`
`973-410-4098
`
`

`

` I N D E X
`
`Page 3
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` TESTIMONY OF: PAGE
`
` PAUL K. MULKA
`
` (By Mr. Saraswat) 5, 56
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` (By Mr. McNamara) 54
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` E X H I B I T S
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` EXHIBIT DESCRIPTION PAGE
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`Page 4
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` Exhibit 2060 previously marked 10
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` Exhibit 2058 previously marked 25
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` (The parties have stipulated that due to
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` the need for this deposition to take place remotely
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` because of the government's order for social
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` distancing, the court reporter may swear in the
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` witness over the internet. Counsel also agree that
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` a Massachusetts Notary may administer the oath to
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` the deponent in Illinois.)
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` PAUL K. MULKA, having
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` first been duly sworn, was
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` examined and testified as
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` follows to interrogatories
`
` BY MR. SARASWAT:
`
` Q. Good morning, Mr. Mulka.
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` Could you please spell your full name for
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` the record.
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` A. It's Paul, P-a-u-l, middle initial K., and
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` Mulka, M-u-l-k-a.
`
` Q. Okay. Thanks.
`
` So my name is Anant Saraswat, and I'm
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` counsel for the petitioners in these proceedings,
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` who are Google, Samsung Electronics, and LG
`
` Electronics; and with me is my colleague, Elizabeth
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` Hunt, and we are both from the firm of Wolf
`
` Greenfield.
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` MR. SARASWAT: Patent owner's counsel, IF
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`800-567-8658
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`Veritext Legal Solutions
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`973-410-4098
`
`

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`Page 6
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` you want to state your appearances?
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` MR. McNAMARA: This is Michael McNamara
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` for Parus and the patent holder and the witness.
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` Also with me here today is my colleague, Sean
`
` Casey.
`
` Q. So, Mr. Mulka, today's deposition concerns
`
` two cases: IPR 2020-00846 regarding the '431
`
` patent, and IPR 2020-00847, regarding the '084
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` patent, both owned by Parus Holdings.
`
` Do you understand that?
`
` A. Yes.
`
` Q. And you submitted a declaration in those
`
` proceedings; is that correct?
`
` A. Yes, that's correct.
`
` Q. Okay. So I'll be asking you some
`
` questions today about your testimony in those
`
` proceedings, and the court reporter will be
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` transcribing your answers for the record.
`
` Do you understand that you need to give
`
` audible answers to my questions so the court
`
` reporter can transcribe them?
`
` A. Yes.
`
` Q. So, for example, instead of nodding or
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` shaking your head, you'll need to speak your
`
` answers as "yes" or "no"; okay?
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` A. Yes. Okay.
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` Q. Okay. And are you represented by counsel
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`Page 7
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` today?
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` A. Yes.
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` Q. And are those counsel Mr. McNamara and
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` Mr. Casey?
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` A. Yes.
`
` Q. Okay. Now, there may be times today when
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` I ask a question and patent owner's counsel makes
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` an objection to the question.
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` Do you understand that if that happens,
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` after counsel states their objection, you're still
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` required to answer the question unless counsel
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` specifically instructs you not to answer?
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` A. Yes. I understand.
`
` Q. Okay. Great. Thanks.
`
` Now, if at any point I ask a question and
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` you don't understand or it's not clear, please ask
`
` me for a clarification before you answer; okay?
`
` A. Okay.
`
` Q. Okay. And I'll try to watch the clock,
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` and we'll take a break each time we've been going
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` for about an hour, but if you need to take a break
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` at any other point, please feel free to let me know
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` and we'll get to a convenient stopping point as
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`Page 8
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` soon as we can; okay?
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` A. Okay.
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` Q. Okay. And have you been informed that now
`
` that the deposition has started patent owner's
`
` counsel is not permitted to discuss with you the
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` substance of your testimony for as long as we're
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` still in the period when it's my turn to ask
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` questions?
`
` A. Yes.
`
` Q. Okay. And that includes during breaks.
`
` Do you understand that?
`
` A. Yes.
`
` Q. Okay. And are you under the influence of
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` any medication or other substance that would
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` prevent you from giving full, complete, and
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` truthful answers today?
`
` A. No.
