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` UNITED STATES PATENT AND TRADEMARK OFFICE
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ------------------------------
` QUALCOMM INCORPORATED
` Petitioner,
` v.
` MONTEREY RESEARCH LLC,
` Patent Owner.
` ------------------------------
` Inter Partes Review No. IPR2020-01492
` U.S. Patent 6,765,407
`
` ------------------------------
`
`REMOTE VIDEOTAPED DEPOSITION BY VIRTUAL ZOOM OF
` ROBERT J. MURPHY
` Tuesday, May 18, 2021
`
`Reported By: Lynne M. Ledanois, CSR 6811
`
`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`516-608-2400
`
`Monterey Exhibit 2009
`Qualcomm, Inc. v. Monterey Research LLC
`Case IPR2020-01492, 0001
`
`

`

`Page 4
`1 I N D E X O F E X A M I N A T I O N
`
`23
`
`Examination by: Page
`4 Mr. Wueste 8
`
`56789
`
`10
`11
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`13
`14
`15
`16
`17
`18
`19
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`Page 2
`1 UNITED STATES PATENT AND TRADEMARK OFFICE
`2 BEFORE THE PATENT TRIAL AND APPEAL BOARD
`3 ------------------------------
`4 QUALCOMM INCORPORATED
`5 Petitioner,
`6 v.
`7 MONTEREY RESEARCH LLC,
`8 Patent Owner.
`9 ------------------------------
`10 Inter Partes Review No. IPR2020-01492
` U.S. Patent 6,765,407
`
`11
`
` ------------------------------
`
`12
`13
`14 Videotaped deposition of ROBERT J.
`15 MURPHY, taken in Los Gatos, California,
`16 commencing at 8:00 a.m., on Tuesday, May 18,
`17 2021 before Lynne Ledanois, Certified
`18 Shorthand Reporter No. 6811
`19
`20
`21
`22
`23
`24
`25
`
`Page 3
`
`Page 5
`
`1 I N D E X O F E X H I B I T S
`2 Deposition Description Page
`3 Exhibit 2008 Declaration of Robert Murphy 142
`4 in Support of Defendant GSI
`5 Technology, Inc.'s Respon-
`6 sive Claim Construction
`7 Brief;
`
`8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`
`1 REMOTE APPEARANCES
`
`23
`
`Counsel for the Petitioner:
`4 DESMARAIS LLP
`5 BY: MICHAEL WUESTE
`6 BY: RYAN THORNE
`7 Attorneys at Law
`8 230 Park Avenue
`9 New York, New York 10169
`10 mwueste@desmaraisllp
`11
`12 Counsel for the Patent Owner:
`13 NORTON ROSE FULBRIGHT US LLP
`14 BY: DANIEL LEVENTHAL
`15 BY: BRETT McKEAN
`16 Attorneys at Law
`17 1301 McKinney Street
`18 Suite 5100
`19 Houston, Texas 77010-3095
`20 daniel.leventhal@nortonrosefulbright.com
`21 brett.mckean@nortonrosefulbright.com
`22
`23 ALSO PRESENT:
`24 Jill Warren, Videographer
`25
`
`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`2 (Pages 2 - 5)
`
`516-608-2400
`
`Monterey Exhibit 2009
`Qualcomm, Inc. v. Monterey Research LLC
`Case IPR2020-01492, 0002
`
`

`

`Page 6
`
`Page 8
`
`1 Tuesday, May 18, 2021
`2 8:00 a m.
