UNITED STATES PATENT AND TRADEMARK OFFICE
` ____________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _____________
` YITA LLC,
` Petitioner,
` V.
` MACNEIL IP LLC,
` Patent Owner.
` ____________
` Case Nos. IPR2020-01139 and IPR2020-01142
` Patent No. 8,382,186
` _____________
` Videoconference Deposition of "SAMUEL" SHEN CHONG
` Tuesday, August 10, 2021
` 12:03 p.m. EST
`
`Job No.: 391550
`Pages: 1 - 95
`Reported By: Dawn M. Hart, RPR/RMR/CRR
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`EX1050
`Yita v. MacNeil
`IPR2020-01139
`
`
` ____________
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` _____________
` YITA LLC,
` Petitioner,
` V.
` MACNEIL IP LLC,
` Patent Owner.
` ____________
` Case Nos. IPR2020-01139 and IPR2020-01142
` Patent No. 8,382,186
` _____________
` Videoconference Deposition of "SAMUEL" SHEN CHONG
` Tuesday, August 10, 2021
` 12:03 p.m. EST
`
`Job No.: 391550
`Pages: 1 - 95
`Reported By: Dawn M. Hart, RPR/RMR/CRR
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`EX1050
`Yita v. MacNeil
`IPR2020-01139
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`Transcript of Samuel Shen Chong
`Conducted on August 10, 2021
`
`2
`
`Pursuant to Notice, before Dawn M. Hart,
`RPR/RMR/CRR and Notary Public.
`A P P E A R A N C E S
`ON BEHALF OF THE PETITIONER:
`JASON A. FITZSIMMONS, ESQUIRE
`STERNE, KESSLER, GOLDSTEIN & FOX, PLLC
`1100 New York Avenue, Northwest
`Suite 600
`Washington, DC 20005
`(202) 371-2600
`(via videoconference)
`
`ON BEHALF OF THE PATENT OWNER AND THE
`WITNESS:
`DAVID G. WILLE, ESQUIRE
`CLARKE STAVINOHA, ESQUIRE
`BAKER BOTTS, LLP
`2001 Ross Avenue, Suite 900
`Dallas, Texas 75201
`(214) 953-6595
`(via videoconference)
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`3
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` A P P E A R A N C E S (Continued)
`ON BEHALF OF THE PATENT OWNER:
` JEFFERSON PERKINS, ESQUIRE
` PERKINS IP LAW GROUP, LLC
` 4200 Commerce Court, Suite 310
` Lisle, Illinois 60532
` (630) 505-1305
` (via videoconference)
`
`ALSO PRESENT: Lucas Shaker, AV Technician
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`Transcript of Samuel Shen Chong
`Conducted on August 10, 2021
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`4
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` C O N T E N T S
`EXAMINATION OF "SAMUEL" SHEN CHONG PAGE
` By Mr. Fitzsimmons 5
` By Mr. Wille 66
`
` E X H I B I T S
` (Exhibits are attached to the transcript.)
`S. CHONG DEPOSITION EXHIBIT PAGE
` Exhibit A Document displaying Chinese 12
` characters
`
`PREVIOUSLY MARKED EXHIBITS
` Exhibit 2023 Certification of Translation 50
` Exhibit 2137 Certification of Translation 17
` with attachments
` Exhibit 2141 Patent 82
` Exhibit 2142 Patent 86
` Exhibit 2143 Document displaying 66
` Chinese characters
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`Conducted on August 10, 2021
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`5
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` P R O C E E D I N G S
` "SAMUEL" SHEN CHONG
` being first duly sworn or affirmed to
`testify to the truth, the whole truth, and nothing
`but the truth, was examined and testified as
`follows:
` EXAMINATION BY COUNSEL FOR THE PETITIONER
`BY MR. FITZSIMMONS:
` Q Good morning, Mr. Chong.
` Can you please state your full legal
`name for the record?
` A "Samuel" Shen Chong. Shen is --
`Shen Chong is my legal name. S-H-E-N, C-H-O-N-G.
` Q Thanks.
` I'm Jason Fitzsimmons at Sterne,
`Kessler, Goldstein & Fox, on behalf of the
`Petitioner, Yita, LLC, in these matters.
` And do you understand why you're here
`today, Mr. Chong?
` A Yes, for a deposition.