`
` Q. Okay. So are you currently employed?
`
` A. Yes.
`
` Q. And who's your current employer?
`
` A. Parus Holdings.
`
` Q. Okay. And what's your current title?
`
` A. Senior software engineer.
`
` Q. Okay. And what are your job
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` responsibilities as a senior software engineer?
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` A. I do design and development of the
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` software components for the main projects that
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` we're working on, but mainly the communicate
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` application.
`
` Q. Okay. And other than Parus, do you have
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` any other employers right now?
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` A. No.
`
` Q. Okay. And when you were preparing for
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` today's deposition, did you look at any documents?
`
` A. Just the declaration.
`
` Q. Okay.
`
` A. And --
`
` Q. Sorry. Go ahead, please.
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` A. And an exhibit that I submitted with the
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` declaration.
`
` Q. Okay. And were you paid for your
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` preparation for the deposition?
`
` A. No.
`
` Q. Okay. And are you getting paid for the
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` time you spend in the deposition today?
`
` A. No.
`
` Q. Okay. So, Mr. Mulka, I think you should
`
` have received a -- a drop bock links -- sorry -- a
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` Dropbox link from your counsel which has some
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` documents in it.
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` Did you -- did you get that?
`
` A. Yes, I got the link.
`
` Q. Okay.
`
` A. The folder, as far as I know, is empty.
`
` Q. Yeah. So if you -- and I apologize. It
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` looks like it's still refreshing on my end. If you
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` hit "refresh" now, you should hopefully be able to
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` see something in there.
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` A. Yes. Okay.
`
` Q. Okay. And so do you see a document in
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` there that's labeled Exhibit 2060?
`
` A. Yes.
`
` Q. Okay. Can you please open that.
`
` A. Okay. I have it opened.
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` (Exhibit 2060, previously marked.)
`
` Q. Okay. And do you recognize this as the
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` declaration that you submitted in these two
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` proceedings?
`
` A. Yes.
`
` Q. Okay. So could you please turn to page 1
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` of Exhibit 2060, and look at paragraph 2.
`
` A. Yes. Okay.
`
` Q. And do you see that the second sentence
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` says "I graduated from college with a bachelor of
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` science in computer science and mathematics in the
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`Page 11
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` December of 1998"?
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` A. Yes.
`
` Q. And then after that it says "After
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` graduating college, I joined Webley Systems as a
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` software engineer."
`
` Do you see that?
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` A. Yes.
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` Q. So did you start working at Webley in
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` December 1998?
`
` A. At -- no.
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` Q. Okay. So when did you start working at --
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` at Webley?
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` A. In July 1999.
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` Q. Okay. Now, are you -- are you still
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` working at Webley?
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` A. Yes.
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` Q. Okay. And so I -- I think earlier when I
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` asked you who your employer was, you mentioned
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` Parus. So at some point did Webley change its name
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` to Parus?
`
` A. Yes.
`
` Q. Okay. And so have you worked at Webley
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` full-time since July of 1999 when you joined?
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` A. No. There's actually a gap in my
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` employment.
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` Q. Okay. When -- when was that?
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` A. From January 2002 to October of 2005.
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` Q. Okay. And -- and what were you doing
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` during that period?
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` A. I had remained unemployed.
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` Q. Okay. And then you came back to Webley at
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` the end of that period?
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` A. Yes.
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` Q. Okay.
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` A. And at that point it changed its name to
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` Parus.
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` Q. Okay. So at some point -- sorry.
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` Withdrawn.
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` So at some point between January of 2002
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` and October of 2005 Webley changed its name to
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` Parus?
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` MR. McNAMARA: Objection to form. Scope.
`
` Q. Is that correct?
`
` A. Yes.
`
` Q. Okay. And during the period from July
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` 1999 to January of 2002, were you working full-time
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` at Webley?
`
` A. Yes.
`
` Q. Okay. And did you have any other
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` employers other than Webley from the period of July
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`Page 13
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` 1999 to January 2002?
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` A. No.
`
` Q. Okay. Now, for -- in the period from July
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` 1999 to January 2002 when you were working at
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` Webley, did you work in an office?
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` A. Can you clarify? Like, office building,
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` or...
`
` Q. Yeah, did -- did -- did Webley have a
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` physical location at that time that you were
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` working at?