`3 _______________________________________________
`4 VIDEOGRAPHER: Good morning. 07:59
`5 We are on the record at 8:00 a m. 07:59
`6 on Tuesday, May 18, 2021. 08:00
`7 This is the beginning of 08:00
`8 Media Number 1 of the 08:00
`9 video-recorded deposition of 08:00
`10 Robert Murphy taken by counsel for 08:00
`11 patent owner in the matter of 08:00
`12 Qualcomm Incorporated versus 08:00
`13 Monterey Research LLC filed in the 08:00
`14 United States Patent and Trademark 08:00
`15 Office before the Patent Trial and 08:00
`16 Appeal Board. Inter partes review 08:00
`17 number IPR2020-01492. 08:00
`18 This deposition is being 08:00
`19 conducted using Veritext Virtual 08:00
`20 Zoom technology and all 08:00
`21 participants are attending 08:00
`22 remotely. 08:00
`23 Please note microphones are 08:00
`24 sensitive and may pick up 08:00
`25 whispers, private conversations 08:00
`
`1 the oath, then counsel may 08:01
`2 proceed. 08:01
`3 08:01
`4 ROBERT J. MURPHY, 08:01
`5 having been duly sworn, testified as follow08:01
`6 EXAMINATION 08:01
`7 BY MR. WUESTE: 08:02
`8 Q Good morning, Dr. Murphy. 08:02
`9 A Good morning. It's just 08:02
`10 mister. 08:02
`11 Q Okay. Mr. Murphy, would you 08:02
`12 please state your name and address for 08:02
`13 the record? 08:02
`14 A Sure. My name is Robert J. 08:02
`15 Murphy. My address is 72 Fairview, 08:02
`16 that's one word, Plaza. The city is 08:02
`17 Los Gatos, two words, California 08:02
`18 95030. 08:02
`19 Q Mr. Murphy, you've been 08:02
`20 deposed before; correct? 08:02
`21 A That's correct. 08:02
`22 Q How many times? 08:02
`23 A Actually, I've never 08:02
`24 counted. More than ten. 08:02
`25 Q I understand today is your 08:02
`
`Page 7
`
`1 and cellular interference. 08:00
`2 Until all parties agree to 08:00
`3 go off the record, audio and video 08:00
`4 recording will continue to take 08:01
`5 place. 08:01
`6 My name is Jill Warren and 08:01
`7 I'm the videographer. The court 08:01
`8 reporter is Lynne Ledanois and we 08:01
`9 are with Veritext Legal Solutions. 08:01
`10 If there are any objections 08:01
`11 to proceeding, please state them 08:01
`12 at the time of your appearance. 08:01
`13 Beginning with the noticing 08:01
`14 attorney, please state your 08:01
`15 appearance. 08:01
`16 MR. WUESTE: Michael Wueste 08:01
`17 of Desmarais LLP for patent owner 08:01
`18 Monterey Research LLC. 08:01
`19 MR. LEVENTHAL: Daniel 08:01
`20 Leventhal, Norton Rose Fulbright 08:01
`21 US LLP for petitioner Qualcomm 08:01
`22 Incorporated and with me is my 08:01
`23 colleague Brett McKean. 08:01
`24 VIDEOGRAPHER: Thank you. 08:01
`25 The court reporter will administer 08:01
`
`Page 9
`1 first remote deposition; is that 08:02
`2 correct? 08:02
`3 A That's correct. 08:02
`4 Q I understand you are an 08:02
`5 experienced witness, but remote 08:02
`6 depositions are a little bit 08:02
`7 different. The one caution I'll give 08:02
`8 you is that it's never more important 08:02
`9 than in a typical deposition that we 08:02
`10 try not to interrupt each other or 08:03
`11 talk over each other because we're 08:03
`12 dealing with computers and internet 08:03
`13 delays at times. 08:03
`14 I'm going to do my very, 08:03
`15 very best to let you finish my answer 08:03
`16 before I ask another question and I 08:03
`17 ask that you do the same. Is that 08:03
`18 okay? 08:03
`19 A That's okay. 08:03
`20 Q Mr. Murphy, do you 08:03
`21 understand that you're under oath 08:03
`22 today? 08:03
`23 A I do. 08:03
`24 Q Is there any reason you're 08:03
`25 not able to testify truthfully and 08:03
`
`212-267-6868