` Q Okay. And so you understand that you're
`having this deposition today in connection with a
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`6
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`declaration and translation that you provided that
`was submitted in an inter partes review proceeding
`at the U.S. Patent and Trademark Office. Do you
`understand that?
` A Yes.
` Q Okay. And the document that you
`translated was in Mandarin Chinese, correct?
` A Yes, in traditional Chinese.
` Q And you translated it into English,
`correct?
` A Yes.
` Q Okay. And just for the record, the case
`numbers here are IPR2020-01139 and IPR2020-01142.
` Do those sound familiar to you?
` A I guess so.
` Q Okay. And have you been deposed before,
`Mr. Chong?
` A Yes.
` Q How many times have you been deposed?
` A Once.
` Q Just once?
` A Yes.
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` Q And when was that?
` A A few years ago.
` Q Do you know how many years ago?
` A Maybe five years ago.
` Q And what matter was that in relation to?
` A In a similar -- translation of
`certain -- certain words or phrases in a
`litigation between two telecommunication
`companies.
` Q Okay. And so the technology at issue
`was telecommunications technology; is that right?
` A Yeah, but the translation related to my
`-- I mean my deposition wasn't related to
`technical issues.
` Q I see. What was -- so it was with
`regards to a document that you translated, though;
`is that right?
` A That's right.
` Q And what was the subject matter, then,
`of the document that you translated?
` A I don't remember.
` Q Okay. And when you were deposed in that
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`matter, were you compensated for the time that you
`spent during your deposition?
` A Yes.
` Q And did you have a standard rate that
`you charged for that?
` A Yes.
` Q And what was that rate?
` A Hourly rate of like -- I forgot exactly
`how much, but it's about a few hundred dollars.
` Q But you're not sure what the exact rate
`was?
` A I forgot it. It's many years ago.
` Q And you understand that you're under
`oath today, correct?
` A Yes.
` Q And just to go over a few ground rules
`to make things run smoothly.
` I just ask that you please speak clearly
`and answer with words rather than nodding your
`head or using hand gestures; is that fine?
` A Yes.
` Q And please just wait until I finish my
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`question so that we don't talk over each other;
`it'll make it easier for the Court Reporter. Do
`you agree?
` A Yes.
` Q And if you don't understand a question,
`will you please tell me?
` A Yes.
` Q And if you don't ask to clarify a
`question, I'll assume that you understood it; is
`that fair?
` A Yes.
` Q Now, counsel for the Patent Owner may
`from time to time object to questions that I ask,
`but you understand that you'll still need to
`answer the question I ask you; do you understand
`that?
` A Yes.
` Q And if at any time you need a break,
`please just let me know. I'd just ask that if
`there's a question pending, that you finish
`answering the question before we take a break; is
`that fair?
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` A Yes.
` Q And do you understand that you can't
`confer with counsel now that the deposition has
`begun?
` A Yes.
` Q Are you under the influence of anything,
`such as medications, that might make it difficult
`for you to understand and answer my questions
`today?
` A No.
` Q Is there any other reason that you can't
`provide your complete and accurate testimony
`today?
` A No.
` Q And since we're doing this deposition
`remotely, I'll just ask you a few additional
`questions.
` Where are you located now?
` A In Alhambra, California.
` Q In California?
` A Yes.
` Q And are you alone in the room?
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` A Yes.
` Q And what equipment are you using to
`participate in the deposition today?
` A A laptop computer.
` Q And do you have a cell phone with you?
` A Not right now.
` Q And do you agree not to communicate with
`anyone via your laptop, cell phone, over the
`internet during the deposition today?
` A I agree.
` Q Thanks.
` Do you have any hard copies of documents
`with you today?
` A No.
` Q So there's nothing in front of you?
` A Right.
` Q No notes in front of you?
` A No notes.
` Q Okay. Thank you.
` MR. FITZSIMMONS: I'd like to ask our
`technician, Lucas, could you please pull up what's
`marked as Deposition Exhibit A for us on the
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`screen.
` AV TECHNICIAN: Absolutely. One moment,
`please.
` Q And, Mr. Chong, you see there's three
`lines numbered 1, 2, and 3 on this exhibit?
` A Yes.
` Q Okay.
` MR. FITZSIMMONS: And Dawn or Lucas, can
`we please mark this as Exhibit A?
` (Exhibit A was marked for identification
`and is attached to the transcript.)