`
` A. Yes.
`
` Q. And -- and where was it?
`
` A. It was in Deerfield, Illinois.
`
` Q. Okay. And was it a -- strike that.
`
` So was the Webley facility a single
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` building that was owned by Webley, or was it a set
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` of offices in an office building?
`
` A. Set of offices.
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` MR. McNAMARA: Object to form.
`
` Q. And during that period from July 1999 to
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` January 2002, was -- was the office that you worked
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` at Webley's only office?
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` MR. McNAMARA: Object to form.
`
` A. Yes, I think so.
`
` MR. McNAMARA: Scope.
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` Q. Okay. So during that period from July
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` 1999 to January 2002, did you physically come into
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` the building to do your work?
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` A. Yes.
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` Q. Okay. And did you come in every day?
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` A. Yes.
`
` Q. Okay. All right. So could you now turn
`
` to paragraph 3 of your declaration, Exhibit 2060.
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` A. Okay.
`
` Q. And do you see that it says "While working
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` at Webley, I became personally acquainted with
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` Alexander Kurganov and Valery Zhukoff?
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` A. Yes.
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` Q. What do you mean by "personally
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` acquainted"?
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` A. I -- I knew they were employees at Webley
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` at the time.
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` Q. Okay.
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` A. I -- I had talked with Alex.
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` Q. How often did you talk to Alex?
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` A. It was just on occasion. I don't think it
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` was very often, but...
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` Q. Okay. And what about Mr. Zhukoff? Did
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` you also talk to him?
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` A. I don't really remember. I don't -- I
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` was...
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` Q. Okay. Did you -- did you work in the same
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` building as Mr. Zhukoff and Mr. Kurganov?
`
` A. Yes.
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` Q. Okay. And so I think you mentioned
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` earlier that in the -- that in the building where
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` Webley was located Webley had a number of different
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` offices in an office building; is that correct?
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` MR. McNAMARA: Objection.
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` A. Webley was just one office in the
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` building.
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` Q. Okay. So you just had one -- so -- so
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` Webley just had one office in the office building;
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` is that correct?
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` MR. McNAMARA: Objection.
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` A. Yeah.
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` Q. Okay. And so did -- did Mr. Kurganov and
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` Mr. Zhukoff work in the same office that you worked
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` in?
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` A. Yes.
`
` Q. Okay. And so when you say that Webley had
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` one office, how many -- how many rooms were in that
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` office?
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` MR. McNAMARA: Objection.
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` A. I do not remember.
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` Q. Okay. Can -- can you -- can you describe
`
` the office for me?
`
` MR. McNAMARA: Object to form.
`
` A. It was a typical office. It had various
`
` smaller offices for the managers and executives,
`
` meeting rooms, and --
`
` Q. Okay.
`
` A. -- cubicles that...
`
` Q. Okay. So -- so within that one office
`
` there were a few -- a few smaller offices and
`
` meeting rooms and, then, some cubicles; is that
`
` correct?
`
` A. Yes.
`
` Q. Okay. How many employees worked in the
`
` office?
`
` MR. McNAMARA: Object to form.
`
` A. At the time, I don't -- yeah, I can't
`
` recall at the time.
`
` Q. Do you have a -- do you have a ballpark
`
` figure?
`
` A. 150.
`
` Q. Okay. Now, did you ever -- did you ever
`
` exchange emails with Mr. Kurganov or Mr. Zhukoff?
`
` MR. McNAMARA: Object to form.
`
` A. I don't remember. I think I would have
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` with Alex.
`
` Q. Okay. And what was the -- what was the
`
` relationship between you and Mr. Kurganov in terms
`
` of the employment relationship?
`
` A. I knew him as the -- the CTO.
`
` Q. Okay. And how about Mr. Zhukoff?
`
` A. I -- just as another software engineer.
`
` Q. So did you -- did you -- did you report to
`
` Mr. Kurganov?
`
` A. No.
`
` Q. Okay. Who did you report to?
`
` A. Vladimir --
`
` MR. McNAMARA: Object to form.
`
` A. Vladimir Smelyansky.
`
` Q. Okay. Did you report to Mr. Zhukoff?
`
` A. No.