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`Veritext Legal Solutions
`www.veritext.com
`
`3 (Pages 6 - 9)
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`516-608-2400
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`Monterey Exhibit 2009
`Qualcomm, Inc. v. Monterey Research LLC
`Case IPR2020-01492, 0003
`
`

`

`Page 10
`
`1 accurately today? 08:03
`2 A Not that I am aware of. 08:03
`3 Q My apologies for this. I 08:03
`4 have a couple more questions because 08:03
`5 we're doing this virtually. 08:03
`6 Where are you located today 08:03
`7 to provide your testimony? 08:03
`8 A Located in what sense? 08:03
`9 Q Are you in your house or an 08:03
`10 office? 08:03
`11 A I'm in my house. 08:03
`12 Q And is there anybody else in 08:03
`13 the room with you today? 08:03
`14 A No. 08:03
`15 Q Do you have any documents in 08:03
`16 the room with you today? 08:03
`17 A No. 08:04
`18 Q Okay. 08:04
`19 A Sorry, I have clean copies 08:04
`20 of all the exhibits that were in my 08:04
`21 expert report provided to me by 08:04
`22 counsel. 08:04
`23 Q So just to confirm, do you 08:04
`24 have a paper copy of your declaration 08:04
`25 that you submitted in support of 08:04
`
`Page 11
`
`1 Qualcomm's IPR petition? 08:04
`2 A Yes. 08:04
`3 Q You also have a paper copy 08:04
`4 of all exhibits that were cited in 08:04
`5 your declaration? 08:04
`6 A Correct. That's what I 08:04
`7 asked them to send me and they did 08:04
`8 just because my history is on paper 08:04
`9 really; right? 08:04
`10 Q Understood. And just to 08:04
`11 confirm, you mentioned those are clean 08:04
`12 copies. Neither your declaration nor 08:04
`13 any of the exhibits have any notes on 08:04
`14 them; correct? 08:04
`15 A That is correct. 08:04
`16 Q Are there any other paper 08:05
`17 documents in your room today that 08:05
`18 you've used in preparation for today's 08:05
`19 deposition? 08:05
`20 A No. 08:05
`21 Q Again, my apologies for 08:05
`22 this, it's just something that I want 08:05
`23 to do because we're doing this 08:05
`24 virtually. 08:05
`25 Do you have any other 08:05
`
`Page 12
`1 electronic devices in the room with 08:05
`2 you that you can use to communicate 08:05
`3 other than the device you're currently 08:05
`4 using to appear over Zoom? 08:05
`5 A I have my cell phone here, 08:05
`6 but I understand that it's a 08:05
`7 deposition, I'm not allowed to 08:05
`8 communicate with anyone at least while 08:05
`9 we're still on the record. 08:05
`10 If you would like me to move 08:05
`11 it to the kitchen, I will. 08:05
`12 Q No need to move it to the 08:05
`13 kitchen. I appreciate your 08:05
`14 representation. But if you would 08:05
`15 please turn the cell phone off at 08:05
`16 least while we're on the record. Is 08:05
`17 that okay? 08:05
`18 A Yes, sure. That didn't 08:05
`19 work. How come? It's not something I 08:06
`20 do regularly. 08:06
`21 Q Thank you very much, 08:07
`22 Mr. Murphy. 08:07
`23 A No problem. 08:07
`24 Q I understand that you 08:07
`25 already said this, but just so the 08:07
`
`Page 13
`1 record is clear, you understand you've 08:07
`2 been sworn in and you may not 08:07
`3 communicate with anyone about the 08:07
`4 substance of your testimony during the 08:07
`5 course of today's deposition; correct? 08:07
`6 A Yes, that's pretty standard 08:07
`7 rules for these types of depositions. 08:07
`8 Q Okay. Mr. Murphy, what did 08:07
`9 you do to prepare for today's 08:07
`10 deposition? 08:07
`11 A Well, I certainly reread my 08:07
`12 declaration. I reread various of the 08:07
`13 exhibits that are in my declaration. 08:07