` MR. FITZSIMMONS: Perfect. Thanks.
` Q And each line, 1, 2, and 3, has two
`Chinese characters; is that correct?
` A Yes.
` Q And you recognize the characters?
` A Yes.
` Q And on line 1, "by pressure" would be a
`reasonable translation of those two characters
`into English, correct?
` A If you put it that way, it could be, but
`the two Chinese characters when used together,
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`only the two Chinese characters, they don't make
`any sense.
` Q And so you wouldn't be able to interpret
`these characters here on line 1?
` A If you want to say what -- what the two
`characters mean, I will say "by pressure," but the
`two Chinese characters are not a phrase in
`Chinese.
` Q Okay. And -- but so as a direct
`translation, "by pressure" would be a reasonable
`translation into English; is that right?
` A Yes.
` Q And then on line 2 there, "compression"
`would be a reasonable translation of those two
`characters into English, correct?
` A Yes.
` Q And then on line 3, "forming" would be a
`reasonable translation of those two characters
`into English, correct?
` A Yes.
` Q And the second character on line 1 is
`the same as the first character on line 2,
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`14
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`correct?
` A Yes.
` Q And on line 2, the second character, the
`one on the right, that means to shrink or make
`smaller; is that right?
` A Yes.
` Q And so when you combine the first
`character on line 2 with the second character on
`line 2, you have "pressure" the first character,
`and "to shrink" the second character, and that
`translates to "compression" in English; is that
`right?
` A Yes.
` Q Mr. Chong, can you please spell for
`me -- and I know this may be a little bit
`challenging for our Court Reporter, so we'll do
`our best here -- can you please spell for me with
`Romanized letters how you would translate
`"compression molding technology" from English into
`Mandarin Chinese?
` A Compression molding technology?
` MR. WILLE: Object to the form of the
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`15
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`question.
` A It will be yamo jishu. The spelling
`will be Y-A-M-O, and then "technology" would be
`J-I-S-H-U.
` Q And so would that be two words or three
`words?
` A It'd would be four Chinese characters.
` Q Okay. And similarly, can you please
`spell for me, again with Romanized letters, how
`would you translate "pressure forming technology"
`from English into Mandarin Chinese?
` A Pressure forming?
` Q Pressure forming technology.
` A It will be -- I have to look it up. Can
`I?
` Q And that's not -- so that's something
`you would need to look up in order --
` A Yes, I need to look it up, yes.
` Q -- to spell it?
` A Yes.
` Q Okay. We may revisit that.
` A Okay. One possible translation would be
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`-- well, I think to be more precise, I would need
`to look it up because there are different ways to
`put it. Yeah, there's abbreviated way and there's
`-- I need to look it up.
` Q You said there's an abbreviated way?
` A Yes.
` Q And what would that be?
` A I need to look it up.
` Q Is there a direct translation for the
`term "compression molding technology" between
`English and Mandarin?
` A Yes, there is.
` Q Okay. And is there a direct translation
`between English and Mandarin for "pressure forming
`technology"?
` A I believe so.
` Q Okay.
` MR. FITZSIMMONS: We can put away
`Exhibit A now. I just want to confirm it's marked
`first. I think we marked it, correct?
` AV TECHNICIAN: It is.
` MR. FITZSIMMONS: And then can we pull
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`up now Exhibit 2137, please.
` AV TECHNICIAN: Absolutely. One moment.
` MR. FITZSIMMONS: And we can do that in
`the 1139 proceeding.
` (Exhibit 2137 was previously marked for
`identification and is attached to the transcript.)
` Q And, Mr. Chong, do you recognize this
`document?
` A Yes.
` MR. FITZSIMMONS: And can we just scroll
`through it, please.
` Q And this document is the English
`translation that you provided along with -- after
`this, we'll get to the Chinese language document,
`correct?
` A Yes.
` Q Okay. Thanks.
` MR. FITZSIMMONS: And if we could go
`back to page 1, please.
` Q Is that your signature there on page 1,
`Mr. Chong?
` A Yes.
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` Q And did you sign this on June 2nd, 2021?
` A Yes.
` Q Okay. And so this first page is a
`declaration from you, correct?
` A Yes.
` Q And then pages 2 through 14 are your
`English translation?
` MR. FITZSIMMONS: And if you could
`scroll through that, please, quickly.