`
` Q. Did Mr. Zhukoff report to you?
`
` A. No.
`
` Q. Okay. So at this time from January -- I'm
`
` sorry. Strike that.
`
` At this time, from July 1999 until January
`
` of 2002, were -- were there different groups or
`
` divisions that the employees at Webley were -- were
`
` divided into?
`
` MR. McNAMARA: Object to form.
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` A. Yeah, there were different teams.
`
` Q. Okay. So were you on the same team as
`
` Mr. Kurganov at any point during that time from
`
` July 1999 to January 2002?
`
` A. No.
`
` Q. Okay. What about Mr. Zhukoff?
`
` A. No.
`
` Q. Okay. What -- what team were you on
`
` during that period from July 1999 to January 2002?
`
` A. I was on a team that was managing the
`
` Webley Assistant voice application.
`
` Q. Okay. And do you know what team
`
` Mr. Kurganov was on during that same period?
`
` A. No.
`
` Q. Okay. Do you know what team Mr. Zhukoff
`
` was on during that period?
`
` A. No.
`
` Q. So, Mr. Mulka, I think earlier you said
`
` that you were on a team that was managing the
`
` Webley Assistant voice application; is that
`
` correct?
`
` A. Yes. Correct.
`
` Q. Can you explain what that team did.
`
` MR. McNAMARA: Object to form.
`
` A. We did maintenance of the applications and
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` addition of certain new features.
`
` Q. Okay. And when you referred to the Webley
`
` Assistant voice application, what did you mean by
`
` that?
`
` A. That was the telephony application that
`
` contained the Webley Assistant voicemail and -- the
`
` voicemail messaging, contact management, the
`
` personal assistant for routing calls and calling
`
` contacts and other features like that.
`
` Q. And so -- so was the Webley Assistant
`
` voice application a single application within some
`
` larger product called Webley Assistant?
`
` A. Yes.
`
` Q. Okay. Now, do you still work with
`
` Mr. Kurganov today?
`
` A. No.
`
` Q. And do you still work with Mr. Zhukoff
`
` today?
`
` A. No.
`
` Q. Okay. Do you know when you stopped
`
` working with Mr. Kurganov?
`
` A. I don't remember what year it was.
`
` Q. Do you know approximately?
`
` A. No, I can't remember what year it was. It
`
` was after I was rehired in 2005. A few years after
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` that.
`
` Q. Okay. And do you remember when you
`
` stopped working with Mr. Zhukoff?
`
` A. No, that would be when I was -- had left
`
` the company in 2002.
`
` Q. Okay. Are you still in touch with
`
` Mr. Kurganov today?
`
` A. No.
`
` Q. Are you still in touch with Mr. Zhukoff
`
` today?
`
` A. No.
`
` Q. When -- when's the last time you
`
` communicated with Mr. Kurganov?
`
` A. I don't recall.
`
` Q. Was it in the last year?
`
` A. I think more than that.
`
` Q. Okay. And how about Mr. Zhukoff? Do
`
` you -- when's the last time you communicated with
`
` him?
`
` A. It would -- I'm -- I don't remember.
`
` Q. Do you think it was in the last year?
`
` A. No, it wouldn't have been.
`
` Q. Okay. All right. So can you please turn
`
` to paragraph 1 of your declaration.
`
` A. Okay.
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` Q. And can you please look at the third
`
` sentence. Sorry. I believe it's the -- yes,
`
` sorry. It is the third sentence, and it starts
`
` with the words "I make this declaration."
`
` Do you see that?
`
` A. Yes.
`
` Q. And it says "I make this declaration based
`
` on facts and matters within my own knowledge and on
`
` information provided to me by others."
`
` Do you see that?
`
` A. Yes.
`
` Q. So who are the "others" who provided you
`
` with information that you're referring to here?
`
` A. So that would be the CEO of the company
`
` currently, Taj Reneau, as well as my manager, Darek
`
` Markiewicz.
`
` Q. And would you mind spelling their names,
`
` please.
`
` A. Taj is T-a-j. Reneau -- I think that's
`
` R-e-n-e-a-u.
`
` Darek is D-e-r-e-k [verbatim].
`
` Markiewicz, M-a-r-k-i-e-c-w-z [verbatim], I think.