`14 I conferred with counsel. That's 08:07
`15 pretty much most of it. 08:07
`16 Q Okay. Aside from reading 08:07
`17 your declaration and exhibits cited 08:07
`18 within your declaration, did you read 08:07
`19 any other documents in preparation for 08:08
`20 today's deposition? 08:08
`21 A I read the document that is 08:08
`22 referenced in Schaefer which is an 08:08
`23 SDRAM document printed by Microsoft -- 08:08
`24 not Microsoft, Micron. 08:08
`25 And I referenced a 1998 08:08
`
`212-267-6868
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`Veritext Legal Solutions
`www.veritext.com
`
`4 (Pages 10 - 13)
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`516-608-2400
`
`Monterey Exhibit 2009
`Qualcomm, Inc. v. Monterey Research LLC
`Case IPR2020-01492, 0004
`
`

`

`Page 14
`1 version document of the same device. 08:08
`2 Q So to walk through that, in 08:08
`3 addition to your declaration and the 08:08
`4 exhibits cited within your 08:08
`5 declaration, you also reviewed a 08:08
`6 functional specification for a Micron 08:08
`7 SDRAM device; is that correct? 08:09
`8 A Yes. Schaefer references an 08:09
`9 SDRAM device in a particular column 08:09
`10 early in the patent. 08:09
`11 I looked at that to see what 08:09
`12 it had it in because it's an internal 08:09
`13 reference to his patent. 08:09
`14 Then to refresh my memory 08:09
`15 about operations of SDRAMs, I looked 08:09
`16 at a future reference of that same 08:09
`17 part which was printed in 1998, I 08:09
`18 believe. 08:09
`19 Q And neither of those 08:09
`20 documents, the Micron SDRAM functional 08:09
`21 specification or the 1998 future 08:09
`22 revision of that functional 08:09
`23 specification, were explicitly cited 08:09
`24 or separately cited in your 08:09
`25 declaration; correct? 08:09
`
`Page 16
`
`1 that. 08:10
`2 After reviewing the 08:10
`3 functional specification for the 08:11
`4 Micron SDRAM as well as the 1998 08:11
`5 revision of that functional 08:11
`6 specification, do you intend to change 08:11
`7 any of the opinions set forth in your 08:11
`8 declaration sitting here today? 08:11
`9 A I do not. 08:11
`10 Q Okay. You also mentioned in 08:11
`11 preparation for today's deposition, 08:11
`12 you met with counsel; correct? 08:11
`13 A That's correct. 08:11
`14 Q For how long? 08:11
`15 A Two three-day -- sorry, two 08:11
`16 three-hour sessions and one about 08:11
`17 two-and-a-half-hour session, 08:11
`18 approximately. 08:11
`19 Q So in preparation for 08:11
`20 today's deposition, you met with 08:11
`21 counsel for approximately eight and a 08:11
`22 half, nine hours? 08:11
`23 A Yes. 08:11
`24 Q And you met with 08:11
`25 Mr. Leventhal and Mr. McKean? 08:11
`
`Page 15
`
`Page 17
`
`1 A That's correct. 08:09
`2 Q Did you rely on either of 08:09
`3 those documents in the course of 08:10
`4 forming your opinions as set forth in 08:10
`5 your declaration? 08:10
`6 A They are not listed in my 08:10
`7 declaration and the reason they are 08:10
`8 not listed is because I did not rely 08:10
`9 on them. 08:10
`10 Q Okay. Why did you feel the 08:10
`11 need to reference them in preparation 08:10
`12 for today's deposition if you did not 08:10
`13 rely on them in the course of forming 08:10
`14 your opinions as set forth in your 08:10
`15 declaration? 08:10
`16 A Just because it's been 08:10
`17 awhile since I looked at SDRAMs and 08:10
`18 there was a time, it's quite a few 08:10
`19 years ago now, where I was -- all that 08:10
`20 information was very present to me and 08:10
`21 it wasn't as present anymore. So I 08:10