` A Yes.
` Q Two through 14 are your English
`translation, correct?
` A Yes.
` Q And then pages 15 through 26 are the
`Chinese language document, correct?
` A Yes.
` Q And the document that you translated is
`Taiwanese Publication No. 363545, correct?
` A Yes.
` Q And if I also refer to that document as
`"the Yang document" for the inventor name, you'll
`understand what I'm referring to, right?
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` A Yes.
` MR. FITZSIMMONS: And, counsel, can we
`stipulate that Exhibit 2137 is the same for both
`proceedings, David?
` MR. WILLE: Yes.
` MR. FITZSIMMONS: Thanks.
` Q Mr. Chong, are you being compensated for
`your time today during this deposition?
` A Yes.
` Q And how much are you being compensated?
` A It goes through the company. I don't
`know exactly how much it is.
` Q And so you don't know the rate that
`you're being paid for today's deposition?
` A I don't know.
` Q You're a co-founder of the company
`Abacus, right?
` A Yes.
` Q But you don't know that information?
` A Right, I don't deal with that.
` Q And did you prepare for today's
`deposition?
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` A Yes.
` Q And what did you do to prepare?
` A I reviewed my declaration and also the
`translation of the patent briefly.
` Q And did you do anything else to prepare?
` A No.
` Q Did you meet with anyone to prepare for
`today's deposition?
` A Yes.
` Q Who did you meet with?
` A David Wille.
` Q Anybody else?
` A No.
` Q And were you compensated for your time
`preparing for today's deposition?
` A I don't know.
` Q How do you not know that?
` A You know, the -- the company just asked
`me to prepare the deposition, and to be here for
`the deposition, and just follow the instructions
`from the company, and I didn't ask how much I was
`compensated for.
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` Q And so you say you reviewed your
`declaration and translation to prepare for today.
`How long did you spend doing that?
` A Like maybe 20 minutes to half-hour.
` Q And in meeting with Mr. Wille, how long
`did you spend doing that?
` A Probably one hour.
` Q And was that meeting by phone?
` A By videoconference.
` Q And when was that?
` A Just like a few days ago.
` Q Was it this week or last week?
` A Last week.
` Q And was it the only time that you met
`with Mr. Wille?
` A There was also a brief conversational
`meeting just before the deposition.
` Q So that would be today?
` A Yes. Today.
` Q And how long was that?
` A Maybe like eight minutes.
` Q And did you speak with anyone else to
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`prepare for today's deposition?
` A No.
` Q And in reviewing your translation, did
`you notice any errors?
` A Not -- not that I know of.
` Q If you notice any errors today, will you
`agree to tell me?
` A Yes.
` Q And in reviewing your translation, is
`there anything that you would translate
`differently after reviewing it again?
` A No.
` Q You have provided translations for legal
`or administrative proceedings before, correct?
` A Yes.
` Q About how many?
` A Like a lot. I mean --
` Q More than a thousand?
` A It's hard to count. I've been doing it
`since 2006.
` Q Have you ever provided a translation for
`an inter partes review matter at the Patent and
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`Transcript of Samuel Shen Chong
`Conducted on August 10, 2021
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`23
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`Trademark Office before?
` A Not the U.S. Patent Office, but China.
` Q Have you ever provided any translations
`related to vehicle floor trays before this one?
` A Vehicle ...
` Q Floor trays.
` A No.
` Q Have you ever worked with the Patent
`Owner, MacNeil, before?
` A No.
` Q Have you ever worked with the
`Baker Botts law firm before?
` A No.
` Q And page 1 of Exhibit 2137, this is your
`Certification of Translation declaration portion.
`Did you type that document?
` A Yes.
` Q Did you type all of it?
` A The facts, the facts, yes.
` Q What do you mean by "the facts"?
` A Like my experiences and also -- the
`format was provided to me by the company, and then
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`Transcript of Samuel Shen Chong
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`24
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`I just filled it in with my own knowledge about
`the facts.
` Q And when you say it was provided to you
`by "the company," do you mean Abacus?
` A Yes.
` Q And again, you're a co-founder of
`Abacus Chinese Translation Services, correct?
` A Yes.
` Q And when did you found the company?
` A Like long time ago, like 2000 -- I think
`before 2006.
` Q Okay. And is translating your full-time
`job?
` A Translation, interpretation is my
`full-time job.