`
` Q. Okay. And so Mr. Reneau and
`
` Mr. Markiewicz are the "others" that you're
`
` referring to in paragraph 1; is that correct?
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` A. Yes, that's correct.
`
` Q. Okay. And did anybody other than
`
` Mr. Reneau and Mr. Markiewicz provide you with any
`
` information for your declaration?
`
` A. No.
`
` Q. Okay. And what information did they
`
` provide you?
`
` A. Taj provided me confirmation that Alex and
`
` Valery were employees at the time through -- via HR
`
` records. And I had been working with Darek on
`
` retrieving and analyzing the CVS records.
`
` Q. Okay. So when you say that Mr. Reneau
`
` provided you with confirmation that Alex and Valery
`
` were employees via HR records, did he provide you
`
` with the records themselves?
`
` A. No.
`
` Q. So how did he provide you with
`
` confirmation?
`
` A. Just through talking with him --
`
` Q. Okay.
`
` A. -- in discussion.
`
` Q. And then you said that you had been
`
` working with Mr. Markiewicz on retrieving and
`
` analyzing CVS records; is that correct?
`
` A. Correct.
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` Q. So when you say you were working with him,
`
` what do you mean?
`
` A. Well, he gave me instructions of what to
`
` look for, and so I -- so I retrieved the messages
`
` based on what he was asking for and supplied it to
`
` him and kind of went over it, made sure it was
`
` relevant, what we expected.
`
` Q. Okay. And what did he ask you to look
`
` for?
`
` A. There was the check-in activity from Alex
`
` Kurganov and Valery Zhukoff within a specific time
`
` frame from December of 1999 to January 10th, 2000.
`
` Q. Okay. Now, just -- just going back
`
` quickly to the information that Mr. Reneau provided
`
` you, did -- did you do anything to verify for
`
` yourself what he told you about Mr. Zhukoff's and
`
` Mr. Kurganov's employment?
`
` A. So I had also done the -- just looking for
`
` activity from within our source code repository
`
` that they had been doing work for the company.
`
` Q. But other than looking at their activity
`
` in the source code repository, you didn't do
`
` anything else to verify what Mr. Reneau told you
`
` about Mr. Kurganov's and Mr. Zhukoff's employment;
`
` is that correct?
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` MR. McNAMARA: Object to form.
`
` A. That is correct.
`
` Q. Okay. So can you please look at paragraph
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`Page 24
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` 4 of your declaration.
`
` A. Okay.
`
` Q. And the first sentence says "Based on
`
` information provided to me from the management at
`
` Parus, Incorporated (formerly Webley Systems) and a
`
` review of the source code management system, it is
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` my understanding that Alex and Valery were employed
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` by Webley Systems in 1999 and 2000."
`
` Do you see that?
`
` A. Yes.
`
` Q. Okay. So when you say the management at
`
` Parus provided information to you, what do you mean
`
` by "management"?
`
` A. I mean the CEO. Again, Taj Renault.
`
` Q. Okay.
`
` A. And my own manager, Darek.
`
` Q. So when you -- when you refer to
`
` "management" in paragraph 4, you're referring to
`
` Mr. Reneau and Mr. Markiewicz; is that correct?
`
` A. Yes.
`
` Q. Okay. And what is the information that
`
` they provided to you?
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` A. So from Taj Reneau, I had received the
`
` confirmation that Alex and Valery were working
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` full-time at Webley. And with Darek, it was that
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` they're working on looking through the activity for
`
` the source code repository.
`
` Q. Okay. So are you referring to the same
`
` information that you mentioned in paragraph 1 of
`
` your declaration that we were discussing earlier?
`
` A. Yes.
`
` Q. Okay.
`
` MR. McNAMARA: Object to form. Sorry.
`
` Couldn't get there.
`
` Q. So when you refer to "information" in
`
` paragraph 1, is that the same information that
`
` you're referring to in paragraph 4 of your
`
` declaration?
`
` A. Yes.
`
` Q. So, Mr. Mulka, I've added another document
`
` to that Dropbox folder. Could you please refresh
`
` it and let me know if you see it.
`
` A. Okay. Yes I see it.
`
` MR. McNAMARA: -- just 'cause Dropbox is
`
` not working well for me.