`22 referenced the document just to 08:10
`23 refresh my memory. 08:10
`24 Q In your review of either of 08:10
`25 those documents, did you -- strike 08:10
`
`1 A That's correct. 08:11
`2 Q Anyone else? 08:11
`3 A No. 08:12
`4 Q Mr. Murphy, in how many 08:12
`5 patent cases have you provided expert 08:12
`6 opinions? 08:12
`7 A I don't know the actual 08:12
`8 count. It's, again -- it might be 08:12
`9 ten, it might be slightly over ten, I 08:12
`10 don't know. Everything that I have 08:12
`11 been involved in is listed on my C.V. 08:12
`12 Q Safe to say somewhere 08:12
`13 between ten, 15 cases; is that fair? 08:12
`14 A That would be a good guess I 08:12
`15 would say, yes. 08:12
`16 Q How many of those patent 08:12
`17 cases have been inter partes review 08:12
`18 matters? 08:12
`19 A I don't know. I would 08:12
`20 venture a guess and say at least six; 08:12
`21 but again, it's all in my C.V. 08:12
`22 Q And how many of those ten to 08:12
`23 15 patent cases have been District 08:12
`24 Court matters? 08:12
`25 A Almost the rest of them I 08:13
`
`212-267-6868
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`Veritext Legal Solutions
`www.veritext.com
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`5 (Pages 14 - 17)
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`516-608-2400
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`Monterey Exhibit 2009
`Qualcomm, Inc. v. Monterey Research LLC
`Case IPR2020-01492, 0005
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`

`

`Page 18
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`Page 20
`
`1 would say. I'm finding it hard to 08:13
`2 think of a case that wasn't either in 08:13
`3 District Court or in an IPR. I don't 08:13
`4 think I've ever been involved with one 08:13
`5 that's not one of those two. 08:13
`6 Q Okay. Well, just to 08:13
`7 confirm, maybe this help refresh your 08:13
`8 recollection. 08:13
`9 Have you provided an expert 08:13
`10 opinion in a matter before the 08:13
`11 International Trade Commission? 08:13
`12 A I'm sorry, yes. I have done 08:13
`13 those also. 08:13
`14 Q And how many times have you 08:13
`15 provided expert opinions in front of 08:13
`16 the ITC? 08:13
`17 A Again, I really don't know. 08:13
`18 I didn't go back and count, but more 08:13
`19 than a few times I've been in the ITC. 08:13
`20 Q And how many of the ten to 08:14
`21 15 cases in which you provided expert 08:14
`22 opinions have you submitted an expert 08:14
`23 report or an expert declaration? 08:14
`24 A I don't know the answer to 08:14
`25 that. I would say most of them. My 08:14
`
`1 documents that I have read. 08:15
`2 And then I then discuss 08:15
`3 those opinions with counsel and it's 08:15
`4 generally a back-and-forth arrangement 08:15
`5 where I would say I provide what I 08:15
`6 believe is going to be my opinion and 08:15
`7 provide what I believe is the support 08:15
`8 for that opinion. 08:15
`9 Then usually counsel will 08:15
`10 review that and then if they think 08:15
`11 there is something I haven't 08:16
`12 considered or something else that I 08:16
`13 should look at, then we go through 08:16
`14 that back and forth. 08:16
`15 And eventually we have 08:16
`16 seen -- well, enough material is made 08:16
`17 available for me to finish making my 08:16
`18 opinion and then I ask counsel to 08:16
`19 write the first drafting, which should 08:16
`20 encompass all of the opinions that I 08:16
`21 have discussed with them. 08:16
`22 And then from there, I edit 08:16
`23 the document and then pass it back to 08:16