` Q And so you make the distinction between
`translating and interpreting, where translating
`would be documents and interpreting would be like
`spoken language; is that right?
` A Yes.
` Q Okay. And how many hours a week do you
`spend translating or interpreting?
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` A 20 hours.
` Q And how many documents do you translate
`per month?
` A Like based on how many pages? Because
`the documents can be lengthy or short.
` Q So that's fine, go ahead, how many pages
`do you translate per month? That's fine.
` A Maybe like a few hundred.
` Q And you translate documents from
`Mandarin into English?
` A And vice versa, yes.
` Q I was just going to ask you.
` So you also translate from English into
`Mandarin, correct?
` A Yes.
` Q Which language did you learn first?
` A Mandarin.
` Q And do you translate in any other
`languages?
` A Yes.
` Q And what are those?
` A I also do -- when you say translate
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`Conducted on August 10, 2021
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`26
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`means written documents, I do translations from
`traditional Chinese into English and simplified
`Chinese into English and vice versa, and sometimes
`I do translation from Spanish into English or
`Chinese.
` Q And so you also translate, you said,
`Spanish into English or Chinese?
` A Yes.
` Q And what kinds of documents do you
`usually translate?
` A Mostly documents like legal documents or
`documents to be presented as evidence in courts or
`company presentations for business purposes.
` Q And what is your standard translation
`rate?
` A For documents?
` Q For documents, yes.
` A The company deals with it. Normally, I
`will say between 10 cents to 35 cents per word.
` Q And so the way you calculate your rate
`is by word; is that correct?
` A Yes.
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`Transcript of Samuel Shen Chong
`Conducted on August 10, 2021
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`27
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` Q And you gave a range of 10 cents to 35
`cents. Why is there a range?
` A It depends on the difficulty of the
`content of the documents and also how legible the
`documents are.
` Q And how do you determine how difficult a
`document is?
` A It depends on the text. If I need to
`spend a lot of time to review, and mostly if I
`need to spend a lot of time to recognize the
`Chinese characters, because a lot of documents are
`handwritten. Some documents, not a lot, some.
` Q And so the difficulty level, that is
`something that you as the translator determines;
`is that right?
` A Yes.
` Q And what level of difficulty did you
`assign to the document in this matter?
` A I would say towards like technical, more
`difficult than the average court -- the documents
`for evidence for court.
` Q And so what rate did you assign to this
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`Transcript of Samuel Shen Chong
`Conducted on August 10, 2021
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`28
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`matter?
` A I don't know exactly how much we
`charged, but it should be towards like the higher
`range.
` Q And what made you say that the document
`in this case was more difficult than the average
`document?
` A One thing is that it's from Taiwan and
`in Taiwan, for patent documents, they use more
`kind of classical Chinese, the traditional form of
`Chinese, in a way that's not kind of like oral
`language, not like the way that people normally
`talk every day, but in more written form of like a
`formal way, and those I would need to look up some
`of the terminologies, technical phrases.
` Q And you said this is the more
`traditional or classical form of Chinese; is that
`right?
` A Yes.
` Q And most documents that you translate
`are in the simplified Chinese; is that right?
` A Simpli- -- not simplified, but more like
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`Transcript of Samuel Shen Chong
`Conducted on August 10, 2021
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`29
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`the way we talk every day. Like the more -- like
`spoken language, the way of how we talk every day,
`yeah.
` Q And so it's easier to translate when a
`document is written in more spoken language form?
` A Yes.
` Q And you said you needed to look up some
`terminologies or technical phrases, correct?
` A Yes.
` Q What terminologies or technical phrases
`did you need to look up?
` A Some of the key phrases in the patent,
`not just the ones at issue, but also like other
`phrases, too.
` Q Do you recall what other phrases?
` A If you show me the document, I'll point
`it out to you.
` Q The English version or the --
` A The English version would be good, yeah.
` Q Sure.
` MR. FITZSIMMONS: Can we turn over
`control to Mr. Chong so it will be easier for him
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`Transcript of Samuel Shen Chong
`Conducted on August 10, 2021
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`30
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`to manipulate the document.
` AV TECHNICIAN: Absolutely.
` Mr. Chong, if you just click on the
`screen, you should have access.
` A (Reviewing.)
` So, for example, if we take a look at
`Abstract.
` (Reviewing.)