`
` (Exhibit 2058, previously marked.)
`
` MS. HUNT: Sorry, Mike. We couldn't hear
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` everything you said. Did you -- did you just say
`
` -- what exactly?
`
` MR. McNAMARA: Is that a particular
`
` exhibit? Just because Dropbox is not working well
`
` for me. It's not refreshing very well.
`
` MR. SARASWAT: Oh, yeah. It's Exhibit
`
` 2058 that was filed.
`
` MR. McNAMARA: Okay. Thank you.
`
` Q. So, Mr. Mulka, could you please open the
`
` document that's marked Exhibit 2058.
`
` A. Yes. Okay.
`
` Q. And could you please take a few moments to
`
` review it, and let me know when you're done.
`
` A. (Witness reviews document.) Okay.
`
` Q. Okay. Have you seen this document before?
`
` A. Yes.
`
` Q. What is it?
`
` A. It is the CVS analysis that I did to find
`
` all of the activity from Alex and Valery.
`
` Q. And when you say it's the CVS analysis
`
` that you did, is this the same analysis you were
`
` referring to before that you did with
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` Mr. Markiewicz?
`
` A. Yes.
`
` Q. Okay. Do you know who created this
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` document that's Exhibit 2058?
`
` A. Yes, I did.
`
` Q. Okay. So you created Exhibit 2058; is
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`Page 27
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` that correct?
`
` A. Yes.
`
` Q. Okay. Now, could you please turn to --
`
` turn back to your declaration, Exhibit 2060, and
`
` look at paragraph 6.
`
` A. Yes. Okay.
`
` Q. And in paragraph 6 the first sentence
`
` begins "Based on my review of the CVS records
`
` between December 1st, 1999 and January 10th, 2000
`
` (attached as Exhibit A)."
`
` Do you see that?
`
` A. Yes.
`
` Q. So is -- is the document that I showed you
`
` that's labeled Exhibit 2058 the same document as
`
` the Exhibit A you referred to in paragraph 6 of
`
` your declaration?
`
` A. Yes.
`
` Q. Okay. So can you please turn back to
`
` Exhibit 2058.
`
` A. Okay. I'm looking at it.
`
` Q. And do you see that the first sentence
`
` under the title says "The following records were
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` created with a tool called cvsps"?
`
` A. Yes.
`
` Q. Okay. What is cvsps?
`
` A. It's a tool that scans a CVS repository
`
` and creates a PatchSet which indicates all of the
`
` files that were committed based on a single
`
` command. So it -- and it allows a filtering based
`
` on the user that committed it and the date range.
`
` Q. And when you say -- sorry.
`
` So you said "It's a tool that scans a CVS
`
` repository and creates a PatchSet which indicates
`
` all of the files that were committed based on a
`
` single command."
`
` When you say "based on a single command,"
`
` what do you mean by "command"?
`
` A. You add files to the CVS source code
`
` repository. There is a tool CVS and you need to
`
` run CVS commit and then you get a list of files,
`
` and that goes into the source code repository.
`
` Q. So when you said that cvsps creates the
`
` PatchSet which indicates all of the files that were
`
` committed based on a single command, is that single
`
` command that you were referring to a CVS commit
`
` command?
`
` A. Yes.
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` Q. Okay. So cvsps scans a repository and
`
` creates a PatchSet which indicates all of the files
`
` that were committed by a given CVS commit command;
`
` is that correct?
`
` A. Yes, it will output a list of PatchSets so
`
` the -- a single PatchSet for every commit that was
`
` done.
`
` Q. So is each PatchSet a group of files that
`
` somebody committed together with a single commit
`
` command?
`
` A. Yes.
`
` Q. Okay. And then if you turn back to
`
` Exhibit 2058 again; right above that screenshot
`
` there's a sentence that says "The command was run
`
` on the repositories that can be seen in this
`
` screenshot with two exceptions."
`
` Do you see that?
`
` A. Yes.
`
` Q. And then do you see that below that
`
` screenshot it says "The exceptions were," and then
`
` there's two bullets?
`
` A. Uh-huh.
`
` (Court Reporter comment.)
`
` A. Yes.
`
` Q. When you -- so in that sentence above the
`
`800

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