`24 counsel and the document will go back 08:16
`25 and forth where I try and hone, if you 08:16
`
`Page 19
`1 guess would be 85 or 90 percent. 08:14
`2 Q So would you say that you've 08:14
`3 submitted an expert declaration or 08:14
`4 expert report in around ten of the 08:14
`5 matters? 08:14
`6 A Yes, it's just a guess. 08:14
`7 I've been doing this since '98. 08:14
`8 You're asking me to remember all that 08:14
`9 stuff. 08:14
`10 Q Completely understood. It's 08:14
`11 not a memory test at this point in 08:14
`12 time. 08:14
`13 So I just want to get a 08:14
`14 sense of your experience. 08:14
`15 A Mm-hmm. 08:15
`16 Q Mr. Murphy, what is your 08:15
`17 typical process for writing an expert 08:15
`18 declaration? 08:15
`19 A My typical process for 08:15
`20 writing an expert declaration is that 08:15
`21 I generally read all of the material 08:15
`22 that has been provided to me by 08:15
`23 counsel. 08:15
`24 And then I start to form my 08:15
`25 opinions about what I see in the 08:15
`
`Page 21
`
`1 will, the language so that it 08:16
`2 expresses my opinions succinctly. 08:16
`3 Q Safe to say that you are the 08:16
`4 one that comes up with the opinions 08:17
`5 set forth in the declarations in your 08:17
`6 typical declaration-writing process; 08:17
`7 correct? 08:17
`8 A Yes. 08:17
`9 Q You stand by the opinions in 08:17
`10 any declaration you submit; is that 08:17
`11 correct? 08:17
`12 A Of course. 08:17
`13 Q Mr. Murphy, do you 08:17
`14 understand that you're testifying 08:17
`15 today regarding an IPR petition 08:17
`16 Qualcomm has brought against U.S. 08:17
`17 Patent Number 6,651,134 owned by my 08:17
`18 clients, Monterey Research LLC? 08:17
`19 A Yes, I do. 08:17
`20 Q If I refer to that patent as 08:17
`21 the '134 patent, will you understand 08:17
`22 what I mean? 08:17
`23 A I will. 08:17
`24 Q When was the first time you 08:17
`25 looked at the '134 patent? 08:17
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`Qualcomm, Inc. v. Monterey Research LLC
`Case IPR2020-01492, 0006
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`Page 22
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`Page 24
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`1 A I don't remember, to tell 08:17
`2 you the truth. It was in the middle 08:17
`3 of the pandemic, as I recall. I don't 08:17
`4 remember. I would have to go back and 08:18
`5 look. 08:18
`6 Q Had you looked at the '134 08:18
`7 patent before this matter, this inter 08:18
`8 partes review matter? 08:18
`9 A Yes. I believe the '134 was 08:18
`10 involved in an action between Cypress 08:18
`11 and GSI, which I'm pretty sure is on 08:18
`12 my C.V. 08:18
`13 Q Roughly when had you looked 08:18
`14 at the '134 patent in the Cypress/GSI 08:18
`15 matter? 08:18
`16 A I don't really know. Let's 08:18
`17 see. Let me think that out a little 08:18
`18 bit. 08:18
`19 I think that was roughly 08:18
`20 during the year that my wife had 08:18
`21 pancreatic cancer, as I recall, and -- 08:18
`22 I remember that that year I had four 08:19
`23 depositions and I think one of them 08:19
`24 was Cypress/GSI. 08:19
`25 And she -- she died in 2014. 08:19
`
`1 Q That's correct. 08:20
`2 A I can see it. 08:20
`3 Q For the record, previously 08:20
`4 marked Exhibit 1015 is a complete copy 08:20
`5 of your declaration in IPR2020-01492 08:20
`6 regarding U.S. Patent 08:20
`7 Number 6,651,134; correct? 08:20
`8 A Yes, it appears to be. It 08:20
`9 has my signature on the last page and 08:21
`10 it's dated 8/20 of 2020. 08:21
`11 Q Mr. Murphy, I understand you 08:21