` For example, I looked up some of the
`words like Tetoron cloth. This is one phrase I
`looked up.
` And so -- and also, besides compression
`molding and those I looked up, like foamed
`polyethylene, and ethylene vinyl acetate
`copolymer.
` So some of the technical phrases were
`the ones that I looked up.
` Q And so you said the words you needed to
`look up included compression molding, foamed
`polyethylene, ethylene vinyl acetate, correct?
` A Copolymer, yes.
` Q You also said you looked up Tetoron
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`Transcript of Samuel Shen Chong
`Conducted on August 10, 2021
`
`31
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`cloth, correct?
` A Yes.
` Q Now, is it your understanding that
`Tetoron is a product name?
` A Yes.
` Q And so how did you translate that word?
` A No, when I looked it up, it showed to
`be -- it can either translation after I look it
`up.
` Q And where did you look that up?
` A Let me see. If you look at the Chinese
`version, this is the word for Tetoron cloth. So
`when I look it up, I look it up on two search
`engines, one is Google and the other is -- Google
`Translate, and the other is DeepL. DeepL is
`D-E-E-P-L.com.
` Q And then just for the record, you
`highlighted what has page 2 at the bottom, it's
`the second line from the bottom, and it's the four
`characters at the end of that second line from the
`bottom, correct?
` A Yes.
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`32
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` Q And you mentioned you looked up that in
`Google Translate, correct?
` A Yes, and also DeepL, D-E-E-P-L.
` Q And are those resources that you
`typically use when you're translating documents?
` A Yes. And there may be others. I also
`do sometimes need to do a search on Google, type
`in the source phrases, and also some other ways
`to -- and some other phrase to find exact
`translation of that source phrase.
` Q Do you use any other resources for words
`that you need to look up?
` A I used to use dictionaries, but not
`anymore because it's not necessary anymore.
` Q And so you don't use dictionaries for
`your translations; is that correct?
` A Nowadays, no, but in the past, yes.
` Q And so you didn't use any dictionaries
`for translation you provided here; is that
`correct?
` A That's right.
` Q Other than Google Translate and DeepL,
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`Transcript of Samuel Shen Chong
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`are there any other resources you used in this
`matter to look up words?
` A Google Search.
` Q Google Search.
` A And also Bing search, B-I-N-G search.
` Q And you find those resources to be
`reliable?
` A Yes.
` Q I want to turn back to something briefly
`here. Do you charge the same rate for translating
`from Mandarin into English as you do for English
`into Mandarin?
` A They're about in the same range.
` Q And do you charge a rush fee for a
`certain turnaround time of a document?
` A I do.
` Q And when do you charge that rush fee?
` A Normally when they need it the next day
`or on the same day or maybe in a very short time.
` Q Did you charge a rush fee in this case?
` A I don't know if the company did.
` Q Do you recall how long it took you to
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`Transcript of Samuel Shen Chong
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`34
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`translate the document in this matter?
` A For this one, like I think over a few
`days.
` Q And so you translated over a few days,
`but I assume you didn't spend the entire day
`translating it. So do you know about how many
`hours you spent --
` A I don't --
` Q -- translating the document?
` A I don't remember.
` Q Was it more than one?
` A It's more than one.
` Q Was it less than 20?
` A Yes, I would say less than 20.
` Q Do you think it was less than 10?
` A I don't know.
` Q Do you think it was more than five?
` A Well, I -- I think for the time spent
`it's more than five.
` Q What do you mean "for the time spent it
`was more than five"?
` A Because I also needed to look it up.
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`Transcript of Samuel Shen Chong
`Conducted on August 10, 2021
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`35
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`Some of the phrases. It took me a while to do
`this.
` Q Turning back to your company, Abacus,
`now, how many employees does Abacus have?
` A We have like three.
` Q Three employees?
` A Yes.
` Q And yet you're not aware what was your
`rate in this case?
` A I'm not aware because I don't deal
`with -- with the inquiries during the daytime. I
`only deal with that during the evenings or on the
`weekends.
` Q And are you included in one of those
`three employees?
` A Yes.
` Q So one of the other two employees, do
`they handle those fee matters?
` A Yes.
` Q Do any of your employees live outside of
`the United States?
` A No.
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`Transcript of Samuel Shen Chong
`Conducted on August 10, 2021
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`36
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` Q Have you -- and so when a tr
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