`12 have a paper copy of your declaration 08:21
`13 in the room with you today? 08:21
`14 A I do. 08:21
`15 Q Can you take a brief moment 08:21
`16 just to make sure that the version of 08:21
`17 your declaration that has been 08:21
`18 uploaded over Exhibit Share is 08:21
`19 identical to your paper copy. 08:21
`20 I'm happy to let you use the 08:21
`21 paper copy. I just want to make sure 08:21
`22 there aren't any huge differences 08:21
`23 between the two of them as we go 08:21
`24 through today's deposition. 08:21
`25 A Okay. I can do that. You 08:21
`
`Page 23
`1 So I would say late 2013, or 2014. 08:19
`2 That's the best I can put on it. 08:19
`3 Q My sincere condolences for 08:19
`4 you and your wife. 08:19
`5 A Thank you. 08:19
`6 Q In today's IPR proceeding, 08:19
`7 you've put forth some opinions 08:19
`8 regarding the validity of the '134 08:19
`9 patent; correct? 08:19
`10 A Correct. 08:19
`11 Q You provided a declaration 08:19
`12 describing your opinions regarding the 08:19
`13 validity of the '134 patent; correct? 08:19
`14 A Correct. 08:19
`15 Q Mr. Murphy, I have uploaded 08:19
`16 through Exhibit Share an exhibit that 08:19
`17 has been previously marked as 08:20
`18 Exhibit 1015. 08:20
`19 You may have to re-click the 08:20
`20 Exhibit Share file to refresh the page 08:20
`21 so you can see it. 08:20
`22 A Exhibit 1015. 08:20
`23 BY MR. WUESTE: 08:20
`24 Q That's correct. 08:20
`25 A My declaration? 08:20
`
`Page 25
`1 understand what you've put up as an 08:21
`2 electronic file is 94 pages long. 08:21
`3 So I can check a few pages 08:21
`4 and then -- I'm pretty sure that it's 08:21
`5 identical, but I will look. 08:21
`6 Q I appreciate that. You 08:21
`7 don't need to check every single page, 08:21
`8 just as long as you're comfortable 08:22
`9 that the version that has been 08:22
`10 uploaded as an exhibit is the same as 08:22
`11 the version in front of you, the paper 08:22
`12 copy in front of you, that's all I'm 08:22
`13 looking for. 08:22
`14 (Discussion off the record.) 08:22
`15 THE WITNESS: Okay. So what 08:26
`16 I did as a check is just picked 08:26
`17 some random pages like, for 08:26
`18 instance, 6, 20, 24, 41, all the 08:26
`19 way through to 93 just randomly. 08:26
`20 And then looked to see that the 08:26
`21 words at the bottom of the page in 08:26
`22 the electronic document matched 08:26
`23 the paper document that I have. 08:26
`24 And that would basically say 08:26
`25 if there was something missing or 08:27
`
`212-267-6868
`
`Veritext Legal Solutions
`www.veritext.com
`
`7 (Pages 22 - 25)
`
`516-608-2400
`
`Monterey Exhibit 2009
`Qualcomm, Inc. v. Monterey Research LLC
`Case IPR2020-01492, 0007
`
`

`

`Page 26
`
`1 if lines had changed, it would 08:27
`2 have -- at some point in the 08:27
`3 document it would have shown up as 08:27
`4 a difference somewhere. 08:27
`5 So I believe this to be an 08:27
`6 identical copy to what you have 08:27
`7 shown electronically. 08:27
`8 BY MR. WUESTE: 08:27
`9 Q Thank you very much, 08:27
`10 Mr. Murphy. As I said, if you prefer 08:27
`11 to use your paper copy now that we've 08:27
`12 established that they are identical, 08:27
`13 feel free to do so. Whatever is -- 08:27
`14 A Okay. 08:27
`15 Q Mr. Murphy, did you write 08:27
`16 your declaration? 08:27
`17 A I did not write all of the 08:27
`18 declaration. I certainly wrote parts 08:27
`19 of it and counsel helped me write 08:27
`20 other pieces of it, which I thoroughly 08:27
`21 checked and I have adopted as my own. 08:27
`22 Q All of the opinions 08:27
`23 expressed in -- strike that. 08:27
`24 All the opini